ASSOCIATE’S

HANDBOOK
ABOUT THIS HANDBOOK
ANY STORES OWNED AND OPERATED BY ROCHE BROS. CO., INCLUDING BUT NOT LIMITED
TO ROCHE BROS. SUPERMARKETS, SUDBURY FARMS AND BROTHERS MARKETPLACE WILL BE
REFERENCED IN THIS HANDBOOK AS “ROCHE BROS.” AND/OR “THE COMPANY”.

THE POLICIES IN THIS HANDBOOK REFLECT THE COMPANY’S VALUES, AND WE EXPECT EACH
ASSOCIATE TO READ THIS ASSOCIATE HANDBOOK CAREFULLY AS IT IS A VALUABLE REFERENCE
FOR UNDERSTANDING YOUR JOB AND THE COMPANY. THIS HANDBOOK DOES NOT CONSTITUTE OR
IMPLY A CONTRACT OF EMPLOYMENT BETWEEN ROCHE BROS. AND ITS ASSOCIATES (HEREINAFTER
REFERRED TO AS “ASSOCIATES”). NOR DOES THIS HANDBOOK ALTER THE COMPANY’S RIGHT OF
ITS ASSOCIATES TO TERMINATE THE EMPLOYMENT RELATIONSHIP AT ANY TIME FOR ANY REASON,
WITH OR WITHOUT NOTICE. THIS “AT-WILL” RELATIONSHIP CAN ONLY BE MODIFIED BY A WRITTEN
CONTRACT OF EMPLOYMENT WHICH IS SIGNED BY THE CHIEF OPERATING OFFICER AND EXPRESSLY
MODIFIES THE AT-WILL NATURE OF EMPLOYMENT.

THE PURPOSE OF THIS HANDBOOK IS TO PROVIDE ROCHE BROS. ASSOCIATES WITH GENERAL
INFORMATION REGARDING THE COMPANY’S GUIDELINES. THE COMPANY RESERVES THE RIGHT
TO RESCIND, MODIFY, OR DEVIATE FROM THESE OR OTHER GUIDELINES, POLICIES, PRACTICES,
OR PROCEDURES RELATING TO EMPLOYMENT MATTERS FROM TIME TO TIME AS IT CONSIDERS
NECESSARY IN ITS SOLE DISCRETION, EITHER IN INDIVIDUAL OR COMPANY-WIDE SITUATIONS,
WITH OR WITHOUT NOTICE. THE COMPANY MAY, AT ANY TIME, WITH OR WITHOUT NOTICE, MODIFY,
ALTER, AMEND, SUPPLEMENT, OR DELETE ANY OF THE POLICIES AND PROCEDURES CONTAINED
IN THIS HANDBOOK. NOT ALL OF THE COMPANY’S POLICIES AND PROCEDURES ARE SET FORTH
IN THIS ASSOCIATE HANDBOOK.

NOTHING IN THIS HANDBOOK OR IN ANY OTHER DOCUMENT OR POLICY IS INTENDED TO VIOLATE

ANY LOCAL, STATE OR FEDERAL LAW. NOTHING IN THIS HANDBOOK OR IN ANY OTHER DOCUMENT
OR POLICY IS INTENDED TO LIMIT ANY CONCERTED ACTIVITIES BY ASSOCIATES RELATING TO THEIR
WAGES, HOURS OR WORKING CONDITIONS, OR ANY OTHER CONDUCT PROTECTED BY SECTION
7 OF THE NATIONAL LABOR RELATIONS ACT. FURTHERMORE, NOTHING IN THIS HANDBOOK
PROHIBITS AN ASSOCIATE FROM REPORTING CONCERNS TO, FILING A CHARGE OR COMPLAINT
WITH, MAKING LAWFUL DISCLOSURES TO, PROVIDING DOCUMENTS OR OTHER INFORMATION TO
OR PARTICIPATING IN AN INVESTIGATION OR HEARING CONDUCTED BY THE EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION (“EEOC”), NATIONAL LABOR RELATIONS BOARD (“NLRB”), SECURITIES
AND EXCHANGE COMMISSION (“SEC”) OR ANY OTHER FEDERAL, STATE OR LOCAL AGENCY
CHARGED WITH THE ENFORCEMENT OF ANY LAWS.

THIS ASSOCIATE HANDBOOK REPLACES ALL OTHER PREVIOUS ASSOCIATE HANDBOOKS AND
ANY PRIOR INCONSISTENT ORAL OR WRITTEN STATEMENTS AS OF JANUARY 1, 2019.
Welcome to the Roche Bros. Family!
Since our company was founded in 1952, we have enjoyed steady growth,
not only in size but in the standards of excellence by which we operate.
We pride ourselves on our customer service, our dedicated associates
and our belief in the “Golden Rule”— to treat others the way you want to
be treated — when dealing with our customers, associates, vendors and
the communities we serve.

We hope you will share the same pride in your job and enthusiasm for
our company as do all our associates. We succeed not from any one
individual’s efforts, but from our collective efforts as a team. It takes each
of us giving 100% to succeed, and we know that you will add your own
contributions to the Roche Bros. success story.

Our policy is to treat all our associates fairly and to expect that each will
maintain the highest standards of integrity and honesty while working
together in the best interests of our company. Together we can make our
stores the best place to shop, as well as the ideal place to work.

Welcome again to Roche Bros.! We look forward to having you on

our team.

Rick & Ed Roche

ASSOCIATE’S HANDBOOK | 1
 Table of Contents
Our Company
OUR MISSION 3 SMOKE-FREE WORKPLACE 15

OUR BELIEF 3 STANDARDS OF CONDUCT 15

OUR VALUES 3 HONESTY AND INTEGRITY 16

CUSTOMER SERVICE 4 ATTENDANCE AND WORK SCHEDULES 17

COMPANY OBJECTIVES 4 ASSOCIATE PARKING 17

 HY IS CUSTOMER SERVICE
W ASSOCIATE SHOPPING 17
IMPORTANT TO EVERY ASSOCIATE? 4
ASSOCIATES UNDER 18 YEARS OF AGE 18
 HY IS EVERY ASSOCIATE
W
STORE FACILITIES 18
IMPORTANT TO THE CUSTOMER? 4
OUTSIDE EMPLOYMENT 18
 OW CAN YOU SERVE THE
H
CUSTOMER BETTER? 4 CONTACT WITH THE MEDIA 19
100% SATISFACTION GUARANTEE 5 CONFLICTS OF INTEREST 19
ADVERTISING GUARANTEE 5 RELATIONSHIPS IN THE WORKPLACE 19
CUSTOMER ASSISTANCE 5 SOLICITATION AND DISTRIBUTION 20
SPECIAL SERVICES 5 SAFETY RULES 20
UNIQUE SITUATIONS 5 DRESS CODE FOR STORE ASSOCIATES 20
NO TIPPING POLICY 5 PERSONAL APPEARANCE/HYGIENE 21

SCHEDULES, PAYCHECKS AND COMPENSATION 21

Our Business Environment
PERSONAL PROPERTY 24
EQUAL EMPLOYMENT OPPORTUNITY 6
REST PERIODS 24
HARASSMENT FREE WORKPLACE 7
PERSONNEL RECORDS 24
OPEN DOOR PHILOSOPHY 8
LEAVE OF ABSENCE 25
COMMUNICATION 9
SERVICE AWARD RECOGNITION PROGRAM 30
AT-WILL EMPLOYMENT 9
WORKERS’ COMPENSATION 30
INTRODUCTORY PERIOD 9
LACTATION ACCOMMODATION 30
EMPLOYMENT CATEGORIES 10
SEVERE WEATHER CONDITIONS 30
BACKGROUND INVESTIGATION 10
TRAVEL PAY 31
ENGLISH ONLY 10
RESPONSIBLE UTILIZATION OF
ELIGIBILITY TO WORK IN THE UNITED STATES 10 ELECTRONIC COMMUNICATION SYSTEMS 31
BENEFITS PROGRAM 10 SOCIAL MEDIA 32
PAID TIME OFF 11 CONFIDENTIAL AND PROPRIETARY
BUSINESS INFORMATION 34
VIOLENCE-FREE WORKPLACE 13
RECEIPT OF ASSOCIATE’S HANDBOOK 35
SUBSTANCE-FREE WORKPLACE POLICY 13

2 | ASSOCIATE’S HANDBOOK
Our Company
Since 1952, Roche Bros. has strived to offer the highest quality of
products with an extra focus on customer service. It all started with
the simple philosophy of operating the business based on the
“Golden Rule”—Treat others the way you would want to be treated.

At Roche Bros., we prove why we Roche Bros. recognizes through OUR VALUES
are the premier grocery store in the dedication of our associates
To deal fairly with all customers,
the Greater Boston Area. We offer that the Company will be able to
associates, suppliers, and the
the freshest fruits and vegetables, achieve:
general public.
an amazing variety of poultry,
meat and seafood and the finest OUR MISSION To offer our associates
selection of breads and desserts. To operate retail outlets in a opportunity to improve their
highly ethical manner with special managerial skills so the company
Our commitment to customer
emphasis on customer service and will have the necessary depth of
service requires each associate to
quality of goods. managerial talent.
have a strong focus on providing
excellent service to our customers To further enhance our image for
and to the communities we serve. OUR BELIEF excellence in every phase of our
We refer to the people that work To adhere to the Golden Rule in operation.
at Roche Bros as “associates” all our relations with customers, To increase our position of
because we believe that we work associates, suppliers, and the leadership in the industry and the
with each other, not for each general public. community.
other. It’s done in a positive work
To operate at a net profit that will
environment where each of us
provide a return on investment
strives to achieve success and
and develop sufficient capital for
personal satisfaction. Your store
further growth.
director and other members of
management including buyers, To continue profitable growth
merchandisers, and directors along well planned lines, to assure
comprise our Store Support a long and pleasant life for the
Team. Each member of this team company and associates.
supports your efforts in providing
the highest level of customer
satisfaction. We are committed
to a management style that is
Respectful, Supportive, and Totally
Team Oriented (RSTO) and follows
the Golden Rule.

ASSOCIATE’S HANDBOOK | 3
 Customer Service
Our success is based on a commitment to our customers, the
communities we serve and to our associates who take pride in their
work. Roche Bros. is committed to delivering the highest level of
customer service and we expect each associate to work in a manner
that is consistent with this philosophy to achieve our goals.

Roche Bros. will provide customer WHY IS CUSTOMER SERVICE HOW CAN YOU SERVE THE
relations and services training IMPORTANT TO EVERY CUSTOMER BETTER?
to all associates with extensive ASSOCIATE?
The Right Attitude:
customer contact. Customers who
• The customer is the lifeblood of • A warm smile and greeting –
wish to lodge specific comments or
our business. eye contact.
complaints should be directed to a
member of the store management
• Satisfied customers mean repeat • Finding ways of making the
team for appropriate action.
business when happy customers customer feel special.
Positive customer relations not only
return again and again; and
enhance the public’s perception or
new business when customers • A positive outlook.
image of Roche Bros., but also pays
recommend us to others.
off in greater customer loyalty and
• A neat and well-groomed
increased sales and profit!
• Satisfied customers mean success appearance.
which results in continued growth,
COMPANY OBJECTIVES
security in our jobs, and more • A sense of humor.
• To adhere to the Golden Rule in advancement opportunities for all
all our relations with customers, associates. • Pride in your job.
associates, suppliers, and the
public. We define the Golden Rule • The customer is our main priority • A sincere “thank you” for
as follows: Treat others the way and our reason for being. shopping with us.
you want to be treated.
WHY IS EVERY ASSOCIATE The Right Knowledge:
• To provide products and services IMPORTANT TO THE CUSTOMER? • Know our store services.
of the highest quality and greatest
• You represent the company.
possible value in our retail stores, • Know the location of items so
gaining and holding our that you will be able to take the
• No matter what your job is, we all
customers’ respect and loyalty. customer to them.
serve the customer.

• To do business with customers, • Keep up-to-date on new products.

• While there are many associates
associates, suppliers and
in the store, to the customer, you
the community based on • Know what’s on sale.
represent the company.
uncompromising honesty
and integrity. • Know our policies.
• Your attitudes and actions will
determine whether we meet the
customer’s expectations of
excellent service.

4 | ASSOCIATE’S HANDBOOK
The Right Communication: CUSTOMER ASSISTANCE NO TIPPING POLICY
• Be alert to the customer’s need
Our customers deserve our full It is our policy to provide all our
for assistance, even if they don’t
attention. When a customer asks services in a prompt and cheerful
ask.
a question about the location of a manner. This high service level
product, take the customer to the is Roche Bros.’ most important
• Don’t guess about price, products,
particular product. If your customer quality that sets us apart from the
or procedures. Be accurate!
assistance responsibilities do not competition. Accepting tips for any
permit you to leave your job station, service is not allowed because it
• Recognize the customers you see
call another associate to take the would increase the customer’s cost
frequently.
customer to the item. When you of shopping at Roche Bros. and
get a request for an item that is would diminish our competitive
• Volunteer additional information.
not available, find out why it is not advantage. Failure to comply with
available. Ask: is it out of stock this policy may result in disciplinary
• Always rule in favor of the
temporarily or is it not carried? action, up to and including
customer.
Whatever the question, be sure termination.
the answer is clear and correct and
• Remember: The customer is
the customer is satisfied with the
always right!
information.

100% SATISFACTION GUARANTEE

SPECIAL SERVICES
Because we are committed to
An opportunity to fulfill a special
providing our customers with
request for a customer is an
service, quality, value, and variety,
opportunity to provide extra service,
our customer’s satisfaction is
which we take pride in doing. We
unconditionally guaranteed or the
should try to find a way to honor
full purchase price will be promptly
these requests whenever possible.
and courteously refunded.
You should be familiar with what
our services are so you can satisfy
ADVERTISING GUARANTEE
customer needs.
Our policy is to provide sufficient
supplies of advertised items for our UNIQUE SITUATIONS
customers. To back up this policy,
Sometimes a situation arises
it is our practice, should we run
for which there is no clear
out of any advertised item prior to
policy. If that happens, ask your
the end of the sale, to substitute
department manager for help. If
a comparable item or issue a rain
you need to act on your own due
check.
to the circumstances, use your best
judgment and discuss the situation
with your manager as soon as
possible. A rule of thumb to keep
in mind is to rule in favor of the
customer.

ASSOCIATE’S HANDBOOK | 5
 Our Business Environment
EQUAL EMPLOYMENT OPPORTUNITY
Roche Bros. believes that all associates should treat their
colleagues with respect and dignity, and we are committed to
our objective of providing equal employment opportunity and
maintaining a workplace free of harassment, intimidation,
and exploitation of any nature.

EQUAL EMPLOYMENT as third parties, such as vendors or prohibited by this policy.

OPPORTUNITY customers. Associates can raise concerns
Roche Bros. believes that and make reports without fear
Roche Bros. is an equal opportunity
maintaining a diverse team of of reprisal. Retaliation against
employer and is committed to
associates encourages open associates who raise an issue
providing equal employment
communication and a free flow under this policy or participate
opportunity and maintaining a
of ideas. Any associate who in an investigation is prohibited.
workplace free of harassment,
feels that he or she has been Associates who believe they have
intimidation, and exploitation of any
treated in violation of this policy been retaliated against must
nature.
is encouraged to discuss this report the incident to Human
Roche Bros. provides equal situation with his or her supervisor, Resources or a member of senior
employment opportunity to all department manager, a member of management who is not engaging
associates and applicants for senior management, or a member of in the complained conduct. Anyone
employment. The Company the Human Resources Department. found to be engaging in any type
prohibits discrimination based on If the associate is not comfortable of discrimination or retaliation
an individual’s race, sex, gender, reporting the incident to a member in violation of this policy will be
ethnicity, religion, creed, age, of the management team or if the subject to disciplinary action, up
color, military/veteran status, issue is not resolved after reporting to and including termination of
sexual orientation, gender identity, it to a member of the management employment.
disability, genetic information, team, report the matter to a Reasonable Accommodations
ancestry, national origin, pregnancy, member of the Human Resources
childbirth or related medical The Company provides reasonable
Department at (781) 235-9400.
conditions or any other category accommodations for the known
After a report is received, a prompt physical or mental disabilities of
protected by applicable local,
and thorough investigation by otherwise qualified associates,
state or federal law. Our policy of
management will be undertaken. unless the accommodation would
non-discrimination applies to all
The Company expects that all impose an undue hardship on
phases of our association with you
associates fully cooperate with the operation of our business
including, but not limited to, hiring,
any investigation conducted by or would pose a direct threat
promoting, layoff or termination,
the Company into a complaint of to the health and safety of the
discipline, rates of pay or other
discrimination. If we determine individual or others. The Company
forms of compensation and
that this policy has been violated, will also consider requests for
selection for training. This policy
remedial action will be taken, reasonable accommodations for
applies to all persons involved
commensurate with the severity medical conditions related to
in our operations and prohibits
of the offense. Appropriate action pregnancy, childbirth and lactation
harassing conduct by any associate,
will also be taken to deter any where supported by medical
including nonsupervisory associates,
future harassment or discrimination documentation and/or as required
supervisors and managers, as well

6 | ASSOCIATE’S HANDBOOK
by applicable federal, state or local orientation, religion, disability, also include sexual joking, vulgar
law. national origin, military/ veteran or offensive conversation or jokes,
If you require assistance to perform status, ethnicity, gender identity, commenting about an associate’s
your job duties, please let us know. genetic information, ancestry, or physical appearance, conversation
any other characteristics about your own or someone else’s
We also provide reasonable
protected by applicable law sex life, teasing or other conduct
accommodation for sincerely held
• Threats, whether verbal or directed toward a person because
religious beliefs, consistent with
otherwise of his or her gender which is
applicable law. If you require an
sufficiently severe or pervasive to
accommodation, please contact • Physical harm such as hitting,
create an unprofessional and hostile
Human Resources. pushing, or other aggressive
working environment.
physical conduct
Sexual harassment is unlawful
HARASSMENT FREE WORKPLACE • Distribution of derogatory
electronic mail or display of “Sexual harassment” means sexual
Roche Bros. believes that all
derogatory material, such as advances, requests for sexual favors
associates should be treated
posters, cartoons etc. based on a and verbal or physical conduct of a
professionally. It is the policy of the
protected characteristic sexual nature when:
Company to prohibit intentional and
unintentional harassment of any • Unwelcome conduct such as (a) submission to or rejection
individual by another person on the sexual advances, demands for of such advances, requests or
basis of any protected classification sexual favors, or other verbal or conduct is made, either explicitly
under applicable federal, state or physical conduct of a sexual or implicitly, a term or condition
local law. Harassment based on a nature of employment or as a basis for
protected characteristic is illegal employment decisions; or
Similarly, it is the Company’s
and harassment, even if it does not policy to prohibit harassment of (b) such advances, requests or
rise to the level of being illegal may any associate by an associate, conduct have the purpose or effect
still violate this policy. including supervisors, managers and of unreasonably interfering with an
Accordingly, harassment in the associates, and third parties, such as individual’s work performance by
workplace is prohibited based on a vendors and customers on the basis creating an intimidating, hostile,
person’s race, sex, gender, ethnicity, of a protected characteristic. humiliating or sexually offensive
religion, creed, age, color, military/ work environment.
Sexual harassment is a particular
veteran status, sexual orientation, type of harassment. While it is not If an associate believes that he/she
gender identity, disability, genetic easy to define precisely what types has been subjected to or otherwise
information, ancestry, national of conduct could constitute sexual witnessed conduct in violation of
origin, pregnancy, childbirth or harassment, examples of prohibited this policy, he/she should:
related medical conditions or behavior include unwelcome sexual • Report the harassment to a
membership in any other category advances, requests for sexual member of the management
protected by applicable law. favors, obscene gestures, displaying team.
Harassment can include verbal, sexually graphic magazines,
physical, or visual conduct that calendars, or posters, sending
creates an intimidating or offensive sexually explicit e-mail, voice-mail,
work environment. Some examples graphics, downloaded material
of harassment, depending on the or websites, and other verbal or
facts and circumstances, may physical conduct of a sexual nature,
include, but are not limited to: such as uninvited touching of a
• Unwelcome or derogatory sexual nature or sexually-related
comments regarding a person’s comments. Depending upon the
race, color, age, gender, sexual circumstances, the conduct can

ASSOCIATE’S HANDBOOK | 7
 • If the associate is not comfortable the investigation of such reports Worcester Office:
reporting the incident to a in accordance with this policy. 488 Main Street, Room 320
member of the management Retaliation is unlawful. Any form of Worcester, MA 01608
team or if the issue is not resolved retaliation in violation of this policy (508) 453-9630
after reporting it to a member of will result in disciplinary action,
the management team, report the up to and including termination OPEN DOOR PHILOSOPHY
matter to a member of the Human of employment. Associates who
Roche Bros. recognizes that
Resources Department at believe they have been retaliated
satisfied associates and successful
(781) 235-9400. against must report the incident
operations go hand in hand;
Any associate who has witnessed to Human Resources or a member
therefore, as a company we place
conduct in violation of this policy of senior management who is not
great importance on creating and
or believes that such behavior has engaging in the complained of
maintaining strong relations with
occurred is required to bring this conduct.
all associates. It is the Company’s
behavior to the attention of the While associates are encouraged commitment that every suggestion,
appropriate manager and/or the to report claims internally, if an complaint, question or concern
Human Resources Department associate believes that he or she be thoroughly investigated and
immediately. This includes reporting has been subjected to sexual addressed by appropriate action
inappropriate actions of non- harassment, he or she may file a and follow-up. We believe that
associates while on Company formal complaint with either or both with better communication, higher
property or at an off-site business of the government agencies set morale and higher productivity
function. forth below. Using the Company’s is achieved when managers and
Every report of perceived complaint process does not prohibit associates are able to interact
harassment will be promptly an associate from filing a complaint directly with each other.
and thoroughly investigated. with these agencies.
There are many avenues to present
The Company expects that all The contact information for those your suggestions and/or questions
associates fully cooperate with agencies is as follows: to the Company:
any investigation conducted by The United States Equal • First, speak to your department
the Company into a complaint Employment Opportunity manager.
of harassment. If we determine Commission (“EEOC”)
that this policy has been violated, • Second, if you are not satisfied
JFK Federal Building, Room 475
remedial action will be taken, with your department manager’s
Boston, Massachusetts 02203
commensurate with the severity response, or you are not
(617) 565-3200
of the offense. Appropriate comfortable raising the concern
The Massachusetts Commission with your department manager,
action will also be taken to
Against Discrimination (“MCAD”) you may bring the issue to the
deter any future harassment or
discrimination prohibited by this Boston Office: attention of the Store Director and/
policy. Such disciplinary action One Ashburton Place, Room 601 or Assistant Store Manager.
may include, but is not limited to, Boston, Massachusetts 02108 • If difficulty continues, or you
verbal counseling, written warning, (617) 727-3990 are not comfortable raising your
demotion, suspension, and any Springfield Office: concerns to those above, you
other action deemed appropriate, 436 Dwight Street, Room 220 may go to the Director of your
up to and including termination of Springfield, Massachusetts 01103 department, the Director of Human
employment. (413) 739-2145 Resources or the Vice President of
In addition, the Company will New Bedford Office: Store Operations.
not allow any form of retaliation 800 Purchase St., Room 501 If you are still not satisfied with
against individuals who report New Bedford, MA 02740 the resolution of the problem, you
unwelcome conduct to Company (508) 990-2390 may request a meeting with the
management or who cooperate in
8 | ASSOCIATE’S HANDBOOK
company Chief Operating Officer. Workstations or agreement contrary to this policy,
We encourage you to follow this To maintain a professional except for the Chief Operating
procedure to resolve any problems workplace, the Company prohibits Officer and then only in a written
or concerns you have. We prohibit the posting of inappropriate contract specifically modifying the
retaliation and you can raise material at workstations, desks, at-will nature of employment.
concerns without fear of reprisal. offices or other Company locations.
Inappropriate materials may include INTRODUCTORY PERIOD
certain items such as calendars,
COMMUNICATION Your first ninety (90) days of
photographs, pictures, posters,
Bulletin Boards, Video Boards employment at the Company are
cartoons or drawings of any kind
Associates are encouraged to read considered an Introductory Period.
that convey an implied or explicit
items posted on the Company This Introductory Period will be
derogatory or otherwise improper
bulletin boards and video board time for getting to know your fellow
racial, ethnic, religious, sexist, or
found in the break room of your associates, your manager and the
sexual message. The Company may
store and in the Store Support tasks involved in your job position,
require you to remove any material
Center. Bulletin boards are for as well as becoming familiar with
that violates this policy. Should you
Company communications and the Company’s culture, products
have a concern as to whether or not
are not to be used to publicize any and services. Your manager will
an item can be posted in your work
information other than Company- work closely with you to help
area, please consult your supervisor
related business. Be sure to review you understand the needs and
or contact the Human Resources
all memos, job postings, updates, processes of your job. If you take
Department.
and other information periodically approved time off in excess of five
so that you are well informed about workdays during the Introductory
AT-WILL EMPLOYMENT Period, the Introductory Period may
our Company.
We realize that our continued be extended by that length of time.
Promotional Opportunities
employment relationship will Should you successfully complete
As Roche Bros. continues to grow,
depend on both Roche Bros. the ninety (90) day Introductory
we are committed to providing
and your commitment; therefore, Period, your manager may discuss
promotional opportunities to our
we have a responsibility to you your job performance with you.
associates. Whenever possible, we
to create the right working During the course of this discussion,
fill open positions by promoting
environment. you are encouraged to give your
associates, provided a qualified
associate is available and is the best All associates are employed by comments and ideas as well.
qualified person for the position. Roche Bros. on an “at-will” basis. Please understand that completion
However, in some circumstances, a This means that either you or Roche of the Introductory Period does
position may be filled from outside Bros. has the absolute right to not alter the at-will nature of the
the Company, at the Company’s sole terminate the relationship at any employment relationship and
discretion. time, for any reason or no reason, does not guarantee continued
with or without cause or notice.
Generally, internal job opportunities
This Handbook does not constitute
are posted on the Ultipro Portal,
or contain a contract, expressed
Breakroom Digital Boards and near
or implied, of any kind and can be
the Time-Clock Station. Interested
modified by the company in its sole
applicants should complete an
discretion.
electronic application form via the
company’s Intranet Portal, which No associate, representative or
can be found on any company agent of Roche Bros. has the
computer’s desktop. Please see your authority to promise employment
Store Director or Assistant Store for a specified period of time, or to
Manager for details. make any promise, representation

ASSOCIATE’S HANDBOOK | 9
 employment for any specified categorized as either “exempt areas during their working time.
period of time, nor does it require or non-exempt,” as defined Associates should generally keep
that an associate be discharged by applicable law. Pursuant to all personal conversations (in any
for “cause”. Employment, both applicable law, exempt associates language) to a minimum when
during and after the Introductory do not receive overtime pay. working in work areas. Personal
Period, remains at-will. This means Associates classified as exempt conversations can be conducted in
that during the Introductory Period receive a salary which is intended to any language that individuals prefer
and thereafter, either you or the cover all hours worked. Non-exempt when they are on break, utilizing
Company may terminate the associates are eligible for overtime staff break rooms and lounges,
employment relationship, for any as set forth in the Schedules, Payroll associate restrooms or other areas
reason or no reason, with or without and Compensation policy. not open to the public,
notice or cause. Please remember that Roche If a customer prefers conversing in a
A former associate who has Bros. is an equal employment language other than English and in
been rehired is subject to the opportunity employer and as such which you are able to communicate,
Introductory Period during their first does not condone discrimination you may speak that language with
ninety (90) days following rehire. or harassment of any individual, the customer. If you need assistance
If you are promoted, you will have a including based on ethnicity, understanding a customer, consult a
ninety (90) day promotional period ancestry or national origin. Please member of your Store Management
during which you and the Company refer to the Equal Employment Team.
evaluate your fitness for the new Opportunity and Harassment
position. If during the promotional policies. ELIGIBILITY TO WORK IN THE
period or anytime thereafter, you UNITED STATES
or the Company determines that BACKGROUND INVESTIGATION All offers of employment are
the promotion is not a good fit, you Your employment with us is contingent upon verification of
may request or the Company may conditional upon a satisfactory an individual’s right to work in
decide to return you to your former background investigation. The the United States. As required
position, subject to availability. Company reserves the right by Federal law, within three (3)
to conduct this background days of an associate’s start date
EMPLOYMENT CATEGORIES investigation at any time after we that associate must provide
Regular Full-Time — one who is have made you a job offer or during documentation required by the I-9
hired or promoted to a position your employment, consistent with form, consistent with applicable law.
that is classified as full time, which applicable law.
requires 40 or more hours of BENEFIT PROGRAMS
regularly scheduled work per week. ENGLISH ONLY Roche Bros. provides associates
Regular Part-Time — one who is The success of Roche Bros. with one of the most comprehensive
hired for a position that is classified depends on our customer service, benefit packages in our industry.
as part time and generally requires the working relationships between The benefits we offer will enhance
fewer than 28 hours of regularly associates, and the ability of the quality of life for you and your
scheduled work per week. A part- supervisory staff to effectively family.
time associate may work additional monitor operations and provide Set forth below are summaries of
hours each week but shall not be instruction so that we can deliver some of the benefits we offer our
considered full time unless and until the highest level of customer associates. The Company and its
the associate moves into a position service. In order to meet our plan administrators reserve the
classified as full time. customer service objectives, we maximum discretion permitted by
In addition to the preceding require that associates speak law to interpret, administer, change,
categories, associates are also English when in the presence of modify or eliminate any rules,
customers or in normal working

10 | ASSOCIATE’S HANDBOOK
guidelines, policies, and/or benefits • Supplemental Life Insurance 18 or over will become eligible to
described below. The eligibility Roche Bros. periodically reviews its participate in the 401(k) elective
standards and other details benefits programs and may make and safe harbor match portion of
regarding many of the benefits changes to the benefits it offers as the plan at the beginning of the
described below are contained it deems appropriate. Roche Bros. month, after completing ninety (90)
in the actual plan documents reserves the right to change, alter, days of employment. After meeting
themselves. suspend, terminate or supplement the initial eligibility requirements
Some benefits are available these plans at any time and for any of 90 days employment you will
immediately upon employment reason without prior notice. receive an enrollment packet with
while others are available after a detailed eligibility requirements and
Other Group Benefits
special waiting period or completion instructions on how to enroll, as
The Company offers various
of a certain period of employment. well as a Summary Plan Description
types of group benefits to eligible
Please contact Human Resources explaining how the Plan works.
associates; some are paid for
for more detailed information entirely by the Company and Please review the Summary Plan
concerning eligibility, coverage others require contribution by the description for Profit Sharing
and enrollment. More detailed associate. These benefits include: eligibility requirements.
information may also be found in
• Bereavement Pay
the summary plan descriptions and PTO (PAID TIME OFF)
• Direct Deposit/Payroll Savings
individual plan documents, also
Plan Roche Bros. provides each associate
available through Human Resources.
• Jury Duty Pay with a PTO (Paid Time Off) bank.
In the event of a conflict between
• Education Assistance Program This PTO program provides a
this handbook and a plan document,
• Scholarship Program universal method for associates to
the terms of the applicable plan
• 401(k) and Profit Sharing Plan utilize their time off. The bank may
document will take precedence.
• Service Award Program be used for a variety of reasons
Health and Welfare Benefits • Tuition Reimbursement including vacation, holidays, sick
The following benefits are paid for time, to care for others, personal
Roche Bros. 401(k) and Profit
entirely by the Company and are business, or weather. This will
Sharing Plan
automatically provided to all eligible give associates flexibility in how
Through the Roche Bros. 401(k) and
associates upon completion of and when they use their PTO.
Profit Sharing Plan, you are offered
eligibility period at no cost to our Each associate will accrue a PTO
an easy way to work with Roche
associates: percentage based on their hours
Bros. to add to your long-term
• Basic Life Insurance retirement savings. There can be worked. Accrual information may be
• Basic Accidental Death and three types of contributions to your obtained from your Store Director.
Dismemberment (AD&D) account under the plan:
Insurance
• The Company may make an
• Short Term Disability (STD)
annual profit sharing contribution
• Associate Assistance Program
on your behalf.
(EAP)
• Workers Compensation Insurance • You may contribute on a pre-tax
basis through a 401(k)
Eligible associates also may choose
contribution.
to enroll in the following benefits:
• The Company may match a
• Medical Insurance
portion of your 401(k)
• Dental Insurance
contribution.
• Dependent Life Insurance
• Health Savings Account Any associate in the Company,
• Long Term Disability whether full or part time and age

ASSOCIATE’S HANDBOOK | 11
 Earning PTO should not be taken for more than • Upon leaving the company you
Part Time Associate PTO Accrual one week at a time. Management will receive pay for the time in the
• Part Time Associates will earn will approve your time off requests PTO bank. If you return to work as
PTO at a set accrual rate for every based on current business a rehire you will be considered as
hour worked beginning on the conditions. a new associate with no credit for
date of hire at a rate of at least • Associates are expected to previous years of service. Any
1 hour for every 30 hours worked. manage their PTO throughout the future PTO will be earned based
PTO earnings are subject to a year. If an associate exhausts their on your new rate and status.
maximum cap per year, which, in PTO bank and continues to Bereavement Pay
the first year is 48 hours. The cap request unpaid time off, they may In the event of a death in the family,
may increase in subsequent years. be subject to corrective action, you will be provided time off with
Once the associate has worked consistent with applicable law. pay in accordance with the policy
a complete year from their date of • Associates can schedule their PTO below. Associates on vacation at the
hire and has worked 1000 hours in in one hour increments. Full Time time of a death in the family will be
the current calendar year, the Associates may not choose to paid PTO.
hourly accrual rate is increased to take an absence without pay in Eligibility
a higher rate earning the associate order to save accrued PTO time. Full-time associates after
more PTO per hour worked. This If a Full Time Associate works less completing their 30-day waiting
rate will continue until the than 40 hours in a week, time period.
associate reaches the maximum from their PTO bank will be used • Up to five (5) days off for the
amount allowed per year. The so they are compensated for the death of a spouse or child.
process will reset at the beginning full 40 hours.
of the next calendar year. • Up to three (3) days off for a
• PTO should be scheduled in death in the immediate family,
• PTO is only accrued for hours advance, with management’s including mother, father, sister,
worked. It is not accrued when an approval. Management brother, mother-in-law, and
associate is on any type of leave will approve PTO based on father-in-law.
or is absent from work. considerations including current
• Day of the funeral for grandparent,
Full Time Associate PTO Accrual business conditions. If an associate
grandchild, sister-in-law,
• Full Time Associates will earn is out sick and cannot request
brother-in-law.
PTO at different rates depending PTO in advance, the associate
on the number of completed years must comply with the Company’s Jury Duty Pay
they have been with the company. notice procedures set forth in the All associates are encouraged
Full time associates accrue PTO sick leave policy. to participate in the community,
beginning on the date of hire at including serving on a jury. If you
Roll over
a rate of at least 1 hour for every are summoned for jury duty on a
At the end of each year, each
30 hours worked. PTO earnings regularly scheduled workday, you
associate will have the opportunity
are subject to a maximum cap per should notify your department
to roll over up to half of the PTO
year, which, in the first year is 128 manager as soon as the summons is
hours the associate accrued during
hours and may increase thereafter. received. All full-time and part-time
the calendar year. The amount rolled
associates will receive their regular
• PTO is only accrued for hours over may not allow the bank to go
compensation during the five days
worked. It is not accrued when an over a maximum of 320 PTO hours
of jury service. Any additional time
associate is on any type of leave for a full-time associate, 95 hours for
off under this policy will be without
or is absent from work. a part-time associate.
pay, except that exempt associates
Using PTO • Carrying PTO over will not affect will not incur any reduction in pay
Each associate will be able to the accrual of the following year. for a partial week’s absence due to
request PTO through the Time and jury duty.
Attendance System. PTO generally

12 | ASSOCIATE’S HANDBOOK
• Associates must provide certified work environment free of violence. individual does not have a valid
documentation from the Clerk of Reports of violence should be made prescription. Illegal drugs do not
Court to your store manager or to a member of management or include medication for which:
your department manager for the Human Resources Department. (1) the associate has a valid
time off and payment of wages. All reports will be investigated prescription;
• Full-time associates will receive promptly and will be kept as
(2) medication is taken in
payment for hours which they confidential as reasonably possible.
accordance with the dosing
were scheduled to work but were Weapons instructions and limitations/
unable due to jury duty, less the The possession of weapons on restrictions;
amount received from the court. Company premises, including
(3) over-the-counter medications
Payment may not exceed parking lots and company vehicles,
used in accordance with
40 hours per week (unless the is prohibited. “Weapons” include,
manufacturer packaging
associate worked more than but are not limited to all firearms,
instructions.
40 hours). knives (except those provided
by the Company solely for an The use, possession, or sale of
• Part-time and temporary non-
associate to perform his/her job alcohol (other than in accordance
exempt associates will receive
duties), explosives, nightsticks, with one’s job duties) and/or
payment for hours which they
metal knuckles and similar items. of illegal drugs or illegal drug
were scheduled to work but were
Associates should not have any paraphernalia and/or, given federal
unable due to jury duty, less the
expectation of privacy of any illegality, medical marijuana by
amount received from the court.
items they have in their possession any associate during work hours
• Roche Bros. expects you to report or on Company property is strictly
while on Company property. The
to work on days when you are prohibited. This includes consuming
Company may, at its discretion,
not required to be in court or are an alcoholic beverage during
inspect any package, desk, purse,
excused early. meal periods or breaks. The only
toolbox, vehicle, or other personal
belonging brought onto Company exception with regard to alcohol
VIOLENCE-FREE WORKPLACE premises as part of its efforts to consumption is participation in a
Roche Bros. is committed to ensure compliance with this policy. Company-sponsored event at which
maintaining a workplace that is Roche Bros. representatives have
safe for everyone who works at or approved alcohol consumption. In
SUBSTANCE-FREE WORKPLACE
visits our premises. The Company those situations, an associate who
POLICY
will not tolerate a threat or act is of legal drinking age may, if he/
Roche Bros. is committed to she chooses, consume a moderate
of violence by any associate or
creating a workplace free of amount of alcohol, provided
anyone who visits our premises.
substance abuse. Associates are that the associate’s conduct and
This includes actions of violence,
prohibited from reporting to work demeanor remain business-like
threats, intimidation, and possession
or remaining on duty while under
of weapons, harassment made by
the influence of alcohol or illegal
an associate or by any person on
drugs and in the case of medical
the Company’s premises. Associates
marijuana, working while impaired
play a crucial role in maintaining a
by marijuana. Illegal drugs means,
safe work environment at Roche
except as provided below, all drugs,
Bros. We believe that associates
the use or possession of which is
may be better prepared to avoid
illegal under federal, state, or local
or prevent violence if they report
law (including but not limited to
early warning signs. Associates
recreational marijuana), as well as
should report any behavior that
prescription medication which is
compromises or may compromise
used in a manner inconsistent with
the Company’s ability to maintain a
the prescription or for which the
ASSOCIATE’S HANDBOOK | 13
 and professional at all times, and Associates need not initially disclose 3. An associate has caused or
provided further that the associate the medical condition or, the name contributed to an incident or
does not thereafter drive or of the underlying medication. accident resulting in injury requiring
otherwise engage in any activity However, the Company may ask the medical attention beyond first aid,
which could be hazardous if the employee to discuss this information lost time, or damage to property in
alcohol consumed impairs or affects in order to determine when the an amount exceeding $250.00 as
the associate’s ability to perform employee is able to resume work estimated by the Company. Post-
those activities, and does not and/or is in need of a reasonable incident/accident testing will be
otherwise engage in illegal conduct accommodation. Associates may performed as soon as reasonably
or conduct which would reflect be asked to obtain a doctor’s practicable following a covered
detrimentally on the Company. certification that the associate can incident/accident.
A Note About Marijuana safely perform the responsibilities of Associates testing negative will
Though Massachusetts has, under his or her position. Any information be paid for time lost as a result of
state law, legalized medical and the Company may learn about an tests performed under this Policy
recreational marijuana, marijuana associate’s health or medications and will be returned to their normal
continues to be illegal federally, and will be treated as confidential, duties. Associates testing positive
thus associates should not use or and will be shared with Company will not be paid for time lost during
possess marijuana at work, while personnel only on a need-to-know the testing procedure and will be
working, on Company premises basis. subject to corrective action, up
or in company owned or leased Drug or Alcohol Testing to and including termination of
vehicles, nor should employees The Company may require an employment. Associates who refuse
work while under the influence of applicant or associate to submit to submit to drug and alcohol
recreational marijuana or impaired to drug and/or alcohol testing as testing will be subject to discipline
by medical marijuana. Recreational a condition of employment and up to and including employment
marijuana use, further, will not continued employment, at its sole termination.
excuse a positive test result on a discretion to the extent permitted Associate Assistance Program
test administered under this Policy. by applicable law. This may include, (EAP)
Medical marijuana use resulting but is not limited to, drug and/or The Company strongly encourages
in a positive test result will be alcohol testing when: associates who believe that they
evaluated on a case-by-case basis, 1. A conditional offer of employment have a problem with alcohol or
and Roche Bros.’ corresponding has been extended contingent on an drugs — legal or illegal — to seek
actions in all situations will comply applicant passing a pre-employment assistance. For those associates
with Massachusetts law, including drug test with a result satisfactory who voluntarily choose to self-
but not limited to reasonable to the Company; employment offers identify a substance-abuse
accommodation obligations. of applicants who refuse to test or problem to the Company, sources
Medications who do not pass a pre-employment of help may be provided. Leave
An associate using a prescription drug test will be withdrawn; or is available to associates who
drug, medical marijuana and/ 2. Reasonable suspicion exists that choose to voluntarily disclose such
or over-the-counter medications the associate is using or has used problems, per and within the terms
that the associate or his or her alcohol or illegal drugs (including of applicable leave/disability laws
health-care provider reasonably marijuana) during working hours or and Company leave and non-
believes may impair the associate’s on Company property (including discrimination policies. Associates
ability to perform his or her job Company owned or leased vehicles) may not, however, escape
responsibilities safely – must notify or has reported to or is working discipline by first self-disclosing a
his/her supervisor or the Human while under the influence of or dependency/abuse issue or problem
Resources Department so that impaired by alcohol or illegal drugs after being selected for testing or
steps can be taken to minimize (including marijuana); or violating the Company’s policies
the safety risks posed by such use. and rules of conduct. Nor will such

14 | ASSOCIATE’S HANDBOOK
self-disclosure excuse associates If an inspection or search reveals SMOKE-FREE WORKPLACE
from compliance with standards of potentially illegal conduct, law Smoking is prohibited in all of Roche
performance or behavior/conduct enforcement will be contacted. Bros. buildings. This includes any
expected of similarly situated An associate’s refusal to consent type of smoking product, including
associates. to a search or inspection when vaping. Smoking outside the stores
Inspections/Searches requested by the Company violates and headquarters is restricted to
Associates should not have any this Policy and is grounds for designated areas, away from any
expectation of privacy while on adverse employment action, up enclosed spaces and away from
Company premises. Roche Bros. to and including termination of the regular entrance/exits from
may, when there is reasonable employment. the store. Smoking or vaping is not
suspicion of a violation of Criminal Convictions permitted in receiving areas or on
Roche policies, procedures and Except in the circumstances receiving docks.
expectations as determined by described below, associates are
Roche Bros, ask an associate to required to inform the Company if STANDARDS OF CONDUCT
submit to a search or inspection. For they are convicted of any crime, no When working together, each of
example, a search may be necessary later than five (5) days after such us should act in a manner that is
where the Company has reason to conviction. Respectful, Supportive, and Totally
believe an associate has violated its
This requirement includes, but not Team Oriented (RSTO) – in other
substance-free workplace policy.
limited to: words, professional. This helps
Entry onto the Company’s premises
• Any drug related felony or assure safety and security and
or worksites constitutes consent to
misdemeanor convictions; provides the best possible work
searches and inspections under this
environment. We expect associates
Policy. The Company will generally • Any conviction for crimes
to follow basic, common-sense
try to obtain an associate’s consent involving theft, fraud or
rules of conduct that will protect
before conducting a search, but dishonesty;
everyone’s interests and safety. It
may not always be able to do so.
• Any conviction for operating is not possible to list all the forms
A search or inspection can be
a motor vehicle while under the of behavior that are considered
required at any time (including
influence. unacceptable in the workplace.
during breaks and meal periods)
Note that associates do not need to The following are examples of
while on Company premises, or
inform the Company of: infractions of rules of conduct that
while otherwise representing the
may result in disciplinary action,
Company, or at any time or in any • First conviction for drunkenness,
including suspension, demotion or
place. simple assault, speeding,
termination of employment:
This includes a search of an minor traffic violations, affray or
disturbance of the peace; or • Failure to treat a customer or
associate’s person and/or the
supplier with dignity and respect.
requirement that the associate • Any conviction of a misdemeanor
make his or her desk, work where the date of the conviction
station, storage locker, briefcase, or the end of any period of
purse, pockets, wallet, personal incarceration occurred more than
belongings, vehicles, electronic three (3) years ago; or
devices, accommodations and/
• A criminal record or anything
or any other property that he or
related to a criminal record that
she uses, has access to and/or has
has been sealed or expunged.
control of, available for inspection.
The Company reserves and retains Failure to promptly make the
the right to remove any lock or appropriate notification may result
other device securing the property, in disciplinary action up to and
as necessary and/or appropriate. including termination.

ASSOCIATE’S HANDBOOK | 15
 • Violating the company’s policies Substance Abuse Prevention • Failure to maintain a neat and
prohibiting discrimination or Policy. clean appearance in terms of
harassment against those with • Smoking in restricted areas or at the standards established by the
whom you interact, including non-designated times, as specified Company; wearing unsafe
fellow associates or groups by departmental rules. clothing.
of associates on the basis of a • Eating food and beverages in
• Carrying or bringing any weapon
protected characteristic, such undesignated areas.
onto Company property including
as race, color, age, gender, sexual
parking lots. • Consuming (eating or drinking)
orientation, religion, disability,
• Fighting or threatening violence. unpaid merchandise.
national origin, veteran status or
any other protected characteristic. • Sleeping during work hours. Should you have any questions
regarding this policy, please consult
• Knowingly or willfully violating • Excessive personal telephone
with your supervisor or contact the
federal, state or local laws that calls during working time whether
Human Resources Department.
govern the conduct of our on one’s own phone or that of the
business. Company and/or use of
HONESTY AND INTEGRITY
• Misuse, misappropriation, theft, Company’s long distance phone
damage, or destruction of lines for non-business purposes. As an associate of Roche Bros., we
Company property or the expect your honesty and integrity to
• Willful violation of security or
property of fellow associates, be of the highest level.
failure to observe Company safety
customers, suppliers, etc. practices; failure to wear required You may be entrusted with handling
• Making knowingly false safety equipment; tampering large sums of money or other
statement such as providing with Company equipment or valuable items. You may not remove
false or inaccurate information safety equipment. any company money, property,
to the Company or on Company equipment, merchandise, or supplies
• Negligence or any careless action
documents or records such as from the company premises without
which endangers the life or safety
time cards, personnel records, permission. This includes consuming
of another person.
applications, resumes, expense or using any company merchandise
• Theft of company property or for which you have not paid in
reports, documents concerning
the property of fellow associates; accordance with the Associate
FMLA leave, etc.
unauthorized possession or Shopping Policy.
• Violation of the Company’s removal of any company property,
policy regarding Confidential and It is your responsibility to advise
unauthorized use of company
Proprietary Business Information. management should you observe
equipment or property for
any person taking merchandise
• Insubordination, such as refusal to personal reasons; using company
without paying for it, whether it
perform assigned tasks. equipment for profit.
is an associate, a customer, or a
• Excessive absenteeism, excluding • Unsatisfactory or careless work. sales vendor. You should report
protected leaves of absence, and/ • Leaving work before the end of a any customer theft to the person
or failure to follow the company’s workday or not being ready to in charge of the store immediately.
call out procedures. work at the start of a workday Associate or sales vendor theft
• Use, possession, or being under without approval of your manager. should immediately be reported to
the influence of alcohol, or illegal • Creating or contributing to store management or a member of
drugs (in the case of medical unsanitary conditions. the Store Support Team.
marijuana associates are also Acts of theft or misappropriation,
• Filling your own order or invoicing
prohibited from working while whether they involve money,
or ringing up your own order.
impaired by marijuana) while on merchandise, supplies or equipment
Company property or during work • Buying company merchandise for
or confidential and proprietary
hours or other violations of the resale.
business information or trade

16 | ASSOCIATE’S HANDBOOK
secrets will be dealt with severely. Friday in your department. Requests law. If you believe an absence
The associate will be subject for time off or special work hours or lateness is entitled to legal
to disciplinary action up to and should be communicated to your protection, please contact Human
including termination. In addition, department manager prior to the Resources.
the company may seek restitution Wednesday before the schedule is
and may make reports to the posted. ASSOCIATE PARKING
appropriate authorities. You are scheduled to work based on As a company, we are committed to
We believe and sincerely hope that business conditions and to provide excellence in customer service. It is
it will not be necessary to take any the best customer service possible. appropriate that our customers park
of the foregoing actions against any Because of the changes in business as close to the store as possible.
of our associates. conditions from week to week, your For this reason, we have specific
schedule may vary. Depending on designated areas for associate
ATTENDANCE AND WORK labor laws, associates are expected parking. At some stores it is a
SCHEDULES to work their assigned shift. The designated area of the supermarket
schedule may vary also regarding parking lot, in other stores, it is a
You should understand the
department needs, customer separate parking lot away from the
importance of having good
needs and emergency situations. store. Every associate is required to
attendance and punctuality. If you
Once the schedule is posted, you park only in designated associate
are going to be late or absent,
are responsible for checking and parking at each store unless the
you are responsible for notifying
working the hours posted. Your associate is visiting the store as a
your department manager at least
department manager must approve customer.
one hour prior to your start time,
all schedule changes.
unless one hour advance notice If an associate requires a variation
is not possible, in which case, In application of this Attendance from this policy because of a
notice must be provided as soon policy, the Company is committed disability, please contact the Human
as possible. An associate who is to complying with applicable law Resources Department regarding
excessively late (either for the start providing you a legal right to be the request.
of your scheduled shift, or returning absent from, late to work or to leave
from break and meal times), who early. All aspects of this Attendance
ASSOCIATE SHOPPING
leaves early or is absent may be policy will be interpreted and
applied to ensure compliance As an associate of Roche Bros., you
subject to disciplinary action,
with these laws. Specifically, any are a valued member of our team.
up to and including termination.
unscheduled absence, tardiness You are also a valued customer.
Excessive absenteeism includes,
but is not limited to, absences or other incident that is protected The following are some common
that average more than once per by applicable law will not count sense rules that will explain
month. Excessive absenteeism against an associate under this the procedures on associates’
does not include absences that are policy. For example, while associates purchases.
protected by law (such as FMLA are expected to report to work on
approved absences, reasonable time, as scheduled, with proper
accommodation, sick time under notice, an associate eligible for
MA’s paid sick leave law). If you FMLA leave and needing to receive
are absent for three scheduled planned medical treatment, would
days without reporting your be excused from reporting to
absence, you will be considered to work late. Consistent with this
have voluntarily resigned, unless policy, the Company is prepared to
otherwise provided by applicable consider whether absences should
law. be excused and/or additional
time off provided as a reasonable
Work schedules are posted every
accommodation under applicable

ASSOCIATE’S HANDBOOK | 17
 • Company policy requires that ASSOCIATES UNDER 18 YEARS OF clean up after yourself when using
your shopping be done on your AGE these facilities.
own times, that is, you must be off Operation of machinery Personal Items
the clock while doing your In accordance with applicable state • Whenever possible, we
personal shopping. With the and federal laws, associates under recommend that personal items
exception of purchases for the age of 18 are prohibited from not be brought into the store.
consumption during a break or operating certain machinery. No • Coats, boots, and other personal
meal period, once the associate under age 18 may operate items should be placed only in
merchandise has been rung any compactor or power-driven designated areas.
through the register, it must machines (such as, bakery mixers,
be accompanied by a receipt • Handbags are to be placed in
meat slicers or grinders, etc.).
and removed from the store. No the courtesy booth. No handbags
Cigarettes/Beer and Wine or other personal items should be
associate is permitted to bring
Identification placed at the checkout lanes or in
merchandise back into the store
• Under Massachusetts law, a the departments.
once it has been rung through
person must be 21 years of age
the register. Associates are not • You are to enter and leave the
or older to purchase cigarettes.
permitted to store merchandise store by the front door only. Back
For all sales of cigarettes, the
anywhere in the store which doors are secured at all times
Company requires associates to
includes, but not limited to, break unless authorized deliveries are
verify proof of the customer’s age
rooms, freezers, refrigerators, etc. being made.
by requesting a valid driver’s
• You may purchase food for license, state identification card or • When leaving the store, you
consumption during your shift passport from all customers. may be asked to present personal
during a rest break or meal period. packages for inspection to the
• Under Massachusetts law, a
All purchases must be person in charge prior to exiting.
person must be 21 years of age or
accompanied by a receipt and
older to purchase beer and wine.
may be consumed in break rooms
For all beer and wine sales, the OUTSIDE EMPLOYMENT
or designated areas in the store.
Company requires a valid driver’s If you are employed in a full-time
• You are not permitted to wait on license, state identification card position, the Company expects that
or handle your own purchases or or passport from all customers. No your position here is your primary
those of any member of your associate under the age of 18 (or employment. Any outside activity
family. 21 in some locations) is permitted must not interfere with your ability
• You are not permitted to weigh, to sell alcoholic beverages. to perform your job duties at the
package or price products that A valid driver’s license, state Company.
you or your family will purchase. identification card or passport While the Company does not
• You must make your selections is the ONLY form of identification prohibit associates from holding
from the regular merchandise accepted for proof of age for other jobs, the following types of
available to our customers. cigarette, beer and wine sales. outside employment are prohibited:
• You are not permitted under any • Employment that conflicts with
conditions to use or consume any STORE FACILITIES the associate’s work schedule,
company merchandise for which We are dedicated to providing duties and responsibilities or
you have not paid unless approved positive, productive work creates an actual conflict of
by a member of the management environments for all our associates. interest;
team. One way we do this is by keeping • Employment that impairs or
our stores clean and neat. All stores has a detrimental effect on the
provide a break room and restrooms associate’s work performance with
for your use. Please take care to the Company;

18 | ASSOCIATE’S HANDBOOK
• Employment that requires business with the Company; This policy in no way prohibits
associates to conduct work or • Owning a material interest in associate affiliations or activities
related activities during working or being a creditor of or having that are protected under applicable
times or using any of the other financial interest in a state and federal laws, including
Company’s tools, materials or supplier, customer, competitor but not limited to any activity that
equipment; and or any entity that engages in is protected under Section 7 of the
• Employment that directly or business with the Company; National Labor Relations Act, which
indirectly competes with the includes the right of associates to
• Receiving from or giving to any
business or the interests of the organize collectively and to speak
supplier, customer or competitor
Company. with others about their terms and
gifts, gratuities, special allowances,
conditions of employment.
• For the purposes of this policy, discounts or other advantages not
self-employment is considered generally available to associates of
outside employment. the Company; RELATIONSHIPS IN THE
WORKPLACE
• Having any significant direct
CONTACT WITH THE MEDIA or indirect personal interest in a While a family member of an
business transaction involving the associate may be considered for
To ensure that the Company
Company; employment by the Company, a
communicates with the media in a
family member of a Store Director
consistent, timely and professional • Conducting outside activities that
or Assistant Store Manager may
manner about matters related to materially detract from or interfere
not be permitted to work in the
the Company, you should notify the with the full and timely
same store or location as the Store
Chief Operating Officer (COO) that performance of an associate’s job
Director or Assistant Store Manager.
you have been contacted by the duties for the Company;
In addition, the Company generally
media. Whenever you are asked to • Influencing commercial will not permit a family member
speak on behalf of the Company transactions involving purchases, of an associate to work in any role
please notify the Company (COO) contracts or leases in a way that in which one family member has
that a media inquiry has been made. would have a negative impact on decision-making or management
Do not respond to media inquiries the Company or its business. authority over the other. For
on the Company’s behalf without
If an associate finds that he or purposes of this policy, family
authorization. This rule does not
she has, or is considering the member includes spouse, domestic
prevent you from speaking with the
assumption of, a financial interest partner, child, parent, sibling,
media, but you should not attempt
or outside employment relationship parent-in-law, brother- or sister-in-
to speak on behalf of the Company
that might involve a conflict of law, grandparent, grandparent-in-
unless you have specifically been
interest, or if the associate is in law, any family member living in the
authorized to do so by an officer of
doubt concerning the proper same household, aunt, uncle, cousin,
the Company.
application of this policy, he or she or any other relation required by
should promptly discuss the matter
CONFLICTS OF INTEREST with the Chief Operating Officer and
All associates must conduct refrain from exercising responsibility
themselves in such a way as to on the Company’s behalf in any
avoid actual or potential conflicts of manner that might reasonably be
interest. The following are examples considered to be affected by any
of prohibited conflicts of interest: adverse interest.
• Acting as a director, officer, Failure to disclose the fact of a
consultant, agent or associate of conflict or potential conflict may
a supplier, customer, competitor constitute grounds for disciplinary
or any entity that engages in action.

ASSOCIATE’S HANDBOOK | 19
 applicable law. pamphlets, or any kind of printed store manager.
In addition, the Company strongly matter in the Company work areas • If there is something on the floor
discourages romantic or sexual is prohibited. Off-duty associates or in the parking lot that may
relationships and any conduct that are not permitted in work areas, cause an unsafe or unsanitary
may lead to the formation of such a except as customers. Persons not condition, pick it up or clean it up
romantic or sexual relationship (i.e., employed by Roche Bros. are not immediately using proper safety
dating) between a Supervisor and permitted to solicit for any purpose equipment. If something has
an associate who the Supervisor or distribute any form of literature spilled or broken, remain in the
directly manages or over whom or other matter, at any time, in work area to warn customers and
the Supervisor has employment areas. associates of the problem and
decision-making authority. take steps to remove it as quickly
If a romantic or sexual relationship SAFETY RULES as possible.
between a Supervisor and an Your safety is important to us. • Climbing on shelves, boxes, chairs
associate who the Supervisor Safety is the individual and or equipment is not permitted.
either directly manages or collective responsibility of everyone Working in an unsafe manner or any
over whom the Supervisor has at Roche Bros. The goal is to actions that are improper, careless,
employment decision-making provide a safe work environment, negligent, and/or destructive may
authority should develop, it is the with well-maintained equipment result in disciplinary action, up
responsibility of the associate and and associate training. Associates to and including termination of
the Supervisor to immediately are responsible for following employment.
disclose the relationship to the safe practices and reporting
Human Resources Department. The unsafe conditions and accidents.
Company may elect to relocate one DRESS CODE FOR STORE
Together, we have a responsibility
or both parties of the relationship ASSOCIATES
to conduct a continually improving
or change an associate’s position. process — one whose ultimate goal All associates working in a store
The same reporting requirements is the elimination of workplace receive a company-provided
apply to an associate who is a family accidents, injuries and illness. Our uniform, and name badge. You
member of an associate or applicant safety program demonstrates must wear the uniform applicable
or who becomes a family member our commitment to safety. In the to the store location to which you
at any time during employment. interest of the safety and well-being are assigned. Your uniform is a very
of everyone, you must follow these important part of your image to
guidelines: our customers. You are responsible
SOLICITATION AND DISTRIBUTION
for laundering and keeping your
No solicitations of any kind, • If you, a customer, or another
uniform neat and clean. Uniforms
including solicitations for associate is injured while on
are made of wash and wear material,
memberships or subscriptions, the store premises, you must
meaning they can be laundered with
will be permitted by Company IMMEDIATELY report the situation
other personal garments in a regular
associates during the associate’s to the store manager or the
washer or dryer.
working time or the working time of person in charge of the store.
You must wear footwear appropriate
the associate at whom the activity • The company has established
for our work environment. You may
is directed. Working time does not safety rules and working
wear sneakers or other footwear
include meal periods or rest breaks. conditions that are in compliance
that is neat, clean, and tied. For your
Solicitation is also prohibited in with applicable law. It is important
personal safety, sandals, open-toed
customer service areas. that you follow these procedures
shoes, high-heeled shoes, flip flops
Solicitation is defined as requesting so that you are in compliance
and slippers are not acceptable
or seeking, in writing or orally, with these regulations. If you are
footwear. Mesh tennis shoes are not
donations, help, or the like for unsure of a particular procedure,
recommended in areas that may
any cause. Distributing literature, ask your department manager or

20 | ASSOCIATE’S HANDBOOK
encounter hot products. consumed by our customers. (Sunday through Saturday).
Name badges are to be worn on • Certain perishable departments Overtime
the upper left portion of your have specific sanitary procedures Overtime is paid to all non-exempt
uniform and must be visible at all for you to follow, including proper associates who have worked over
times during your work shift. There hand washing procedures and 40 regular hours in one weekly
should be no stickers or labels wearing of hats and gloves. pay period. This will be paid at
applied to your nametag to ensure • Hair must be neat, clean, and 1-1/2 times your regular rate of pay.
other associates and customers can well groomed. Hair restraints are All payment for hours worked on
identify you. All aprons and name required in all food preparation Sundays will be at 1-1/2 times your
badges are to be returned to your areas. regular rate of pay.
store manager when you leave the Paid time off such as PTO and jury
• Associates must be clean-shaven
company. duty pay (where applicable) will not
or wear side burns, mustaches,
and/or beards that are neatly count toward hours worked for the
PERSONAL APPEARANCE/ groomed. purpose of determining overtime
HYGIENE pay.
• Associates are not allowed to eat,
To our customers and the drink or chew gum during working All overtime work must be
communities we serve, Roche Bros. time, except during approved authorized in advance by an
strives to represent the highest meal and other break periods in associate’s supervisor. Working
level of cleanliness, quality, and designated areas. overtime without prior authorization
excellence in customer service. may result in disciplinary action.
Roche Bros. provides
In keeping with that image, our accommodations to individuals for Exempt associates are expected
associates’ personal appearance and disabilities and based on sincerely to work as much of each workday
dress must be appropriate to reflect held religious beliefs, as required as is necessary to complete their
our commitment to these standards. by applicable law. If you require an job responsibilities. No overtime or
Perishable Departments should accommodation, of the above policy additional compensation is provided
not wear jewelry which protrudes due to a disability or a sincerely to exempt associates.
below the ear, dangling necklaces, held religious belief, please contact Sunday Work—Retail Associates
rings or bracelets. Nails should be Human Resources. Retail associates may be scheduled
clean and short: false or long nails to work on Sundays. Nonexempt
are not acceptable. These items retail associates will be paid at a
SCHEDULES, PAYCHECKS AND
may fall off and drop into food, rate of one and one-half times their
COMPENSATION
creating unsafe and unsanitary food regular hourly rate of pay for work
prep conditions. When applicable, Your Paycheck and the Time/ performed on Sundays.
associates may be required to wear Attendance System
Nonexempt associates are also
hair and/or a beard restraint. It is our policy and practice to
accurately compensate associates
Store managers may set additional
and to do so in compliance with all
guidelines for each store.
applicable laws. To ensure that you
• One of the most important parts are paid properly for all time worked
of your appearance is a SMILE.. and that no improper deductions
offer a smile and greeting when are made, you must correctly record
dealing with our customers. all time worked and review your
• Be sure your appearance is well- paychecks promptly to identify and
kept at all times, paying special to report all errors.
attention to hygiene as the items Your paycheck covers the hours
you are touching may be worked in the previous week

ASSOCIATE’S HANDBOOK | 21
 entitled to one and one-half times Mandatory Time Off / Day of Rest periods. If you forget to punch in
their regular rate of pay for hours The Company will provide or out, it is your responsibility to
worked in excess of 40 per week. associates with at least one day (24 inform the store director as soon
However, Sunday work hours that consecutive hours) of rest every as possible so that your timesheet
are paid at a rate of one and one- seven days. The day of rest will may accurately reflect the actual
half times an associate’s regular rate include an uninterrupted period hours worked. When you receive
of pay will not be counted when between the hours of 8:00 a.m. and each pay check, please verify
determining whether an associate 5:00 p.m. immediately that you were paid
has worked more than 40 hours Associates required to perform correctly for all regular and
during the workweek. their usual work on a Sunday will overtime hours worked each
Holiday Work—Retail Associates be provided 24 consecutive hours work week.
Retail associates may be scheduled without work during the following • It is your responsibility to review
to work on the following holidays: six days. and approve your electronic
New Year’s Day Review Your Pay Stub punches for each pay week. This
We make every effort to ensure must be done immediately
Patriots Day
our associates are paid correctly. following the completion of the
Memorial Day work week.
Occasionally, however, inadvertent
Independence Day mistakes can happen. When • Unless you are authorized by your
Labor Day mistakes do happen and are called supervisor, you should not work
to our attention, we will promptly any hours that are not authorized
Columbus Day
make any corrections necessary. or scheduled. Do not start work
Veterans Day Please review your pay stub when early, finish work late, work during
Nonexempt retail associates who you receive it to make sure it is a meal break or perform any other
work on the holidays listed above correct. If you believe a mistake extra or overtime work unless
will be compensated at one and has occurred or if you have any you are authorized to do so and
one-half times their regular rate questions, please use the reporting that time is recorded on your time
of pay. procedure that follows. card. Associates are prohibited
Computerized Timecard System from performing any “off-the-
Nonexempt associates are also
Roche Bros. uses a computerized clock” work. “Off-the-clock”
entitled to one and one-half times
payroll/timecard system called work means work you may
their regular rate for hours worked
“Time & Attendance.” This system is perform but fail to report in the
in excess of 40 per week. However,
to help us ensure that associates are system. Any associate who fails
holiday work hours that are paid at
paid accurately and promptly every to report or inaccurately reports
a rate of one and one-half times an
week. any hours worked will be subject
associate’s regular rate of pay will
to disciplinary action, up to and
not be counted when determining • It is your responsibility to
including termination.
whether an associate has worked accurately record your hours into
more than 40 hours during the the payroll system. You must It is a violation of company policy
workweek. punch in just prior to the time to alter or falsify your own timecard,
you actually begin to work and or to alter, falsify or punch another
punch out immediately following associate’s timecard. Failure to
the end of your working time. comply with this policy may
Your electronic time record must result in disciplinary action, up to
accurately reflect all hours and including termination. If any
worked, any absences, late manager or associate instructs you
arrivals, early departures and meal to (1) incorrectly or falsely under-
breaks. You are also required to or over-report your hours worked,
punch in and out for unpaid meal or (2) alter another associate’s

22 | ASSOCIATE’S HANDBOOK
time records to inaccurately or classified as an exempt associate. • Your absence on a day because
falsely report that associate’s While it may be subject to review the Company has decided to close
hours worked, you should report and modification from time to time, a facility on a scheduled work day.
it immediately to the Human such as during salary review times, • Absences for jury duty, attendance
Resources Department. the salary will be a predetermined as a witness, or military leave
Payroll Deductions amount that will not be subject in any week in which you have
Your earnings and payroll to deductions for variations in the performed any work.
deductions are itemized each pay quantity or quality of the work you
• Any other deductions prohibited
period on your check stub or direct perform.
by state or federal law.
deposit statement. Associates are Under federal and state law,
Please note: it is not an improper
encouraged to take advantage of your salary is subject to certain
deduction to reduce an associate’s
the direct deposit feature. Roche deductions. For example, absent
accrued paid time off for full or
Bros. is required to make proper contrary state law requirements,
partial day absences for personal
deductions from your earnings on your salary can be reduced for the
reasons, sickness or disability,
your behalf. Amounts withheld vary following reasons:
subject to applicable law.
according to how much you earn, • Full day absences for personal
your marital status, government To Report Errors in Pay or Improper
reasons.
employment regulations, and other Deductions
• Full day absences for sickness or Roche Bros. takes all reasonable
factors. Other deductions may be
disability. steps to ensure that associates
made from your paycheck with your
permission such as for insurance • Full day disciplinary suspensions receive the correct amount of
premiums and 401(k) contributions. for infractions of our safety rules pay and that associates are paid
At the end of each year, you will of major significance. promptly on the scheduled payday.
receive a W-2 form indicating your • Family and Medical Leave In the unlikely event that there is
yearly earnings and all deductions absences (either full or partial an error in the amount of your pay,
made during the year. If you need day absences). you should promptly bring the
to change your tax status for discrepancy to the attention of your
• To offset amounts received as
withholding purposes, please log store manager or Human Resources.
payment for jury and witness fees
into UltiPro to complete a new W-4 Corrections will be made as quickly
or military pay.
form. as possible, in most cases that will
• The first or last week of be your next scheduled payday. All
Every associate is responsible
employment in the event you work associates may file complaints or
for providing Roche Bros. with
less than a full week. raise concerns regarding deductions
accurate payroll information. This
• Any full work week in which you from wages without fear of reprisal.
includes the correct spelling of your
name (as it appears on your social do not perform any work. Roche Bros. prohibits improper
security card or other government Your salary may also be reduced for deductions from associate pay
issued ID), correct mailing address, certain types of deductions such as
correct Social Security Number, and your portion of health, dental or life
any other required information. insurance premiums; state, federal
Payroll Deductions for Exempt or local taxes, social security; or,
Associates voluntary contributions to a 401(k)
If you are classified as an exempt or pension plan. In any work week
salaried associate, you will receive in which you performed any work,
a salary which is intended to your salary will not be reduced for
compensate you for all hours you any of the following reasons:
may work for the Company. This • Partial day absences for personal
salary will be established at the reasons, sickness or disability.
time of hire or when you become
ASSOCIATE’S HANDBOOK | 23
 and is committed to preventing break instead of a paid 15-minute • Address
improper deductions. Managers break. Associates who elect to • Telephone Number
who are uncertain about whether take an unpaid lunch, must advise • Insurance Designations
a deduction is proper should seek the supervisor so that adequate • Emergency Contacts.
guidance from Human Resources staffing can be arranged. If an associate needs assistance,
before making or ordering the • 6 hours to 8 hours — You receive they may contact a member of
deduction. Associates with a paid 15-minute break and a management. Only authorized
questions or complaints about 30-minute unpaid meal period. members of management and
any deduction to their pay should Human Resources have access to an
• More than 8 hours — You receive
see their store manager or Human associate’s personnel file. However,
two paid 15-minute breaks and
Resources immediately for the Company will cooperate
a minimum of a 30-minute unpaid
clarification or correction. Such with—and provide access to an
meal period per eight hours of
complaints will be investigated associate’s personnel file to—law
work. The length of your unpaid
and if an improper deduction enforcement officials or local, state
meal period is at the discretion
is verified, the associate will be or federal agencies in accordance
of your store manager, but at a
promptly reimbursed. Roche Bros. with applicable law, or in response
minimum will be consistent with
prohibits any retaliation against an to a subpoena, in accordance with
applicable law.
associate for making a good faith applicable law.
complaint pursuant to this policy, You are required to take breaks and/
or meal periods within the allotted Associates may review or obtain
or for otherwise participating in any
time and as scheduled by your a copy of their personnel file,
investigation concerning payroll
department manager and breaks generally not more than two times
deductions.
may not be combined. Associates per calendar year, by submitting
must not perform any work during a written request to Human
PERSONAL PROPERTY Resources. The review will take
the meal break and are free to leave
The Company does not insure or the workplace premises. Associates place in the presence of a company
assume any responsibility for loss are expected to return to work representative during normal
of personal property anywhere on promptly at the end of every meal business hours. Associates who
Company premises including inside break. disagree with any of the information
personal vehicles. Additionally, contained in their personnel file
Department managers schedule
the Company does not assume should notify Human Resources and
breaks and meal periods in
responsibility for loss or damage to if an associate and the Company
accordance with applicable law
personal vehicles while in Company cannot agree to remove or correct
and during those times that least
parking areas. the specified information, the
interfere with the operation of the
associate can submit a written
store or our ability to serve our
REST PERIODS statement explaining his or her
customers. Remember, our highest
position regarding the disputed
Rest periods are provided by Roche priority is to provide excellent
information. The statement will be
Bros. to ensure that all associates customer service at all times in
maintained as part of the associate’s
have a period of time to relax and accordance with applicable law.
personnel file and included in any
refresh themselves during their
disclosure to a third party.
scheduled shift. PERSONNEL RECORDS
Upon request, associates will also be
If you are scheduled for: It is important for all associates and allowed to inspect certain paper or
• 5 to up to 6 hours — You receive the Company to maintain accurate electronic wage records maintained
a paid 15-minute break. If your records. Associates may update by the Company. Associates will
work schedule goes through a their personnel records by logging be allowed to inspect such wage
lunch or dinner period, then into UltiPro, including: records at a reasonable time and
you may take a 30-minute unpaid • Name place. Upon request, associates

24 | ASSOCIATE’S HANDBOOK
will be provided with a copy of the evaluated on a case by case basis. • To care for the associate’s child
wage records within ten business All leave requests are to be after birth, or placement for
days. submitted in writing (see store adoption or foster care;
manager for appropriate form) to • To care for the associate’s spouse,
LEAVES OF ABSENCE your store manager and /or HR for son, daughter or parent (but not
Roche Bros. understands that there review and approval. All associates in-law) who has a serious health
may be times when associates returning from any medically related condition;
experience medical or personal leave will be required to present • For the associate’s own serious
issues requiring extended time a doctor’s certification of their health condition (including
away from work. Under certain fitness to return to work including any period of incapacity due to
circumstances, applicable law may whether they require any workplace pregnancy, prenatal medical
afford an eligible associate with a accommodations, unless otherwise care or childbirth) that makes the
protected leave of absence. For provided by applicable law. associate unable to perform one
example, you may be eligible for a Family and Medical Leave Act or more of the essential functions
Family and Medical Leave, Maternity (FMLA) of the associate’s job; and/or
Leave, or Military Leave, among Under the provisions of the Family • Because of any qualifying
others. and Medical Leave Act (FMLA), situation arising out of the fact
During all leaves of absence the associates may be entitled to a that an associate’s spouse, son,
Company will require an associate leave of absence for certain reasons. daughter or parent is a military
to use accrued and unused PTO for This policy provides associates member on covered active duty or
some or all of the leave period to information concerning FMLA call to covered active duty
the extent permitted by law. entitlements and obligations status (or has been notified
associates may have during such of an impending call or order to
Generally, during any period of time
leaves. If associates have any covered active duty) in the
that an associate is out of work on
questions concerning FMLA leave, Reserve component of the Armed
a leave of absence and is receiving
they should contact the Director of Forces for deployment to a
pay for the period of leave, either
Human Resources. foreign country in support of a
through short-term disability,
workers’ compensation, or the Associate Entitlements for FMLA contingency operation or Regular
use of earned PTO, the associate Leave Armed Forces for deployment to a
is responsible for paying the As described below, the FMLA foreign country.
associate’s portion of all insurance provides eligible associates with A serious health condition is an
premiums. When the associate is a right to leave, health insurance illness, injury, impairment, or
receiving pay through Roche Bros.’ benefits and, with some limited physical or mental condition that
payroll system, these amounts will exceptions, job restoration. involves either an overnight stay in
be deducted from the associate’s Basic FMLA Leave Entitlement a medical care facility, or continuing
pay. Otherwise, the associate is The FMLA provides eligible
responsible for providing premium associates up to 12 work weeks
payments when due. of unpaid leave for certain family
When an associate is out of work and medical reasons during a
on a leave of absence for longer 12 month period. The 12 month
than 26 weeks, the associate will period is determined on a rolling
be required to exhaust his or her basis, beginning from the time the
available earned PTO. Unless associate commences leave. Leave
otherwise provided by applicable may be taken for any one, or for
law, associates who remain out of a combination, of the following
work for 26 weeks or more will be reasons:

ASSOCIATE’S HANDBOOK | 25
 treatment by a health care provider 12-month period begins on the reasons for FMLA leave, the leave
for a condition that either prevents first day an eligible associate takes may be denied. When associates
the associate from performing the leave to care for the injured service seek leave due to FMLA-qualifying
functions of the associate’s job, member. reasons for which the Company
or prevents the qualified family Eligible Associates has previously provided FMLA-
member from participating in school FMLA leave is available to “eligible protected leave, they must
or other daily activities. Subject to associates.” To be an “eligible specifically reference the qualifying
certain conditions, the continuing associate,” an associate must: (1) reason for the leave or the need for
treatment requirement may be met have worked for the Company for at FMLA leave.
by a period of incapacity of more least 12 months; (2) have worked for Timing of Notice
than 3 consecutive calendar days at least 1,250 hours in the 12 month If your need for FMLA leave is
combined with at least two visits period preceding the leave request; foreseeable, you must give 30 days
to a health care provider or one and (3) be employed at a worksite prior written notice to your Store
visit and a regimen of continuing that has 50 or more associates Director. If this is not possible, or the
treatment, or incapacity due to within a 75-mile radius. approximate timing of the need for
pregnancy, or incapacity due to a leave is not foreseeable, you must
Intermittent Leave and Reduced
chronic condition. Other conditions give notice as soon as practicable
Leave Schedules
may meet the definition of under the facts and circumstances
FMLA leave usually will be taken for
continuing treatment. of the particular situation. Failure to
a period of consecutive days, weeks
Qualifying exigencies may include or months. However, associates provide such notice may be grounds
attending certain military events, also are entitled to take FMLA leave for delay or denial of leave.
arranging for alternative childcare, intermittently or on a reduced leave When planning medical treatment,
addressing certain financial and schedule when medically necessary associates must consult with the
legal arrangements, attending due to a serious health condition Company and make a reasonable
certain counseling sessions, caring of the associate or covered family effort to schedule treatment
for the parents of the military member or the serious injury or so as not to unduly disrupt the
member on covered active duty illness of a covered service member. Company’s operations, subject
and attending post-deployment Qualifying exigency leave also may to the approval of an associate’s
reintegration briefings. be taken on an intermittent basis. health care provider. Associates
Additional Military Family Leave Provide Notice of the Need for must consult with the Company
Entitlement (Injured Service Leave prior to the scheduling of treatment
Member Leave) Associates who take FMLA leave to work out a treatment schedule
In addition to the basic FMLA leave must timely inform the Human which best suits the needs of both
entitlement discussed above, an Resources Department of the need the Company and the associate,
eligible associate who is the spouse, for FMLA-qualifying leave and the subject to the approval of an
son, daughter, parent or next of kin anticipated timing and duration of associate’s health care provider.
of a covered service member may the leave, if known. If associates providing notice of
be entitled to take up to 26 weeks the need to take FMLA leave on
Calling in “sick,” without providing
of leave during a single 12-month an intermittent basis for planned
the reasons for the needed leave,
period to care for the service medical treatment neglect to fulfill
will not be considered sufficient
member with a serious injury or this obligation, the Company may
notice for FMLA leave under this
illness. Leave to care for a service require associates to attempt to
policy. Associates must respond
member shall only be available make such arrangements, subject
to the Company’s questions
during a single 12-month period and to the approval of the associate’s
to determine if absences are
when combined with other FMLA- health care provider.
potentially FMLA-qualifying.
qualifying leave, may not exceed 26
weeks during that period. The single If associates fail to explain the

26 | ASSOCIATE’S HANDBOOK
Medical Certification accrued PTO must be utilized for the failure to return to work is due
Associates requesting FMLA the time not compensated by to the continuation, recurrence or
leave related to the serious health Short Term Disability. If the leave onset of a serious health condition
condition of a spouse, child, or is for the associate’s own serious that would entitle the associate to
parent or their own serious health health condition, PTO must also FMLA leave or other circumstances
condition will be required to provide be substituted for any FMLA leave beyond the control of the associate.
a medical certification (generally and the associate may be eligible Reporting While on Leave
within 15 days of the company’s for salary continuation under the If you take FMLA leave because of
request, unless it is not practicable Company’s short-term disability your own serious health condition
to do so despite the associate’s policies. If your leave is the result of or to care for a covered relative’s
diligent, good faith efforts). It is the a work-related injury or illness, some illness, you must contact Human
associate’s responsibility to provide or all of your leave may be paid Resources periodically (generally
the Company with timely, complete for by the workers’ compensation every 30 days) regarding the
and sufficient medical certifications. carrier to the extent you are status of the condition and your
The Company will inform associates deemed eligible for such benefits. intention to return to work. If an
if submitted medical certifications The substitution of paid leave time associate’s anticipated return to
are incomplete or insufficient and for unpaid leave time does not work date changes and it becomes
provide associates at least seven extend the 12 weeks of FMLA leave. necessary for the associate to
calendar days to cure or correct Upon written request, the Company take more or less leave than
deficiencies. The Company will deny will allow associates to use accrued originally anticipated, the associate
FMLA leave to associates who fail to PTO to supplement any paid must provide the Company with
timely cure or correct deficiencies disability benefits. reasonable notice of the associate’s
or otherwise fail to timely submit Medical and Other Benefits changed circumstances and new
requested medical certifications. During an approved FMLA leave, return to work date. If associates
When leave is taken to care for the company will maintain your give the Company unequivocal
a covered service member with benefits as though you continue to notice of their intent not to return
a serious injury or illness, the be actively employed. If paid leave to work, the Company’s obligation
Company may require associates to is substituted for unpaid FMLA to maintain health benefits (subject
obtain certifications completed by leave, the company will deduct to COBRA requirements) and to
an authorized health care provider your portion of any applicable restore their positions cease.
of the covered service member. In premiums as a regular payroll Return from Leave
addition, and in accordance with deduction. If your leave is unpaid, When the approved FMLA leave
the FMLA regulations, the Company you must prepay the full amount ends, the associate (with the
may request that the certification of any premiums that would exception of those associates
submitted by associates set forth ordinarily be due. Check with designated as “highly compensated
additional information provided by Human Resources for the amount
the associate and/or the covered of your premiums and payment
service member confirming procedures. Your benefit coverage
entitlement to such leave. will cease if your premium payments
Leave & PTO Usage are more than 30 days late; the
FMLA leave is unpaid. In general, company will issue written notice
any accrued PTO must be prior to cancellation. The company
substituted for any unpaid FMLA may recover premiums it paid for
leave. Sick leave must be used to maintaining benefits during unpaid
the extent the reason for the FMLA FMLA leave if the associate fails to
absence is covered by the sick leave return to work after the expiration
policy; in certain circumstances, of his or her FMLA leave, unless

ASSOCIATE’S HANDBOOK | 27
 associates” under the FMLA) will off between the two. because they request or take leave
be returned to the same position, Associates may utilize PTO during in accordance with this policy.
if available, or to a similar available this leave. If PTO is unavailable Abuse Victim/Domestic Violence
position for which the associate is the leave will be unpaid. Finally, Leave
qualified with equivalent pay and associates may be eligible for short Roche Bros. complies with all
benefits. Unless otherwise required term disability benefits during this applicable laws governing time off
by applicable law, the company period. The substitution of paid for victims of domestic violence,
cannot guarantee reinstatement time for unpaid leave time does not stalking, sexual assault and
to associates who take more than extend the length of leave under kidnapping and when an associate’s
12 weeks of leave in the rolling 12 this policy and the paid time will family member is a victim of abusive
month period. run concurrently with an associates behavior. Associates may take up
If you take FMLA leave because of leave entitlement under this policy. to 15 days of unpaid leave within a
your own serious health condition, Associates must provide at least 12-month period to address issues
you are required to provide a two weeks’ notice of the intended related to the abuse.
medical certification that you are fit departure date for leave, and Where they overlap, leave
to resume work including whether notice of the intention to return to taken under this policy will run
there is a need for any workplace work or provide notice as soon as concurrently with leave under the
accommodations. The Company practicable if the delay is for reasons Family and Medical Leave Act.
may delay and/or deny job beyond the individual’s control. Leave taken under this policy must
restoration until associates provide Parental leave runs concurrently be used to address issues directly
return to work/ fitness for duty with Family and Medical Leave and related to the abusive behavior and
certifications. the receipt of short term disability may be used to:
Questions and/or Concerns about benefits or paid time.
• Seek or obtain medical attention;
FMLA Leave At the conclusion of parental receive counseling, victim services
If you have questions regarding leave, associates will generally be or legal assistance;
this FMLA policy, please contact reinstated to their previous position
Human Resources. The Company is • Secure housing;
or a similar position with the same
committed to complying with the status, pay, length of service credit • Obtain a protective order from a
FMLA and, whenever necessary, and seniority as of the date of their court;
shall interpret and apply this policy leave. If an associate requests and • Appear in court or before a grand
in a manner consistent with the is granted an extension of parental jury;
FMLA. leave beyond eight (8) weeks, the
• Meet with a district attorney or
Parental Leave associate is not guaranteed job
other law enforcement official;
Regular full-time associates who reinstatement under this policy.
have completed the introductory Associates, however, may be • Attend child custody proceedings;
period are eligible for eight weeks entitled to job reinstatement under • Address other issues directly
of unpaid parental leave for the other applicable laws, such as FMLA related to the abusive behavior
purpose of giving birth or for the during the extension. against the associate or covered
purpose of adopting a child under If leave is not protected under family member.
the age of 18 or a person under the applicable law, the Company Associates may be required to
age of 23 if that person is physically provides no assurance the provide supporting documentation
or mentally disabled. associate will be restored to his or for a leave, including a police report,
If both spouses work for the her previous position or a similar court order etc.
Company and are eligible for leave position when the extension expires.
Associates must exhaust any
under this policy, the spouses will be The Company will not discriminate available PTO and sick leave, if
limited to a total of eight workweeks or retaliate against associates applicable.

28 | ASSOCIATE’S HANDBOOK
An associate who is the perpetrator scheduled to minimize disruption to The company requires that an
of the abusive behavior is not normal work schedules. associate use any accrued but
eligible for leave under this policy. Military Leave unused PTO and sick time, if
Associates who wish to take Roche Bros. will provide you with applicable, during his or her small
leave to care for themselves or a leave of absence to allow you necessities leave, which will be
an eligible family member should to satisfy your military service or counted against the twenty-four
provide Roche Bros. adequate reserve obligations as required (24) hour leave period described
advance notice unless the associate by law. You should notify your above. After such accrued paid
or the family member faces department manager of the dates of time is exhausted, such leave will be
imminent danger. Please contact the leave as soon as possible, unless unpaid.
Human Resources for additional disclosure is prohibited by military Veterans’ Day and Memorial Day
information. necessity. Leave for Veterans
Crime Victim Leave Associates who are called for active The Company will provide
Associates who are victims of duty in the armed forces shall be associates who are veterans, time
a crime may take time off from entitled to all rights and benefits off to participate in local Veterans’
work to appear as a witness in afforded to them by applicable state Day or Memorial Day exercises,
a criminal proceeding regarding and federal law. parades or services. For purposes
that crime. Leave under this policy of this policy, a veteran is someone
Small Necessities Leave
will be unpaid except that exempt who has received an honorable
Under Massachusetts law, associates
associates will not incur any discharge from military service.
eligible for FMLA Leave also may
reduction in pay for a partial week take up to an additional twenty- Associates whose services are
absence due to witness duty. four (24) hours of unpaid leave in essential to the Company’s safety
Associates should notify the a rolling 12-month period for the and security are not eligible for this
Company of their required service following purposes: (1) to take leave.
prior to the day of attendance. a child or elderly (60 years old) Time off on Veterans’ Day will
Time Off to Vote relative (by blood or marriage) be paid, so long as the associate
The Company encourages all to a routine medical or dental provides reasonable advance notice
associates to fulfill their civic appointment (or, in the case of an before taking the leave. Time off
responsibilities and to vote in all elderly relative, to an appointment for Memorial Day will be unpaid,
public elections. Most associates’ for other professional services except that exempt associates may
schedules provide sufficient time related to that elder’s care); or (2) to receive pay, as required by law.
to vote either before or after participate in a child’s educationally- Associates should contact their
working hours. Associates who related school activity (including supervisor to make appropriate
have less than two consecutive licensed day care facilities), such arrangements.
hours between the time their polling as a parent-teacher conference or
location opens and the time their interviewing for a new school.
scheduled shift begins may arrive Associates who qualify to take leave
late to work so that they have a under this Section are required to
total of two consecutive hours after give the company at least seven
the polls open to vote. Time off (7) days’ notice of an intention to
under this policy will be without pay, take leave if the need for leave is
except that exempt associates may foreseeable. If the need for leave
receive pay, as required by law. is not foreseeable, associates must
Associates must provide reasonable give notice as soon as practicable.
advance notice of the need for time Associates may be asked to provide
off to vote so that time off can be certification for the absence.

ASSOCIATE’S HANDBOOK | 29
 Volunteer Emergency Responder WORKERS’ COMPENSATION break time cannot run concurrently
Leave Roche Bros. provides Workers’ with meal and break periods already
An associate who serves as a Compensation insurance for all of its provided to the associate, the break
volunteer firefighter or emergency associates. The plan will pay medical time will be unpaid for non-exempt
medical technician may take time expenses and provide income in associates. Please speak to Human
off from work to respond to an the event of a work-related illness Resources if you have questions
emergency that occurs prior to the or injury, to the extent provided by regarding this policy.
time the associate is scheduled to applicable law.
report to work. For purposes of this SEVERE WEATHER CONDITIONS
If you are injured on the job, Roche
policy, “respond to an emergency”
Bros. will pay you for the remainder If you anticipate that your arrival
means responding to, working at
of your scheduled hours if you are to the workplace may be delayed
the scene of or returning from, a fire,
unable to complete the shift on the due to weather conditions, please
rescue, emergency medical service
day of the injury. Failure to report an contact your supervisor at least
call, hazardous materials incident
injury immediately may result in the an hour before your scheduled
or a natural or man-made disaster
denial of the claim. start time. Stay tuned to your local
in the good faith belief that such
To the extent applicable, any weather channel for conditions in
action is necessary to prevent the
period of time an associate is out your area. The Company urges each
imminent loss of life or property.
of work and receiving workers’ associate to plan ahead and drive
Leave under this policy will safely.
compensation, payments will
be unpaid except that exempt
run concurrently with any period If severe weather conditions exist
associates will receive pay when
of Family and Medical Leave and the Chief Operating Officer (or
required by applicable law.
Act (“FMLA”) leave of absence, designated representative) decides
The Company may request pregnancy/childbirth medical leave to close the Company or a particular
associates to provide a statement of absence or other medical leave of location for the remainder of the
signed by the chief of the fire or absence. day, you will be notified as soon as
ambulance department certifying possible by your manager. If a non-
During the time you are out of
the date and time the associate exempt (hourly) associate is sent
work and are receiving workers’
responded to and returned from the home before having worked three
compensation payments, you will
emergency. (3) hours, they will be paid a total of
not be eligible to earn or accrue
PTO. Workers’ compensation three (3) hours of work for the day,
SERVICE AWARD RECOGNITION benefits are monetary only and do paid at the employee’s regular rate
PROGRAM not confer substantive leave rights. of pay. If an hourly associate is sent
Leave rights are covered under home after having worked three
Roche Bros. recognizes that our
other applicable company policies. (3) hours, they will be paid for the
associates are one of our most
time actually worked. If an hourly
important assets. Each year we
associate’s manager asked that they
honor those dedicated associates LACTATION ACCOMMODATION
remain at work after the Company
who are celebrating 5, 10, 15, The Company will provide a closes because of severe weather
20, 25, 30, 35, and 40+ years of reasonable amount of break time to conditions, they will be paid for the
service with our company. These accommodate an associate nursing hours that they work beyond the
associates are recognized for their for the associate’s infant child, to the announced closing time.
achievement, dedication, and extent required and in accordance
excellence in customer service. with applicable law. The break time,
if possible, must run concurrently
with meal and break periods already
provided to the associate. If the

30 | ASSOCIATE’S HANDBOOK
TRAVEL PAY This program requires the full company-owned vehicle, unless
Whenever an associate is cooperation of all drivers to operate the associate is using a hands-free
transferred at the request of the their vehicles safely and to adhere device. Texting is strictly
Company from one location to to the following requirements. prohibited and associates
regularly work (and not just on 1. All Drivers must always: should also be aware that texting
a temporary basis) in a store while driving is a violation of
• Operate a motor vehicle in a safe
that is not accessible by public Massachusetts law, in addition to
manner.
transportation and uses his/her car being a violation of Company
• Wear a seatbelt whenever the policy. All cell phone laws must be
to travel to and from work, he/she
vehicle is in motion and require obeyed at all times.
receives a mileage allowance at the
other occupants to do so.
rate determined by Roche Bros. for Associates are responsible for all
mileage reimbursement for miles • Maintain a valid driver’s license traffic and parking violations that
traveled in excess of 40 miles each and registration (if applicable). occur while any company owned,
way, per day (80 miles round trip) • Maintain a current state vehicle leased or rental vehicle is assigned
from his/her residence. inspection. to them. In the event an associate
Example: Associate travels 43 miles fails to make timely payment for a
• Abide by all state, federal and
each way to work totaling 86 miles violation, the company may, in its
local motor vehicle laws and
a day. Associate will be eligible discretion, pay the violation and
regulations.
to be reimbursed for the miles any accumulated penalties. In such
• Ensure the vehicle is maintained in event, in addition to being subject
exceeding 40 each way. In this case,
safe driving condition. to disciplinary action up to and
the associate will be reimbursed for
six (6) miles a day. 2. Company owned, leased, or rented including immediate termination,
vehicles are only to be operated the associate authorizes the
This policy is not applicable
by authorized drivers, unless company to deduct any amount
to associates who move their
otherwise designated. paid from the associate’s earned
residences to a point more distant
Unauthorized passengers are wages to the extent permitted by
from their place of employment. The
prohibited from being present in law.
Store Director and/or Vice President
a company vehicle.
of Store Operations must approve
RESPONSIBLE UTILIZATION OF
all payments pursuant to this policy. 3. Roche Bros. may request and
ELECTRONIC COMMUNICATION
review an associate’s Motor
MOTOR VEHICLE POLICY SYSTEMS
Vehicle Record annually.
Some associates operate company
The Company maintains a separate
owned, leased, rental or personal 4.When a company owned, leased
Electronic Communications policy
vehicles as part of their jobs. or rental vehicle is also operated
which applies to all associates. The
Associates must review and sign for personal use, only the
Electronic Communications policy is
our company driver policies. associate will be permitted to
intended to provide associates
Associates are expected to operate operate the vehicle.
vehicles safely to prevent accidents. 5. Associates are prohibited from
It is the policy of Roche Bros. using motorcycles when traveling
to provide and maintain a safe on company business.
working environment to protect
6.Cell phone usage while operating
our associates and the citizens of
a vehicle on company time is
the communities where we conduct
discouraged and the Company
business from injury and property
prohibits associates from using
loss. The company is committed
cellular phones for business
to promoting a heightened level of
reasons while driving or for any
safety awareness and responsible
reason while driving for work
driving behaviors in its associates.
related purposes or driving a

ASSOCIATE’S HANDBOOK | 31
 with general guidance on use as an associate of the Company. must follow the established terms
of Company-provided systems If from your post in a blog or and conditions of use that have
(including for example, e-mail, elsewhere in social media it is clear been established by the venue and
voicemail, telephone and Internet you are a Company associate, or if not violate those rules.
access systems). Associates are you mention the Company, or it is Do not post any information or
expected to read and understand reasonably clear you are referring conduct any online activity that
the policy and must comply with to the Company or a position may violate applicable local, state
it. Any associate who does not taken by the Company and you or federal laws or regulations. Any
understand any of the requirements express a political opinion or an conduct which is illegal under the
contained within the policy should opinion regarding the Company’s law is illegal if expressed in any
contact Human Resources. positions or actions, the post must other form or forum including social
specifically note that the opinion media.
SOCIAL MEDIA expressed is your personal opinion Recognize Other’s Privacy
This policy establishes a set of rules and not the Company’s position. Before sharing a comment, post,
and guidelines for any activity and This is necessary to preserve picture or video about or from a
participation in “social media” by the Company’s good will in the friend or colleague through any
all Company “users.” These rules marketplace. type of social media, it is a good
are intended to be adaptable to the Follow Existing Policies and Terms practice to be courteous and first
changes in technology. of Use obtain his or her consent.
For purposes of this policy: Observe and follow (i) existing It also is inappropriate to use or
Company policies and agreements, disclose personal information (as
The term “social media” applies
such as our Associate Handbook, explained below) about another
to any web-based and mobile
if applicable, (ii) the policies of the individual or use or disclose
technologies, in use now or
particular online/social networking the Company’s confidential or
developed in the future, that
venue, and (iii) applicable law. This proprietary information (explained
enable individuals or entities to
means that you are prohibited below) in any form of social media.
disseminate or receive information,
from using social media to post or For purposes of this Policy, personal
communicate, or otherwise interact,
display comments about coworkers information means an individual’s
and includes, without limitation,
or supervisors or the Company that Social Security number, financial
email, texting, messaging, social
are vulgar, obscene, threatening, account number, driver’s license
networking, blogging, micro-
intimidating, or a violation of the number and medical information
blogging, bulletin boards, and
Company’s workplace policies (including family medical history),
so on, through providers such as
against discrimination, harassment, as well as, if applicable, information
Facebook, LinkedIn, Instagram,
or hostility on account of race, sex, covered by the Company’s written
Twitter, YouTube or others. The
gender, ethnicity, religion, creed, information security program.
term “users” refers to associates,
age, color, military/veteran status, Company confidential or proprietary
volunteers and interns.
sexual orientation, gender identity, information includes but is not
Exercise Responsibility Online disability, genetic information, limited to internal information
You are personally responsible for ancestry, national origin, pregnancy, regarding the Company’s finances,
any of your social media activity childbirth or related medical future business performance
conducted with a Company email conditions or any other category and business plans, business and
address or on a Company website protected by applicable law. brand strategies, and information
or page, and/or which can be
Most websites, including Facebook which is or relates to Company
traced back to a Company domain,
and others, have rules concerning trade secrets. All Company rules
and/or which uses the Company’s
the use and activity conducted on regarding Company confidential
Information Systems and/or which
their sites. These are sometimes or proprietary information and
expressly or implicitly identify you
referred to as “Terms of Use.” You personal information, including, as

32 | ASSOCIATE’S HANDBOOK
applicable, the Company’s written relationships or the Company’s must avoid use of social media
information security program, network to influence polls, rankings, during working time (i.e. the time for
apply in full to social media, such or web traffic. You are not to use the which an associate is paid and/or is
as blogs or social networking sites. size and breadth of the Company scheduled to be performing services
For example, any information that network to unduly influence polls, for the Company; it does not include
cannot be disclosed through a rankings, or web traffic where said break periods, meal periods, or
conversation, a note, a letter or an traffic is a measure of success or periods in which an associate is not
e-mail also cannot be disclosed in popularity of a particular political performing and is not scheduled to
social media. Sharing this type of opinion. be performing services or work for
information, even unintentionally, Manage Your Expectation Of the Company).
can potentially result in harm to the Privacy Avoid Personal Attacks, Online
individual, harm to the Company’s Consistent with the Company’s Fights And Hostile Personalities
business and ultimately you and/ Computer Security Policy, the If a blogger or any other online
or the Company being exposed to Company may access and monitor influencer posts a statement you
legal action and/or subjecting you its Information Systems and obtain disagree with, you can voice your
to disciplinary action. the communications within the opinion, but we suggest that you
Before posting any online material, systems, including email, Internet do not escalate the conversation
ensure that the material is not usage, and other electronic activity, to a heated, personal argument.
knowingly false. If you find that with or without notice to users Speak reasonably, factually and with
you’ve made a mistake, we of the system, in the ordinary good humor. Try to understand and
encourage you to admit and/ course of business when we deem credit the other person’s point of
or correct it and move on. You it appropriate to do so. As such, view. The Company’s violence free
should never post anything that is when using such systems, there is workplace does not allow online
maliciously false. no privacy and you should have no media that impacts the Company or
Before posting a comment or expectation of privacy with regard its associates.
responding to a blog, think before to time, frequency, content or other Identify Any Copyrighted Or
sending. If you are unsure about the aspects of your use, including Borrowed Material With Citations
effects of the post or other online the websites you visit and other And Links
action, you may wish to reach out to Internet/Intranet activity. The Associates must comply with
your manager or Human Resources reasons the Company accesses and intellectual property rights.
for some assistance, particularly monitors these systems include, but
Should you have any questions
when unsure about a response to are not limited to: maintaining the
about this policy, please see Human
another associate or a client. system; preventing or investigating
Resources.
allegations of system abuse or
Use Your True Identity
misuse; assuring compliance with
When participating in any social
software copyright laws; and
media, we suggest that you be
complying with legal and regulatory
completely transparent and disclose
requirements. The usage of cameras
your true identity for your personal
and video may also be reviewed in
protection. Additionally, when
the workplace.
commenting on or promoting any
Company product or service on Interact On Your Time
any form of social media, you must The Company respects the right of
clearly and conspicuously disclose any associate to participate in social
your relationship with the Company media, such as maintaining a blog
to the members and readers of that or participating in online forums.
social media. However, to protect the Company’s
interests and to oversee associates’
Do not use your own personal online
focus on their job duties, associates

ASSOCIATE’S HANDBOOK | 33
 CONFIDENTIAL AND Confidential Information does or other proceeding, if such filing
PROPRIETARY BUSINESS not include information lawfully is made under seal so that it is not
INFORMATION acquired by non-management made public; and, (2) an individual
Many associates may have access associates about wages, hours who pursues a lawsuit for retaliation
to the Company’s confidential and or other terms and conditions of by an employer for reporting a
proprietary business information employment, if used by them for suspected violation of the law may
or trade secrets as a result of purposes protected by §7 of the disclose the trade secret to the
and during their employment. National Labor Relations Act such attorney of the individual and use
The protection of confidential as engaging in collective bargaining the trade secret information in the
and proprietary business or engaging in other concerted court proceeding, if the individual
information and trade secrets is activity for their mutual aid or files any document containing the
vital to the interest and success of protection. Nothing in this policy trade secret under seal, and does
Roche Bros. Each associate should or Handbook prohibits an associate not disclose the trade secret, except
use all reasonable care to protect or from communicating with any as permitted by court order.
otherwise prevent the unauthorized governmental authority or making Except as set forth in this policy,
disclosure of such information. In a report in good faith and with a associates are required to maintain
no event should associates disclose reasonable belief of any violations of the confidentiality of such
or reveal confidential information law or regulation to a governmental information, take steps to protect
within or outside the Company authority, or disclosing Confidential it from disclosure, and refrain from
without proper authorization or Information which the associate utilizing it or disclosing it to any
purpose. acquired through lawful means in outside person or organization
the course of his or her employment without prior written authorization.
“Confidential Information” refers
to a governmental authority in
to a piece of information, or a The obligation to maintain
connection with any communication
compilation of information, in any confidentiality applies even after
or report, or from filing, testifying or
form (on paper, in an electronic employment with the Company
participating in a legal proceeding
file, or otherwise), related to the ceases. Furthermore, upon demand,
relating to any violations, including
Company’s business that the but in no event later than at
making other disclosures protected
Company has not made public separation of employment with the
or required by any whistleblower
or authorized to be made public Company, associates must return
law or regulation to the Securities
and that is not generally known all confidential documents, papers,
and Exchange Commission, the
to the public through proper memoranda, and any other material
Department of Labor, or any
means. Associates who by virtue that belongs to the Company in
other appropriate government
of their performance of their job their possession and/or control.
authority. Under the 2016 Defend
responsibilities have the following
Trade Secrets Act (DTSA): (1) no Any associate who learns of any
information, should not disclose
individual will be held criminally or improper use or disclosure in
such information for any reason,
civilly liable under Federal or State violation of this policy should
except as required to complete job
trade secret law for the disclosure immediately contact his or her
duties, without the permission of
of a trade secret (as defined in the supervisor, store manager, the Vice
the associate at issue: social security
Economic Espionage Act) that: President of Operations or the
numbers, driver’s license or resident
(A) is made in confidence to a Human Resources Department.
identification numbers, financial
Federal, State, or local government An associate who improperly
account, credit or debit card
official, either directly or indirectly, discloses information in violation
numbers, security and access codes
or to an attorney; and made solely of this policy may be subject to
or passwords that would permit
for the purpose of reporting or disciplinary action, up to and
access to medical, financial or other
investigating a suspected violation including termination.
legally protected information.
of law; or, (B) is made in a complaint
or other document filed in a lawsuit

34 | ASSOCIATE’S HANDBOOK
RECEIPT OF ASSOCIATE’S HANDBOOK

I have received either a hard copy or electronic version of the Roche Bros. Associate’s
Handbook and I understand that I am responsible for becoming familiar with the policies
described in it. I understand that the information contained in it represents management
guidelines only, which may be modified from time to time.

I understand that no contract of employment other than “at will” has been expressed or
implied, and that no circumstances arising out of my employment will alter “at will” status
on an individual or collective basis except an express written agreement signed by the
Company’s Chief Operating Officer. As such, I further understand that my employment is
voluntarily entered into, that I am free to resign at any time, and that the Company may
terminate the employment relationship at any time, with or without reason, notice or cause.

I understand the Company has provided me various alternative channels to raise concerns
of violations of this handbook and company policies and encourages me to do so promptly
so that the Company may effectively address such situations, and I understand that nothing
herein interferes with any right to report concerns, make lawful disclosures, or communicate
with any governmental authority regarding potential violations of laws or regulations.
I agree to abide by and be bound by the rules, policies and standards set forth in the
Associate Handbook.

I also understand and acknowledge that nothing about the policies and procedures set
forth in this Handbook should be construed to interfere with any associate rights provided
under state or federal law, including Section 7 of the National Labor Relations Act.

Associate Signature ________________________________________________________

Name (please print) ________________________________________________________

Date ___________________________________ Associate Number_________________

Revised January 2019

ASSOCIATE’S HANDBOOK | 35
NOTES

36 | ASSOCIATE’S HANDBOOK