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					 “Valuable Learning, Meaningful Work, Successful
                      Lives”




EMPLOYEE HANDBOOK
For Exempt and Non-Exempt Employees
December 2010
TABLE OF CONTENTS
WELCOME TO GRYPHEN SPECIALTY PRODUCTS AND SERVICES

Welcome Message .................................................................................................................................................... 8

Company History....................................................................................................................................................... 9

Goals, Values & Beliefs .......................................................................................................................................... 10

GENERAL INFORMATION ABOUT RESOURCES FOR YOU

Resources Are Guides ............................................................................................................................................. 12

Employee Handbook ............................................................................................................................................... 12

Policy and Procedure Manual ................................................................................................................................. 12

Changes in Policy .................................................................................................................................................... 12

GSPS Management .................................................................................................................................................. 12

EMPLOYMENT POLICIES

Nature of Employment ............................................................................................................................................ 14

Equal Opportunity Employment .............................................................................................................................. 15

Cultural Diversity Policy Statement ........................................................................................................................ 16

Employment Procedure ........................................................................................................................................... 17

Employment Applications ....................................................................................................................................... 18

Immigration Law Compliance ................................................................................................................................. 19

Reference Checks .................................................................................................................................................... 20

Background Checks ................................................................................................................................................. 21

Personnel Files......................................................................................................................................................... 22

Personnel Data Changes .......................................................................................................................................... 23

Fingerprint Clearance Card Reimbursement Policy ................................................................................................ 24

New Employee Introductory Period ........................................................................................................................ 25

Employee Orientation .............................................................................................................................................. 27

Training ................................................................................................................................................................... 28




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Professional Development ....................................................................................................................................... 29

Outside Employment ............................................................................................................................................... 30

Employee Referral Program .................................................................................................................................... 31

Employee Suggestion Program ................................................................................................................................ 32

Service Commendations .......................................................................................................................................... 33

Performance Evaluations ......................................................................................................................................... 34

Corrective Action .................................................................................................................................................... 35

Employee Grievance Policy and Procedure ............................................................................................................. 37

Termination of Employment.................................................................................................................................... 39

Reductions in Force ................................................................................................................................................. 40

CLASSIFICATION AND COMPENSATION PRACTICES

Wage and Salary Administration ............................................................................................................................. 42

Employment Classifications .................................................................................................................................... 43

Timekeeping ............................................................................................................................................................ 44

Time Clock Guidelines for Non-Exempt Employees .............................................................................................. 44

Payment of Salaries for Exempt Employees ............................................................................................................ 49

Special Pay Practices ............................................................................................................................................... 50

Expense Reimbursement ......................................................................................................................................... 53

Mileage Reimbursement .......................................................................................................................................... 54

Deductions ............................................................................................................................................................... 55

Paydays .................................................................................................................................................................... 56

Wage and Salary Increases ...................................................................................................................................... 57

BENEFIT INFORMATION

Health Insurance ...................................................................................................................................................... 59

Dental Insurance ...................................................................................................................................................... 60

Vision Insurance ...................................................................................................................................................... 61

Life Insurance .......................................................................................................................................................... 62




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Qualifying Events for Changes to Benefits ............................................................................................................. 63

COBRA ................................................................................................................................................................... 64

Worker’s Compensation .......................................................................................................................................... 66

ATTENDANCE

Attendance and Punctuality .................................................................................................................................... 68

Paid Time Off (PTO) ............................................................................................................................................... 69

Family and Medical Leave Act (FMLA) ................................................................................................................. 71

Personal Leave of Absence ...................................................................................................................................... 74

Bereavement Leave ................................................................................................................................................. 75

Administrative Leave ............................................................................................................................................. 76

Jury Duty ................................................................................................................................................................. 77

Military Leave ......................................................................................................................................................... 78

Holidays ................................................................................................................................................................... 79

Emergency Closure.................................................................................................................................................. 80

STANDARDS OF CONDUCT

Standards of Conduct ............................................................................................................................................... 82

Code of Ethics ......................................................................................................................................................... 83

Nondisclosure and Confidentiality .......................................................................................................................... 86

Sexual and Other Unlawful Harassment .................................................................................................................. 87

Harassment Investigation Policy ............................................................................................................................. 89

Reporting Abuse and Neglect .................................................................................................................................. 91

Workplace Violence ................................................................................................................................................ 92

Drug and Alcohol Abuse ......................................................................................................................................... 93

Smoking ................................................................................................................................................................... 95

Gift Policy ............................................................................................................................................................... 96

Visitors in the Workplace ........................................................................................................................................ 98

Personal Appearance and Dress Code .................................................................................................................... 99




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Cell Phone Usage................................................................................................................................................... 102

Email Etiquette Policy ........................................................................................................................................... 103

Blogging and Social Media Policy ........................................................................................................................ 108

Public Relations ..................................................................................................................................................... 110

Whistleblower Protection ...................................................................................................................................... 111

USE OF COMPANY RESOURCES

Use of Company Property ..................................................................................................................................... 113

Intellectual Property and Ownership of Work ....................................................................................................... 114

Company Supplies ................................................................................................................................................. 115

Computer Usage .................................................................................................................................................... 116

Internet Usage ........................................................................................................................................................ 117

Email Usage........................................................................................................................................................... 119

Telephone Usage ................................................................................................................................................... 120

Fleet Driver and Vehicle Management Policy ....................................................................................................... 121

Energy Conservation and Cost Savings Policy ...................................................................................................... 131

DAY-TO-DAY ADMINISTRATIVE FOCUS

Company Hours ..................................................................................................................................................... 137

Safety and Security ................................................................................................................................................ 138

Parking ................................................................................................................................................................... 140

Personal Property................................................................................................................................................... 141

Privacy Expectations ............................................................................................................................................. 142

Internal Communication ........................................................................................................................................ 143

Internal Incident Reporting ................................................................................................................................... 144

Housekeeping ........................................................................................................................................................ 145

Breaks and Meal Times ......................................................................................................................................... 146




                                                                                   Page 5
WELCOME TO GRYPHEN SPECIALTY
PRODUCTS AND SERVICES




             Page 6
WELCOME MESSAGE

Dear Employee,

Welcome to Gryphen Specialty Products and Services!

We are excited to have you as part of our progressive team! You were hired because we believe
you will share our commitment to our mission, contribute to our overall success, and help us
achieve our goals.

Gryphen Specialty Products and Services is committed to providing superior quality and
unparalleled effectiveness in all aspects of our business. As part of our team, you will discover
that our collective pursuit of excellence is truly a rewarding aspect of your career with Gryphen
Specialty Products and Services.

This employee handbook contains information on the policies, benefits, and mutual expectations
you will need as part of the Gryphen Specialty Products and Services team.

The success of Gryphen Specialty Products and Services is dependent upon how well we operate
as a unified team. We must earn the trust and respect of those we serve and work with every day
to prove ourselves worthy of their trust and respect.

We believe that our greatest assets are creative, productive employees empowered to make
suggestions and think "outside the box." Your job, and the jobs of your colleagues, is to make
decisions that align with our values and will lead to the realization of our mission.

Our primary goal at Gryphen Specialty Products and Services is to live our mission statement
and continue to perform as an industry leader. We believe that the only way to achieve this is
through hard work and commitment at all levels. Our desire, as management of Gryphen
Specialty Products and Services, is organizational and individual success; we are committed to
achieving this success by acknowledging employees as investors in our company and treating
them as such.

This handbook will be a valuable reference throughout your career with Gryphen Specialty
Products and Services. Additionally, the policies contained herein are intended to ensure
consistent management and fair treatment of all employees. From time to time, you may have
questions that are not answered by this handbook. If so, please feel free to discuss them with
your supervisor. At Gryphen Specialty Products and Services, we strive to develop our team and
recognize the contributions of all employees.

Welcome aboard. We look forward to working with you!

Sincerely,

Todd Lewis, M.Ed.
CEO & President



                                              Page 7
COMPANY HISTORY

Founded in 2009 in Tempe, Arizona, Gryphen Specialty Products and Services (GSPS) was
formed to support the choices of individuals with developmental disabilities. GSPS promotes and
provides within communities, flexible, quality, consumer-driven services, supports and
employment. Through a qualified vendor contract with the Arizona Department of Economic
Security (DES), Division of Developmental Disabilities (DDD), GSPS provides various services
to adults with developmental disabilities such as (but not limited to) autism, cerebral palsy,
seizure disorder, and mental retardation.
GSPS is comprised of three core programs: Supported Employment, Vocational Services and
Day Habilitation. Our goal is to help each individual strive towards independence to the best of
their capabilities and to ensure that everyone is satisfied with services provided. These services,
provided on a daily basis, consist of supported employment, daily living skills, interactive
meaningful activities and job training skills. We also provide various educational, leisure, and
social activities.

In early 2010, the company’s continued growth led to a GSPS location in the city of Casa
Grande, Arizona. This center is home to our fully functioning farm, which gives consumers the
opportunity to learn how to grow and harvest crops and raise livestock. Later that same year,
GSPS expanded to a third location in the rural city of Coolidge, Arizona. With each additional
location, GSPS provides unparalleled service to individuals with developmental disabilities and
their loved ones.

Our Tempe location is home to our Senior Management, Marketing, Operations, and Finance
Departments. Each GSPS location employs a fully trained staff of dedicated individuals who not
only profess their belief in mission and values of GSPS, but also display these concepts through
their behaviors and actions each and every day.

We are proud to say that on a daily basis, GSPS fills a void for adults with varying abilities.
Support from parents, loved ones, and members of the community have been tremendous. With
the entire staff of GSPS sharing our vision of a program that strives to provide valuable learning,
meaningful work and successful lives, we are confident that we are headed towards a triumphant
future.




                                              Page 8
COMPANY GOALS, VALUES, AND BELIEFS

Our goal at Gryphen Specialty Products and Services (GSPS) is simple: to support the choices
of individuals with developmental disabilities by promoting and providing within communities,
flexible, quality, consumer-driven services, supports and employment. To accomplish this,
Gryphen Specialty Products and Services will:

      Provide the best possible care and services to consumers with developmental disabilities
      Develop products that are responsive to the employment needs of adults with
       developmental disabilities and consumer needs of customers
      Build strong relationships with communities
      Create strategies for harnessing the skills and talents of individuals with developmental
       disabilities
      Develop and refine educational and vocational interventions that will allow individuals
       with developmental disabilities to enhance their career potential and independent-living
       skills
      Introduce skilled and talented individuals with developmental disabilities to the
       community and employers who need and value these individual’s skills and talents and
       accept and understand their integrated role within community and workplace
      Develop and implement strategies for community outreach
      Develop a training model that can be shared with other service providers and
       communities throughout the U.S. and around the world

Our values and beliefs require that we:

      Treat each employee fairly, providing opportunities to enhance the means by which we
       improve our service.
      Treat employees and colleagues with respect; Gryphen Specialty Products and Services
       does not tolerate discrimination of any kind.
      Encourage all managers and supervisors to involve employees in creative problem
       solving. When problems arise, an important part of dealing with them is understanding
       how to avoid them in the future. f
      Provide consistent leadership and competent on-the-job training.
      Maintain an open-door policy that encourages interaction and discussion; encourage ideas
       to improve the workplace and increase productivity.
      Provide effective and efficient corrective action to resolve issues, ensure complete
       satisfaction of those we serve, and avoid recurrence of those issues.
      Deliver competitive, outstanding service and partner with others who share that goal.
      Make "Do It Right the First Time" our team attitude to ensure continued growth and
       prosperity.




                                             Page 9
GENERAL INFORMATION ABOUT
RESOURCES FOR YOU




             Page
              10
RESOURCES ARE GUIDES
This information is intended to be a guide only. This Handbook is presented as a matter of information.
It is not a contract, and neither the Handbook nor its contents are to be interpreted as a contract between
GSPS and any of its past, present, or future employees.

EMPLOYEE HANDBOOK
This Employee Handbook is a resource for you, but it is not a contract. It is designed to provide you with
general information about working for Gryphen Specialty Products and Services (GSPS). The purpose of
this handbook is to help employees become familiar with GSPS, our employment related policies and
procedures, and to help employees begin to understand what is expected of them and generally what
employees can expect during employment with GSPS. All employees receive an Employee Handbook.

This handbook, in part or in full, will only be reissued to employees when major policy changes occur, so
it may not represent the most current information about employment. For an up-to-date version of the
Employee Handbook, refer to the company website, Human Resources, or locate the hard copy
maintained in each site. Please check the Gryphen website and internal email for policy change
notifications and the most up-to-date policy information.

POLICY AND PROCEDURE MANUAL
The GSPS Handbook is different from the Policy and Procedure Manual but compliments it as a valuable
source of information about your employment with GSPS. The Policy and Procedure Manual contains
more detailed information and is the official manual regarding operations and programmatic related
policies and procedures.

Copies of the Policy and Procedure Manual are maintained in at each GSPS location, with your Human
Resources representative, and on our company website. Neither the Employee Handbook nor the
agency’s Policy and Procedure Manual can do or cover everything about working at GSPS, but they serve
as resources to answer common questions and provide general information.

GSPS MANAGEMENT
There are many employees who can be resources to you during your employment with GSPS. It is
always best to start with your supervisor. If you and your supervisor can address issues together,
everyone can benefit because the learning process will strengthen you and your team. However, there
may be times when it would be appropriate to go to other employees or departments. The Human
Resources representative is always a good resource and can assist you with regards to your alternatives.

CHANGES IN POLICY
This employee handbook supersedes all previous memos, employee handbooks, and other written
communication that may have been issued at any time on subjects covered in this employee handbook.

Company change is inevitable and, as such, we reserve the right to interpret, modify, suspend, cancel, or
dispute, with or without notice, all or any part of our policies, procedures, and benefits at any time.
Changes will be effective on the dates determined by Gryphen Specialty Products and, and after those
dates all superseded policies will be null and void.

No individual supervisor or manager has the authority to alter policies in any way. Any employee who is
unclear on any policy or procedure should consult a supervisor or Director of Operations.


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                                                    11
EMPLOYMENT POLICIES




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              12
NATURE OF EMPLOYMENT

Employment with Gryphen Specialty Products and Services is considered "at-will" and an
employee may be terminated with or without ―good cause.‖ This includes employees who have
performed their duties efficiently and effectively.

The employment relationship is entered into voluntarily and any employee is free to resign at any
time, with or without cause. With receipt and acknowledgement of the Employee Handbook, the
employee agrees that the employment is "at will" and that no terms in the handbook alter that
employment condition.

Similarly, Gryphen Specialty Products and Services may terminate the at-will employment
relationship at any time, with or without cause, in cases in which there is no violation of
applicable federal or state law.

Employees with questions or concerns about this Employment ―At-will‖ policy are encouraged
to bring these issues to the attention of the Director of Operations or Human Resources
representative.




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                                               13
EQUAL OPPORTUNITY EMPLOYMENT

This Equal Employment Opportunity policy governs all aspects of employment, including
selection, job assignment, compensation, discipline, termination, and access to benefits and
training.

Gryphen Specialty Products and Services is an Equal Opportunity Employer. This means that we
will extend equal opportunity to all individuals without regard for race, religion, sex, national
origin, age, disability, or veteran status. This policy affirms Gryphen Specialty Products and
Service's commitment to the principles of fair employment and the elimination of all existing
vestiges of discriminatory practices.

In order to provide equal employment and advancement opportunities to all individuals,
employment decisions at Gryphen Specialty Products and Services will be based on merit,
qualifications, and abilities. Gryphen Specialty Products and Services does not base such
employment decisions on race, religion, sex, national origin, age, disability, or veteran status.
Gryphen Specialty Products and Services will make reasonable accommodations for qualified
individuals with known disabilities unless doing so would result in undue hardship.

Employees with questions or concerns about discrimination in the workplace are encouraged to
bring these issues to the attention of the Director of Operations or Human Resources
representative. Employees may raise concerns and make reports without fear of reprisal. Anyone
found to be engaging in unlawful discrimination will be subject to disciplinary action, up to and
including termination of employment.




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                                                14
CULTURAL DIVERSITY POLICY STATEMENT

Gryphen Specialty Products and Services, in recognition of its responsibility to its employees,
volunteers, and the community it serves, reaffirms its commitment to cultural diversity through a
diverse paid and volunteer work force and the utilization of minority and female contractors,
vendors and suppliers. In addition, we take appropriate action to place and advance in volunteer
and paid positions females, people of color, qualified disabled individuals, disabled veterans,
veterans of the Vietnam Era, and other protected groups as required by law.
We strive to provide a pleasant work environment and equitable treatment in our employment
practices and volunteer involvement.




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                                               15
EMPLOYMENT PROCEDURE

The following policy applies to all new and rehired employees at Gryphen Specialty products
and Services.

   1. JOB POSTING: Job openings are posted internally for five working days. The posting
      may coincide with outside recruitment efforts.
   2. INTERNAL PROMOTION: When a position is available, consideration is given to
      those employees who have demonstrated by their performance and training that they are
      ready to assume additional responsibilities. Employees must remain in their present
      position for six (6) months before being considered for another position unless
      reassignment meets business needs. CEO/President or designee will have final approval.
   3. RECRUITMENT AND SELECTIONS: Recruitment for all job openings is based on a
      written job description. Interviews are conducted on the basis of job related questions. A
      completed application and satisfactory supporting references are necessary before a final
      hiring commitment is made.
   4. HIRING: Each new hire receives an offer letter stating title, starting salary, and starting
      date of employment, as well as a job description and a copy of the CEO/President or
      designee policies. When employment begins, employees receive an orientation that will
      cover matters regarding Gryphen Specialty Products and Services employment
      procedures and policies.
   5. I-9'S: No less than three calendar days prior to beginning employment, all employees
      must provide documentation proving eligibility for employment in the United States.
   6. IDENTIFICATION: Employees may be issued an identification badge at the time of
      employment. Identification badges must be returned when employment terminates.
   7. REHIRING OF FORMER EMPLOYEE: If a former Gryphen Specialty Products and
      Services employee is rehired within 12 months of the original termination date, and when
      not in conflict with other conditions, policies and programs, seniority will be recalculated
      at that time to include his/her prior period of employment. If rehired after 12 months from
      the original date of termination, a rehired employee will not be given credit for prior
      service. All rehires require CEO/President or designee review and approval. Former
      employees may not be rehired if they failed to meet all conditions set forth herein
      regarding voluntary termination of employment.




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                                               16
EMPLOYMENT APPLICATIONS

Gryphen Specialty Products and Services relies upon the accuracy of information contained in
the employment application and the accuracy of other data presented during the hiring process
and throughout employment.

Any misrepresentations, falsifications, or material omissions in any of this information may
result in exclusion of an individual from further consideration for employment or - if the person
has been hired - disciplinary action, up to and including termination of employment.




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                                               17
IMMIGRATION LAW COMPLIANCE

Gryphen Specialty Products and Services employs only United States citizens and those non-
U.S. citizens authorized to work in the United States in compliance with the Immigration Reform
and Control Act of 1986.

Each prospective new employee, as a condition of employment, must complete the Employment
Eligibility Verification Form I-9 and present sufficient documentation establishing identity and
employment eligibility. Prospective employees who are found to be ineligible to work in the
United States of America will not be hired by Gryphen Specialty Products and Services.

Former employees who are rehired must also complete the form, if they have not completed an I-
9 with Gryphen Specialty Products and Services within the past three years, or if their previous I-
9 is no longer retained or valid.

A human Resources representative will verify eligibility to work using the Everify program and
will retain the completed I-9 and Everify documentation in a separate file.




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                                                18
REFERENCE CHECKS

To ensure that individuals who join the Gryphen Specialty Products and Services team are well-
qualified and have a strong potential to be productive and successful, it is the policy of the
recruiter to check the employment references of the selected applicant prior to extending a job
offer. A minimum of three references will be checked. References should, at a minimum,
include at least two professional references and may not be from a family member or any person
related to the applicant.
Gryphen Specialty Products and Services is also designated to respond to reference check
inquiries from other employers. All calls, contacts and written inquires concerning current or
former employees should be referred to the Director of Operations. It is the policy of the
Gryphen Specialty Products and Services to provide neutral references concerning former
employees. Responses to such inquiries will confirm dates of employment, and the title of
position held.
Gryphen Specialty Products and Services will provide additional information upon receiving
signed written permission from the former employee. Only the CEO/President or a designated
representative is authorized to give detailed employment references on behalf of Gryphen
Specialty Products and Services. Only upon receipt of written authorization from the employee
or former employee will wages be verified, unless otherwise permitted or required by law.
Employees should not provide the home address, home telephone number or any other
information about another employee in response to an inquiry. Rather, a message should be taken
and the inquiry should be directed to CEO/President or designee.




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                                               19
BACKGROUND CHECKS

In order to protect the welfare of the clients, customers, employees, and resources of Gryphen
Specialty Products and Services, it is the policy of Gryphen Specialty Products and Services to
conduct background checks on those applicants and employees with a job-related need.
Background checks may include, but are not limited to: reference checks, credit history checks,
driving record checks, criminal record checks, and education and credential verification.
Applicants and current employees seeking promotional opportunities or otherwise qualifying for
a background investigation must consent to and pass a background check prior to any final
appointment or promotion decisions relating to full-time, part-time, and temporary positions.
Applicants who apply for positions in which the essential job duties require the use of company
vehicles must have a driving record in good standing. A driving record check will be made only
after a conditional job offer has been made pending the results of the check. For all employees
continued use of company vehicles is contingent on their maintenance of a good driving record
which will be assessed semi-annually.
This process is necessary to ensure that the individuals who are selected or retained possess the
qualifications required to safely and effectively perform the duties of their position.




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                                                20
PERSONNEL FILES

Employee personnel files maintained by Gryphen Specialty Products and Services include, but
are not limited to, the following:

      job application
      job description
      resume
      reference verification
      fingerprint clearance card copies and declaration statement
      background and motor vehicle checks
      training documentation
      salary history
      disciplinary reports, warnings, and other records
      performance evaluation documentation
      records of coaching and/or mentoring
      Required Certifications
      Professional Licenses

Personnel files are the sole property of Gryphen Specialty Products and Services and access to
information contained therein is restricted. Management personnel of Gryphen Specialty
Products and Services with a legitimate reason to view the file will be permitted to do so.

Employees who wish to view their own files should contact their supervisor. With reasonable
advance notice in writing, employees may view their own personnel files on Gryphen Specialty
Products and Services premises and in the presence of their supervisor. The Director of
Operations or their designee will monitor the review. Employees who disagree with materials in
their personnel files may provide their own written interpretation or statement which will be
placed in their file.

Documentation from employee personnel files may be reviewed by various licensing Agencies
(e.g. Division of Developmental Disabilities, Division of Vocational Rehabilitation, Office for
Certification Licensure and Review, etc.) as part of an audit process. Only required
documentation will be provided to the auditing agencies for review.




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                                               21
PERSONNEL DATA CHANGES

It is important that the personnel records of Gryphen Specialty Products and Services be accurate
and current. To avoid issues with benefit eligibility or legal compliance, Gryphen Specialty
Products and Services expects that all employees will promptly notify their supervisor of any
change in name, home address, telephone number, marital status, number of dependents, or any
other pertinent information subject to change.




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                                               22
FINGERPRINT CLEARANCE REIMBURSEMENT POLICY

Initial Fingerprint Clearance Reimbursement Policy: All employees requiring initial fingerprint
clearance will be required to incur the $69.00 cost initially and to produce to GSPS a photocopy
of the card upon receipt. Employees will also be required to incur the cost of getting the
fingerprints rolled. Employees who have submitted six (6) consecutive months of billing from
the date of clearance card issuance will be eligible for reimbursement for the $69.00 fee and up
to $10.00 for rolling of the prints.

Requests for reimbursement of initial fingerprint fee ($69.00) and fingerprint rolling (up to
$10.00) must be received in writing and accompanied by receipts for approval. Reimbursements
will be paid at the month-end pay period, or within thirty (30) days of receiving proper
documentation of approved request. Reimbursement requests will only be honored within six
months of eligibility (unless extenuating circumstances apply).

Renewal Fingerprint Clearance Reimbursement Policy: All fingerprint renewal fees will be paid
by GSPS in the amount of $69.00 and up to $10.00 for rolling of the prints. If the Employee is
employed by more than one agency or other employer who also requires a fingerprint card,
GSPS will pay only the cost of these fees divided by the number of agencies or employers
requiring fingerprint clearance. The Employee must submit a copy of the receipt(s) to GSPS for
the reimbursement to be approved. Reimbursements will be paid at the month-end pay period, or
within (30) days of receiving proper documentation of approved request. Reimbursement
requests will only be honored within six months of eligibility (unless extenuating circumstances
apply).




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                                               23
NEW EMPLOYEE INTRODUCTORY PERIOD


This policy is applicable to all full-time and part-time new hires at Gryphen Specialty Products
and Services. Contracted employees and temporary employees will be exempt from the
introductory period.

The first 90 days of employment are considered an introductory period for new employees.
During this time, new employees are given an opportunity to evaluate the company as a place to
work and management has the first opportunity to evaluate the new employee's performance.
Satisfactory completion of the introductory period does not alter an employee's at-will status.

The Introductory Period is used to determine if a new employee’s performance successfully
meets the expectations of the role and if continued employment is warranted. The Introductory
Period shall consist of the first ninety (90) days of employment (including transfer or promotion
within the organization).

During this time, the employee’s supervisor will work with the employee to establish clearly
defined performance goals; will educate the employee about the competencies of the position;
will provide the employee with positive feedback regarding the employee’s strengths and
progress, will share constructive feedback in reference to any deficiencies observed; and will
assess whether the employee’s performance meets the expectations of the position.

If deficiencies are identified during the Introductory Period, the supervisor will provide an
opportunity for the employee to improve performance, demonstrate competencies, and/or
achieve stated goals. If deficiencies are significant or persist throughout the Introductory Period
and appear to compromise the employee’s ability to successfully perform the job, the supervisor
must take immediate action. Such action may include termination of employment or extension
of the Introductory Period for an additional ninety (90) days. A decision to pursue termination of
employment or extension of the Introductory Period must be made in consultation with a Human
Resources representative.

Completion of the Introductory Period does not guarantee continued employment and does not
change the at-will nature of the employment relationship. The first ninety (90) days of
employment for all regular full-time or part-time staff is considered an Introductory Period.
Completion of the introductory period does not guarantee continued employment and does not
change the at-will nature of the employment relationship.

   A. AT WILL EMPLOYMENT: At all times during the Introductory Period, either the
      agency or the employee may terminate the employment relationship for no cause as it is
      at all times, an at will employment relationship.




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                                                24
B. TRANSFER TO ANOTHER POSITION: An employee must remain in a position at
   least three (3) months before voluntarily transferring to another position within the
   agency; thereafter, the employee will be subject to a new Introductory Period.
C. REHIRE: Individuals rehired into a new position in the agency must complete a new
   Introductory Period.
D. PAID TIME OFF: During the Introductory Period, employees accrue, but cannot use,
   paid vacation and personal time off. In unusual circumstances, the supervisor has the
   discretion to grant an employee time off. In the event that an employee must take time
   off for medical reasons during the Introductory Period, such leave will be granted as paid
   time off if the employee has accrued sufficient sick leave to cover the absence. If
   sufficient sick leave is not available, such leave will be granted without pay.




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                                           25
EMPLOYEE ORIENTATION

Gryphen Specialty Products and Service's Employee Orientation Program is our way of
welcoming and educating new employees. Our goal is to make new employees feel comfortable,
informed about the company, and prepared to perform well in their position.

The program includes an overview of our company history, as well as an explanation of our core
values, vision, and mission. Our intention is to provide new employees with a clear
understanding of our goals and objectives. In addition, the program will review benefits,
company programs, and standards and provide employees with the opportunity to complete any
necessary paperwork.

Employees may be presented with security and access codes, keys, and procedural information
for use in performing their jobs. New employees will be introduced to staff throughout the
company and acquainted with their personal workspace. During orientation, management may
meet with new employees to review their job descriptions and position scope, explain the
Gryphen Specialty Products and Services performance evaluation system, and answer any
specific questions.




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                                             26
TRAINING


Specific training requirements, including timelines, are required by the Arizona Department of
Economic Security’s Division of Developmental Disabilities and by Gryphen Specialty Products
and Services. Additional training may be required or necessary, depending upon individual
consumer needs, or as deemed appropriate by GSPS. All required training is to be completed
prior to the start of services. Hard copies of training certificates or proof of completion
documents, with expiration dates visible, will be provided to Gryphen Specialty Products and
Services for the personnel file where applicable.

All Direct Service Professionals will attend required trainings including, but not limited to a
general orientation, client orientation, Article 9, Client Intervention Techniques (CIT), CPR,
First Aid, and Bloodborne Pathogens. Additional training on Habilitation and Defensive Driving
will be required as needed according to the job description and duties. The trainings will include
a review of Gryphen Specialty Products and Services policies and procedures annually, terms
and conditions related to employment, understanding and implementation of Individual Support
Plans (ISPs), additional health and safety training for preventing communicable disease transfer,
incident reporting, neglect and abuse, managing inappropriate behaviors, medication
administration, program and operations related forms, and pay schedules.

All initial required training must be completed no later than ninety (90) calendar days from the
date of hire and will be documented in DSP personnel records. Renewal trainings for DSPs must
be completed and GSPS must receive a copy of the renewed certificate BEFORE the expiration
of the current certification to remain eligible to work. Failure to complete these steps will result
in suspension. Any hours worked during a suspension time will not be paid. The DSP’s
employment will be reinstated upon Gryphen Specialty Products and Services’ receipt of the
renewal documentation.

Trainings scheduled by Gryphen Specialty Products and Services are provided to the employee
at no cost. All training certificates will be owned by GSPS with no copies available to the
employee, or to other entities (prospective or not) for the benefit of the employee. If the
employee wishes to own the original certificate after completion of training, the employee will
reimburse GSPS for the cost of the training (to not include the minimum wage training time
pay). Upon receipt of the reimbursement (must be in cash), GSPS will provide the employee
with the original of the certificate, keeping a copy of it for GSPS’s files. If the employee is
unable to attend the trainings that GSPS schedules, the employee may secure training with
another, approved organization (see Note below), at the employee’s expense. No reimbursement
by GSPS will be available. In this case, the employee will own the training certificate. A copy
must be provided to GSPS as proof of training. Employees will be paid the current minimum
wage hourly rate to attend the trainings.

GSPS reserves the right to impose new trainings, as deemed necessary. All new training must be
completed within the given timeline. Failure to meet the given timeline will result in suspension
of employment.




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                                                27
PROFESSIONAL DEVELOPMENT

Gryphen Specialty Products and Services recognizes the value of employees' professional
development and personal growth. Therefore, Gryphen Specialty Products and Services
encourages employees interested in job-specific training and continuing education opportunities
to research such programs and consult their supervisor. Management approval must be obtained,
in writing, prior to registering for the seminars or courses.




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                                              28
OUTSIDE EMPLOYMENT

Employees may hold outside jobs in unrelated and/or non-competing businesses or occupations
as long as the employee meets the performance standards of their position with Gryphen
Specialty Products and Services. Unless an alternative work schedule has been approved by
Gryphen Specialty Products and Services, employees will be subject to the company's scheduling
demands, regardless of any existing outside work assignments.

Gryphen Specialty Products and Service's office space, equipment, and materials are not to be
used for purposes related to outside employment.




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                                              29
EMPLOYEE REFERRAL PROGRAM

For eligible job openings, Gryphen Specialty Products and Services encourages employees to
recommend candidates for consideration.

Under the Employee Referral Program of Gryphen Specialty Products and, if the referred
candidate is hired and successfully completes 90 days of employment, the referring employee
will be eligible for a referral reward.

If the referred employee does not successfully complete the 90 days of employment for any
reason, the referring employee will not receive a referral reward.

Employees may consult Director of Operations with questions on the Employee Referral
Program.




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                                              30
EMPLOYEE SUGGESTION PROGRAM

To involve employees at all levels in the quest to improve operations and results, Gryphen
Specialty Products and Services uses an Employee Suggestion Program. Suggestions are
evaluated regularly by a committee and considered for implementation. Employees whose ideas
lead to implementation will be eligible for a reward. For more information on the Employee
Suggestion Program, employees may consult Director of Operations.




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                                            31
SERVICE COMMENDATIONS

Employees are awarded a gift of appreciation at their fifth anniversary and every five years
thereafter, as commendation for their service in helping your Gryphen Specialty Products and
Services achieve its goals.




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                                              32
PERFORMANCE EVALUATIONS

Each employee will receive a job description, or set of job objectives, that details the
requirements and expectations of the position for which the employee was hired. These
objectives are the criteria by which Gryphen Specialty Products and Services will measure job
performance during regular performance evaluations. During each evaluation, job objectives will
be reviewed and revised if needed. Supervisors are responsible for discussing and clarifying
objectives with employees. Employees must sign a statement acknowledging agreement with,
and understanding of, these objectives.

An employee's first performance evaluation will be conducted at the completion of an
employee's new hire introductory period and at least annually thereafter in conjunction with the
employee's merit (pay) review. If it has been more than six months since an employee's last
performance evaluation, a new evaluation will be required to support a promotion or transfer to
another position. All performance evaluations are based on merit, achievement, and performance
measured against job objectives. A demotion based on performance issues requires a new
performance evaluation to support the action taken. Prior to developing a performance
evaluation that is being conducted for merit review purposes, the employee's manager/supervisor
should request the employee to complete and submit input regarding the employee's performance
during the review period.

Wage increases will be based upon this review, as well as past performance and degree of
improvement; dependability; attitude; cooperation; need for disciplinary action; adherence to all
employment policies; and employee status within a given pay range. Supervisors will review and
discuss pay range and status within that range during performance evaluations. If promoted,
employees may be eligible for an increase as dictated by the pay range of the new position.

Supervisors will conduct performance evaluations and planning sessions with all full-time and
part-time employees. Supervisors may conduct informal performance meetings and planning
sessions more often if they choose. The meeting should be scheduled ahead of time with the
employee and should occur in a private area to permit candid discussion while maintaining
confidentiality.
Performance evaluations and planning sessions are designed for the supervisors and employees
to discuss current job tasks; encourage and recognize achievement; and discuss positive,
purposeful approaches for meeting professional goals. Together, supervisors and employees
create action plans to improve performance and develop skills.
Performance evaluations will be completed using the approved forms. Performance evaluation
forms require signatures by the employee, the employee's manager/supervisor who completed
the form and the employee's department executive. If the employee refuses to sign the
evaluation, the manager/supervisor will write "Employee refused to sign appraisal form." and
add his/her initials and date to the annotation.
The original performance evaluation form will be filed in the employee's personnel file, and the
employee will receive a copy of the completed evaluation.




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                                               33
CORRECTIVE ACTION

The purpose of this policy is to outline Gryphen Specialty Products and Service's position on
administering fair and consistent discipline for unsatisfactory conduct in the workplace. We
strongly believe that the most effective approach to performance management involves setting
clear expectations for behavior, thus preventing disciplinary issues. This approach begins with
good leadership and fair supervision at all employment levels.

Our collective best interest lies in ensuring fair treatment of all employees and in making certain
that, when needed, disciplinary actions are prompt, uniform, and impartial. The main purpose of
any disciplinary action is to correct the problem, prevent recurrence, and provide the employee
with the resources to improve in the future.

Although employment with Gryphen Specialty Products and Services is on an at-will basis and
both the employee and Gryphen Specialty Products and Services have the right to terminate
employment at any time, with or without cause, Gryphen Specialty Products and Services may
take corrective action at its discretion.

Corrective action involves the use of four steps - verbal warning, written warning, suspension
with or without pay, and termination of employment - depending on the severity of the problem
and the frequency of occurrence. There may be circumstances under which one or more steps are
bypassed altogether.

Progressive discipline means that, in dealing with disciplinary problems, these steps will
normally be followed: a first offense may warrant a verbal warning; a second offense may
warrant a written warning; a third offense may warrant a paid or unpaid suspension; and a fourth
offense may warrant termination of employment.

Gryphen Specialty Products and Services recognizes that certain types of employee behavior are
serious enough to justify either a suspension or, in extreme situations, termination of
employment, without observing the above steps of progressive discipline. Though committed to
a progressive approach to corrective action, Gryphen Specialty Products and Services considers
certain rule infractions and violations of standards as grounds for immediate suspension or
termination of employment.

These include but are not limited to:

      Workplace violence
      Harassment
      Theft of any kind
      Insubordinate behavior
      Vandalism or destruction of company property
      Use of company equipment and/or company vehicles without prior authorization
      Indiscretion regarding personal work history, skills, or training
      Divulging Gryphen Specialty Products and Services business practices or any other
       confidential information


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                                                34
      Any misrepresentation of Gryphen Specialty Products and Services to a customer, a
       prospective customer, the general public, or an employee

By using a system of progressive discipline, most disciplinary problems may be avoided or
corrected at an early stage, to the mutual benefit of the employee and Gryphen Specialty
Products and Services.




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                                              35
EMPLOYEE GRIEVANCE POLICY AND PROCEDURE

It is the policy of Gryphen Specialty Products and Services to maintain a harmonious workplace
environment that is free from intimidation or harassment. Gryphen Specialty Products and
Services encourages its employees to express concerns about work-related issues, including
workplace communication, interpersonal conflict, occupational health and safety, and allocation
of work.

Employees are encouraged to raise such concerns with their supervisors on an informal basis in
the first instance. If not resolved at this level, an employee must submit in writing a signed
grievance immediately to their supervisor or if the grievance pertains to the employees
immediate supervisor, then the grievance should be submitted to the supervisor of the employee's
immediate supervisor. This written grievance must: identify the policy or regulation which is
believed to have been violated; contain a brief statement of the facts or evidence surrounding the
grievance; and include a proposed resolution.

Gryphen Specialty Products and Services assures that all employees filing a grievance or
complaint can do so without fear of retaliation or reprisal.

GRIEVANCE PROCEDURE:

A grievance is a claim by an employee who disagrees with Gryphen Specialty Products and
Services’ interpretation or application of policies, administrative decisions and/or practices as
they affect that employee's terms and conditions of employment. A grievance may not be
brought with respect to any matter over which the management has no authority to act, such as
requirements based on federal or state law or local ordinance. In order to be considered under
this procedure, the employee must initiate a grievance within ten (10) working days of the
event's occurrence about which the employee knew or should have known.

       1. VERBAL GRIEVANCE REGISTRATION: An employee who has a grievance is
       encouraged to discuss the matter with his or her supervisor at the time of the occurrence.
       In situations in which the supervisor's actions are at issue, the employee may begin with
       the supervisor's manager/director. If the supervisor's manager/director believes the
       supervisor can handle the issue, he or she may refer the employee back to the supervisor
       for action, and monitor the resolution.
       The supervisor is responsible for investigating the grievance, attempting to resolve it, and
       communicating a decision to the employee. The supervisor should seek guidance from
       CEO/President or designee and will provide a response to the employee within ten (10)
       working days of the verbal grievance being filed. If the grievance is resolved at this step,
       the supervisor will forward a copy of the grievance resolution to CEO/President or
       designee.

       2. WRITTEN GRIEVANCE REGISTRATION: If the issue was not resolved during
       initial discussions, the employee may file an Employee Grievance form within ten (10)
       working days from the time decision at Step 1 was communicated to the employee. The
       employee must forward a copy of the written grievance form to the supervisor's


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                                                36
department director and CEO/President or designee. Grievance forms are available in the
CEO/President or designee office. The department director will investigate the grievance
and provide a decision to the employee within ten (10) working days of the receipt of the
Employee Grievance registration.

3. GRIEVANCE APPEAL: If the employee is not satisfied with the result of the
Employee Grievance form, he or she may appeal the decision to the CEO/President.

       (a) Prior to meeting with the CEO/President, the employee must file a written
       Employee Grievance form and submit the completed appeal to the
       CEO/President. The completed appeal must be submitted no more than five (5)
       working days following the receipt of the department director's recommended
       resolution.
       (b) Management will investigate the grievance and issue a written decision within
       20 working days following receipt of the Grievance Appeal. The decision of the
       CEO/President is final.
       (c) Gryphen Specialty Products and Services’ process for resolving employee
       complaints incorporates fact-finding interviews of witnesses and review of
       documentation appropriate. Every effort will be made to maintain the
       confidentiality of complaints. The investigation of complaints, however, will
       generally require disclosure of a complainant's identity to certain parties. These
       disclosures should be made only on a need-to-know basis. Supervisors must
       obtain guidance from CEO/President or designee before disclosing any
       information.
       (d) Throughout the grievance process, any party may request an extension of the
       time limit from CEO/President or designee, who, depending on the circumstances,
       may grant an extension for a specific length of time.




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                                       37
TERMINATION OF EMPLOYMENT

Termination of employment is an inevitable part of personnel activity within any organization,
and many of the reasons for termination are routine. Common circumstances under which
employment is terminated include the following:

      RESIGNATION: Voluntary employment termination initiated by an employee.
      TERMINATION: Involuntary employment termination initiated by Gryphen Specialty
       Products and Services. In most cases, Gryphen Specialty Products and Services will use
       progressive disciplinary actions before dismissing an employee. However, certain actions
       warrant immediate termination.
      LAYOFF: Involuntary employment termination initiated by Gryphen Specialty
       Products and Services for non-disciplinary reasons.
      RETIREMENT: Voluntary employee termination upon eligibility for retirement.

Nonexempt employees who intend to terminate employment with Gryphen Specialty Products
and, shall provide Gryphen Specialty Products and Services with at least two (2) weeks written
notice. Exempt employees shall provide at least four (4) weeks written notice. Such notice is
intended to allow the Company time to adjust to the employee’s departure without placing undue
burden on those employees who may be required to fill in before a replacement can be found.

Since employment with Gryphen Specialty Products and Services is based on mutual consent,
both the employee and Gryphen Specialty Products and Services have the right to terminate
employment at will, with or without cause, during the introductory period.

In the case of employee termination, the employee will receive their accrued pay in accordance
with all federal, state and local laws. Any employee who terminates employment with Gryphen
Specialty Products and Services shall return all files, records, keys, and any other materials that
are property of Gryphen Specialty Products and Services.

Employee benefits will be affected by employment termination in the following manner:

      All accrued vested benefits that are due and payable at termination will be paid in
       accordance with applicable federal, state and local laws.
      Some benefits may be continued at the employee's expense, if the employee elects to do
       so, such as healthcare coverage.
      The employee will be notified of the benefits that may be continued and of the terms,
       conditions, and limitations of such continuation.

Exit Interview: Terminating employees will typically be asked to meet with the Director of
Operations or their Designee for an exit interview. This interview provides the employee an
opportunity to give feedback to Gryphen Specialty Products and Services, and includes those
measures necessary to ―close-out‖ the individuals employment status (e.g. benefits continuation,
all property returned, paperwork, etc.) If you have any questions or concerns regarding this
policy, direct them to the Director of Operations.



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                                                38
REDUCTIONS IN FORCE

At times, Gryphen Specialty Products and Services may have to reduce or change the
composition of its staff for organizational, budgetary, or management reasons. The
CEO/President has final authority regarding reorganization and/or elimination of positions. An
employee whose job is being eliminated will be notified and management will make the decision
whether other suitable alternative positions within Gryphen Specialty Products and Services are
available.
A "suitable alternative position" is defined by Gryphen Specialty Products and Services as one
which requires skills or training utilized in current position and has a salary range that is greater
than, equal to, or not more than 15% below current salary.




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                                                 39
CLASSIFICATION AND
COMPENSATION PRACTICES




             Page
              40
WAGE AND SALARY ADMINISTRATION

The following policy applies to all Gryphen Specialty Products and Services employees. All
employees will be compensated for work done on the behalf of the company. The information
below contains a more detailed description of the compensation practices of Gryphen Specialty
Products and Services.

EMPLOYEE COMPENSATION: Gryphen Specialty Products and Services maintains a "pay
for performance" approach to employee compensation. Its compensation programs are designed
to help management ensure that employees have an opportunity to earn a competitive rate of pay
based on their qualifications and performance, and that the organization receives a suitable return
on its salary investment.

JOB DESCRIPTIONS: Each position has a written job description that defines pertinent
information about the position, such as title, purpose, reporting relationships, responsibilities and
qualifications. A copy of the current job description will be provided to each employee.

SALARY GRADES/RANGES: Each position is assigned to a salary grade and salary range
based on an evaluation of the factors affecting the position. CEO/President or designee in
conjunction with department managers as appropriate will evaluate positions for salary grade
assignment. All salary grade assignments require approval by the CEO/President. Salary ranges
will be reviewed periodically, as determined by management to maintain competitiveness.

WAGE AND SALARY CHANGES:
    1. Employee rate of pay will be reviewed annually on or about his/her employment
    anniversary with Gryphen Specialty Products and Services and at certain other times
    deemed appropriate by management, such as upon promotion or demotion, transfer to
    another position or completion of an orientation period.
    2. Changes to employee rate of pay are based on Gryphen Specialty Products and
    Services’ ability to grant wage changes, the employee's demonstrated performance and
    the position of the employee's wage in the salary range for his/her job. Merit increase
    guidelines will be provided periodically by CEO/President or designee.
    Wage changes associated with a promotion, demotion or transfer will be determined on a
    case-by-case basis, but wages will be changed in such circumstances to bring the
    employee's rate of pay to an appropriate amount within the salary range for the new
    position.
    3. Generally, promotion to a position in a higher salary grade will be accompanied by an
    increase to the employee's rate of pay in recognition of the promotion. The amount of pay
    change will bring the employee's wage to at least the minimum of the new salary range. If
    his/her wage is already within the new salary range, an increase may be considered
    depending on the employee's position within the new range and his/her qualifications.
    4. Changes to employee merit rate of pay must be accompanied by a current performance
    evaluation that is dated within six months of the date of change.
    5. All changes to rate of pay require approval of the employee's department head, and the
    CEO/President or designee.




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EMPLOYMENT CLASSIFICATIONS

It is the intent of Gryphen Specialty Products and Services to clarify the definitions of
employment classifications so that employees may understand their employment status and
benefit eligibility. Placement in any of these classifications does not guarantee employment in
any way.

Under the Fair Labor Standards Act (FLSA), each employee is designated as either non-exempt
or exempt from federal and state wage and hour laws. Nonexempt employees are entitled to
overtime pay under the specific provisions of federal and state laws. Non-exempt employees are
those whose positions do not meet FLSA criteria for exemption and who are paid for hours
worked in excess of 35 hours per week. Exempt employees are excluded from specific
provisions of federal and state wage and hour laws. An employee's exempt or nonexempt
classification may be changed only upon written notification by Gryphen Specialty Products and
Services. In addition to the above classifications, each employee will belong to one other
employment classification:

FULL-TIME
Full-time employees are those who are regularly scheduled to work 35 or more hours per week.
Generally, they are eligible for Gryphen Specialty Products and Service's benefit package,
subject to the terms, conditions, and limitations of each benefit program.

PART-TIME
Part-time employees are those who are regularly scheduled to work less than 35 hours per week.
Regular part-time employees are eligible for some benefits sponsored by Gryphen Specialty
Products and, subject to the terms, conditions, and limitations of each benefit program.

TEMPORARY
Temporary employees include those hired as interim replacements to assist in a specific function
or in the completion of a specific project. Employment beyond any initially stated period does
not in any way imply a change in employment status. Temporary employees retain temporary
status unless and until they are notified, by Gryphen Specialty Products and Services
management, of a change. They are not eligible for any of the Gryphen Specialty Products and
Service's benefit programs. ―On-call‖ staff and Interns are classified as Temporary employees.




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TIME KEEPING

Accurately recording time worked is the responsibility of every non-exempt employee. Time
worked is the time actually spent on a job performing assigned duties. In some cases, employees
may be responsible for accurately documenting time spent on individual jobs or customer
accounts.

Please note that Gryphen Specialty Products and Services does not include time spent on
personal matters or extended breaks when calculating hours worked.

Timekeeping is a legal matter. Altering, falsifying, or tampering with time records or recording
time on another employee's time record will result in disciplinary action, up to and including
termination of employment.

Vacation days, sick days, holidays, and absences for jury duty, funeral leave or military training
must be specifically noted on employee time records on the days on which they occur.

Non-exempt employees will be issued an electronic timecard on their first day of employment.
The employee will be given instructions on usage. Under no circumstances may any employee
possess or use an electronic timecard which does not belong to him or her.

Non-exempt employees will be financially responsible for replacing their card if lost or stolen.
Replacement cards cost $3.

All employees are expected to work their entire shift. Any employee who records a shift ending
time that is later than the time their shift is scheduled to end, without prior authorization, will be
paid only until the time their shift is scheduled to end.

Overtime hours are permitted on an as needed basis, and must be approved in advance by a direct
supervisor. Employees are expected to work necessary overtime when requested to do so, and
non-exempt employees will be paid for time worked in excess of 35 hours per week. Exempt
employees are not entitled to overtime pay.




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TIME CLOCK GUIDELINES FOR NON-EXEMPT EMPLOYEES

INTRODUCTION
Gryphen Specialty Products and Services is transitioning from handwritten time sheets to record
the time worked by non-exempt employees to an electronic time tracking system called Time
Clock Plus. The electronic time tracking system will enable you to more accurately keep track of
your time. It will also allow the company to more efficiently process your time worked and leave
taken for payroll purposes. In order for this system to work to its fullest potential, we are asking
all non-exempt employees to follow the guidelines and policy outlined below. Your cooperation
and compliance with this policy is very much appreciated.

OFFICIAL TIME OF RECORD
The Time Clock Plus electronic time keeping system and associated work records will become
the official basis for recording hours worked for non-exempt employees of Gryphen Specialty
Products and Services (GSPS). Completed and handwritten timesheets will be replaced by
completed time sheets generated by Time Clock Plus (based on the data in the timekeeping
system). From this time forward, handwritten timesheets will be referred to as ―Regular Time
Sheets‖ and electronic timesheets generated by the Time Clock Plus will be referred to as
―Electronic Time Sheets‖.

In order to ensure consistency of treatment of non-exempt employees, the data recorded in the
Time Clock Plus system shall be considered as the ―official‖ record of the workday. Any
disputes over actual hours worked or attendance will be resolved by referring to the Time Clock
Plus records. In order for the electronic timekeeping system to work as intended, all non-exempt
employees must participate.

EMPLOYEE TIME REPORTS
The Fair Labor Standards Act (FLSA) requires that employers keep certain records for
employees, including the specific date and time worked by non-exempt employees. The
electronic timekeeping system is used to record all hours worked and leave taken during the
reporting period for non-exempt personnel.
The automated time reports must reflect all regular and extra duty hours worked for the period
(including personal leave, compensatory time, holidays, etc.). Adjustments to hours and leave
must be posted weekly by the Director of Operations to avoid errors and omissions that may
occur if these adjustments are posted toward the end of the payroll period.

DAILY CLOCK IN/OUT REQUIREMENTS
As a stated job requirement, all non-exempt employees must ―clock in‖ when their scheduled
shift begins and ―clock out‖ at the end of the workday at their place of work. Under certain
conditions (such as trainings at an off-site location, extracurricular events, etc.), the employee
should report time worked to the Site Manager, who will in turn report this time to the Director
of Operations for processing. A ―regular time sheet‖ should be used to record time that is
worked that cannot be recorded via the Time Clock Plus.
Other requirements and guidelines include:
     Employees are expected to clock in and out at their scheduled times.
     Clock in and out times will be rounded to the nearest quarter hour.


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                                                44
      It is prohibited to abuse or take advantage of the time clock rounding, e.g. clocking in at
       8:07a.m. knowing the clock will round back to 8:00a.m. or clocking out at 3:53p.m.
       knowing the clock will round forward to 4:00p.m.
      Employees are to clock out and back in for any time period wherein the employee was
       not conducting work for GSPS. This would include, but is not limited to lunches, if and
       when they were taken outside of the center and not engaged in GSPS related work and/or
       breaks. Due to the nature of some positions, lunch and/or break may be automatically
       deducted.

FALSIFICATION, TAMPERING, AND UNAUTHORIZED VIEWING
Due to the severity of the infractions below, there will be immediate discipline enforced up to
and including termination.
    Any attempt to tamper with timekeeping hardware or software.
    Punching in for an absent or late employee (a.k.a. ―buddy punching‖).
    Anyone interfering with other employees’ use of the Time Clock Plus system.
    Unauthorized viewing of another employee’s ―regular‖ or ―electronic‖ timsheet.
    The Site Manager and the Director of Operations will review the specific details of such
       an infraction (including but not limited to the above infractions) and develop an
       appropriate response.

CLOCK PROBLEMS
If an employee is unable to punch in or out because of a time clock malfunction or accidental
oversight, it is the employee’s responsibility to immediately inform the Site Manager. In this
situation, the Site Manager will be responsible for informing the Director of Operations the
employee’s time will need to be ―manually‖ entered.

HOLIDAYS
All days (Monday through Friday) that are not considered work days are to be termed
―holidays‖. Holiday credit hours do not count toward the overtime limits.

LUNCH & BREAKS
The United States Department of Labor does not require lunch or breaks. GSPS does require any
employee working more than 4 hours in a day to take 2, fifteen minute breaks during their shift.
All non-exempt employees should clock in and out for such breaks at times authorized by the
Site Manager.

UNREPORTED HOURS
Intentional or careless working off the clock is prohibited. Employees are required to clock in
before performing any work. Employees are not permitted to swipe out before actually stopping
work. Forgetting to clock in or out is not a legitimate reason for working off the clock.
Employees that underreport or fail to report hours worked are subject to disciplinary action.
Once an employee has clocked in, he/she is responsible for starting work. Personal matters or
simply not working while clocked in is considered ―riding the clock‖ and could be grounds for
disciplinary action.




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PROCESSING OF ELECTRONIC TIME REPORTS
Any issues and/or manual entries that need to be resolved (e.g. all missed punches or shifts, leave
taken, holidays, etc.) must be reported to the Director of Operations by the close of business on
the Monday following the end of a pay period. Each Site Manager must fax any ―regular‖ time
sheet to the Director of Operations by the close of business on the Monday following the end of a
pay period. To ensure accuracy, Site Managers should provide non-exempt employees the
opportunity to review their electronic timesheet before the payroll due date. Both ―regular time
sheets‖ and ―electronic time sheets‖ should be signed by the Site Manager and employee are
satisfied with the hours reported, he/she should sign the electronic time sheet as well and submit
to the Director of Operations by the close of business on the Monday following the end of a pay
period.

DISPUTES OVER TIME CLOCKED IN OR OUT
To validate the times clocked in and out, the District has mounted the time clock devices within
view of security cameras. If a dispute over a clock in/out time arises (by employee, supervisor,
or other person), the security video footage will be used to resolve the situation. When security
video footage is not available, the dispute will be properly documented by the Supervisor, signed
by both parties, and submitted to the Human Resources department for filing in the employee’s
personnel file. If the employee refuses to sign the documentation, the Supervisor should note this
accordingly in the paperwork and remit to the Human Resources department.

OVERTIME
Overtime should always be authorized in advance by a supervisor. Before authorizing overtime,
the supervisor is responsible for verifying that funds are budgeted and available. Overtime will
be calculated based on the actual hours recorded and credited to the employee as measured by
the Time Clock System (straight time or at time-and-a-half based on workable hours in the
week).

ABSENCES & PTO
If a non-exempt employee is absent their pay shall be docked for the hours missed based on their
hourly rate of pay. PTO must be authorized in advance, unless PTO is being requested for an
illness (See PTO policy).

TIME CLOCK EDITING
The Director of Operations is the only authorized staff allowed to edit time clock punches. The
Director of Operations may designate a Vice President or Director level staff to edit time clock
punches in his/her absence. E-mails or paper correspondence is sufficient authorization.
Time should be reviewed and edited (if needed) on a daily basis.

BONA FIDE VOLUNTEERS
Bona fide volunteers are generally described as individuals who perform hours of service (for a
public agency for civic, charitable or humanitarian reasons) without promise, expectation or
receipt of compensation for services rendered. If these conditions are met, an individual will not
be subject to the FLSA.




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LOST OR MISPLACED TIME CARD (ID BADGE)
The Time Clock Plus devices located in the district buildings are ―swipe‖ based, meaning, your
ID badge can be used to clock in or out. If you have lost or misplaced your ID badge, a
replacement badge costs $5.00 and will be deducted from your next paycheck following the
replacement.

TRAINING
Site Manager will provide training to employees on how to use the Time Clock Plus.

EDIT HOUR REPORTS
The Director of Operations will run Edit Hour reports on a regular basis and review for any
irregularities or patterns. All irregularities and/or patterns will be reviewed with the
Site Manager and/or Director of Programs and all findings shall be reported/investigated
accordingly.

ABSENCES FROM DUTY
Time Clock Plus is an electronic timekeeping system and as such does not remove the need for
employee’s completing a PTO/Absence from Duty Form when away from GSPS. All
PTO/Absence from Duty forms should be submitted to the Site Manager and a copy forwarded
to the Director of Operations with all payroll documentation by the close of business on the
Monday following the end of a pay period, so that any leave (business or personal) edits can be
verified.

ADDING AND REMOVING EMPLOYEES FROM SYSTEM
The Director of Operations will process all additions/removals from the time clock system when
an employee has been recommended for hire, had a change employment status (non-exempt to
exempt), resigned, been terminated, etc. If an employee is unable to clock in on their first day of
employment, please contact the Director of Operations immediately and proper action will be
taken to resolve the issue.

DEFINITIONS
Non-exempt employees are determined by FLSA and they are to include positions such as direct
services providers, job coaches, secretaries, aides, bus drivers, maintenance workers and
managers, cafeteria workers and managers, clerks, etc.
Holidays, absences and PTO are not considered hours worked and will be excluded when
determining the number of hours worked in a workweek.

QUESTIONS
Please communicate any questions you may have to your supervisor prior to contacting the
Director of Operations.




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PAYMENT OF SALARIES FOR EXEMPT EMPLOYEES

Employees in positions that are exempt from the overtime provisions of the Fair Labor Standards
Act are classified as "exempt salaried" employees. They receive a weekly salary regardless of the
number of days or hours worked during the work week, with certain exceptions as defined
herein.

DEDUCTION IN SALARY: Deduction will not be made from an exempt employee's salary
for absences caused by the operating requirements of the business, if the employee is willing,
and able to work. Absences for exempt employees for personal, sick or vacation must be applied
to available PTO. Other employee absences are covered by benefit policies for bereavement, jury
duty and military leave.

PARTIAL DAY ABSENCES: If benefits are insufficient to cover the absence, the employee
will be paid for a full day.

EXCEPTIONS TO PAYMENT OF FULL SALARY: The following exceptions apply in
reference to payment of full salary:

       a. Hiring or Termination: An exempt employee who works less than a full week during
       their first or last week of employment will receive reduced salary for that week, which
       will be prorated based on the number of days worked. For example, an exempt employee
       who works four out of five days during their first or last week of employment will receive
       80 percent of their regular weekly salary for that week.
       b. Leave of Absence: All leaves of absence for exempt employees, with the exception of
       Administrative Leave (as noted below), are unpaid.
       c. Administrative Leave of Absence: An exempt employee may be placed on an
       Administrative Leave of Absence for time necessary to complete an investigation into
       possible misconduct or violation of Gryphen Specialty Products and Services policy,
       procedure or practice. The Administrative Leave will be paid unless at the discretion of
       management, some or all of an Administrative Leave can serve as time spent toward an
       unpaid suspension as a result of an investigation's findings.
       d. Disciplinary Action to be unpaid: Disciplinary suspensions for exempt salaried
       employees must be for one full workweek, beginning on the first day of the work week.
       Full salary will be paid for disciplinary suspensions of partial weeks (if not in full work
       week increments). For example, if an exempt employee's work week begins at 12:00 a.m.
       on Sunday morning, an unpaid disciplinary suspension would need to begin at 12:00 a.m.
       on Sunday morning and end at 11:59 p.m. the following Saturday night. If the suspension
       begins or ends at any other time or on any other days for this employee, it must be paid
       unless the employee is off the entire work week.




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SPECIAL PAY PRACTICES

1. Overtime Compensation Policy: Overtime compensation at the rate of one-and-one-half times
(1 and 1/2X) the employee's "regular rate of pay" will be paid to nonexempt employees under the
following conditions: a. All hours worked in excess of 40 hours per week and not otherwise paid
at time-and-one-half or greater will be included in determining the number of hours worked for
overtime purposes. b. Worked time, such as PTO, jury duty, holiday, bereavement leave and
military leave for annual trainings is not counted as time worked for purposes of determining
overtime pay eligibility.

2. Exempt Employees: Exempt employees under the Fair Labor Standards Act (FLSA), are
exempt from overtime pay, and are therefore not covered by this policy.

3. Authorization for Overtime: All overtime worked by nonexempt employees must be approved
in advance by the employee's supervisor. Overtime hours worked without supervisory approval
may be regarded as violation of policy and therefore subject to corrective action. Supervisors
will not authorize overtime, except in an emergency, without the express written authorization
from their department head.

4. Speaking Engagements, Publications and Consultation: a. Overview Gryphen Specialty
Products and Services encourages employees to share their professional knowledge and expertise
with other members of the developmental disabilities community and related professionals. Such
activities may take the form of speaking engagements, publications, or providing consultation. b.
Approvals (1) Speaking Engagements Require approval by the employee's management. (2)
Publications All drafts for publication that relate directly or indirectly to Gryphen Specialty
Products and Services’ business or operations or that identify the author as a Gryphen Specialty
Products and Services employee must be reviewed and approved by Gryphen Specialty Products
and Services’ CEO/President or designee prior to submission for publication. (3) Consulting
Agreements Requests for consultation must be approved by the employee's management and the
CEO/President of Gryphen Specialty Products and Services prior to accepting any assignment.
(4) Speaking Engagements, Publications and Consulting Assignments Which benefit the
organization may, at the discretion of the approving authority, also include approval for the
requesting employee to devote scheduled work time to the assignment. (a) If approval is granted
to work on the assignment during the employee's scheduled work time, then other support for the
project will also be considered on a case-by-case basis, such as secretarial or clerical support. (b)
Assignments may also be approved with the restriction that the assignment shall be completed on
the employee's own time, PTO time or leave of absence. If the approval is granted with the
restriction that the assignment must be completed on the employee's own time, then additional
support will generally not be provided.

5. Restrictions Speaking engagements, publications or consultations that create an actual or
potential conflict of interest with Gryphen Specialty Products and Services’ interests may not be
accepted or approved, even if the employee offers to do so on his or her own time. a. Employees
may not provide consultation to an actual or potential competitor or vendor of products, supplies
or services to Gryphen Specialty Products and Services. b. Gryphen Specialty Products and
Services’ CEO/President must approve studies involving any employee.



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6. Compensation and Expenses Honorariums, consulting fees or other compensation greater than
$250 received by an employee for speaking engagements, publications or consultations must be
turned over to Gryphen Specialty Products and Services unless the work was done by the
employee on his or her own time, or while on PTO or leave of absence. a. Any expenses
associated with outside assignments will generally not be paid by Gryphen Specialty Products
and Services without prior written approval by the employee's management and the
CEO/President. b. Any expenses paid by Gryphen Specialty Products and Services that are
subsequently reimbursed to the employee by the organization sponsoring the assignment must be
remitted to Gryphen Specialty Products and Services immediately upon receipt.

   8. Travel and Meeting Policy: a. Policy: Gryphen Specialty Products and Services will
      directly pay for or reimburse employees for authorized and reasonable expenses incurred
      while traveling and/or attending meetings on behalf of the company. Employees are
      expected to follow all guidelines and use sound business judgment when incurring these
      expenses. b. Credit Cards: Gryphen Specialty Products and Services may issue credit
      cards to certain employees for their use. Charges incurred on these cards must be of
      business nature. c. Air Travel: (1) First and business class travel are not reimbursed (2)
      Discount fares should be procured whenever possible (3) Reservations should be made as
      far in advance as possible to obtain the lowest fare. Employees are to use the least
      expensive flights available regardless of their personal participation in "frequent flyer
      programs." "Upgrade" coupons may be used only if they do not disqualify the employee
      from obtaining the lower discount fare. (4) Changes to reservations that would incur
      additional charge should be avoided. (5) Additional costs incurred due to personal
      stopovers or detours are the employee's responsibility. d. Personal Vehicles: (1) Gryphen
      Specialty Products and Services will reimburse employees for use of their personal
      vehicles for company business. (2) The rate per mile will be adjusted periodically by
      management. e. Rental Cars: (1) Rental cars should only be used when the employee's
      vehicle, center vehicle or public transportation are not practical alternatives. (2) The car
      size should be the most economical as determined by the requirements of the trip, but in
      no case larger than "Intermediate." (3) All expenses incurred in the operation of this
      rental are reimbursable including gasoline, oil, toll charges, reasonable parking charges
      and other minor expenses to the extent used for business purposes. (4) Gasoline tanks
      should be filled upon return of the vehicle. (5) Collision coverage should be accepted
      since Gryphen Specialty Products and Services’ current insurance policies do not cover
      collision for rental cars. (6) Accidents involving a rental car should be reported
      immediately to the rental agency and the employee's supervisor. The employee's
      supervisor will inform the Director of Operations. f. Lodging: (1) Reservations for hotel
      rooms are confirmed on a guaranteed payment basis regardless of check-in time. This
      ensures the room will be available regardless of when the employee arrives. (2) Shared
      accommodations may be arranged if a group of employees have been brought to one
      location for the same purpose. (3) Suites may not be reserved unless approved by
      Executive Management. (4) If an employee is attending a convention or meeting for
      which group rate rooms have been blocked by the sponsoring organization, these
      accommodations must be used unless a less expensive alternative is available. (5) "No
      Show" charges should be avoided. If the employee's travel plans are changed or canceled,
      the employee should notify the hotel immediately. If a no show charge is incurred due to



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       other than a business necessity or personal emergency, the employee will be personally
       responsible for the charge. (6) Additional costs such as double or family room
       accommodations incurred for accompanying guests or family members are the
       responsibility of the employee and are not reimbursable by Gryphen Specialty Products
       and Services. g. Meals: (1) The actual and reasonable cost of up to three (3) meals a day
       is reimbursable when an employee is traveling on Gryphen Specialty Products and
       Services business. (2) If a group of Gryphen Specialty Products and Services employees
       are dining together while on company business, the senior ranking employee should pay
       the entire bill and claim it on his or her Expense Statement. (3) There will be no
       reimbursement for personal consumption of alcoholic beverages except for approved
       business, entertainment or development purposes. h. Telephone Personal calls to an
       employee's home when traveling are reimbursable but should not be excessive in number
       or length. i. Other Reimbursable Expenses: (1) Excess airline baggage fees for equipment
       and materials required for the trip. (2) Laundry, dry cleaning and valet service if an
       employee is required to be away from home for at least seven consecutive days. (3)
       Postage and other delivery services when required for business purposes. (4) Approved
       registration for seminars, conferences, conventions or meetings. (5) Reasonable tips and
       gratuities. (6) Internet connections for business purposes. j. Examples of Non-
       Reimbursable Expenses (1) Child care or pet boarding. (2) Airline club memberships. (3)
       Grooming expenses such as barber, hair stylist, manicurist or shoeshine. (4) Clothing,
       briefcases, organizers or other personal items other than those purchased to replace
       damaged or lost items during travel. (5) Fines for parking, speeding or other traffic
       violations. (6) Personal entertainment expenses such as theatre tickets, hotel in-room
       movies or sporting events unless part of a group activity specifically authorized by
       Executive Management. (7) Health facility fees, sauna or massages. (8) Spouse or other
       family travel. (9) Travel insurance (Gryphen Specialty Products and Services provides
       Travel & Accident insurance for employees.) (10) Personal reading materials.

8. Attendance at Lectures, Meetings and Trainings Sessions: Attendance at lectures, meetings,
training sessions and similar activities for nonexempt employees is counted as working time
unless all of the following apply: a. Attendance is outside of the employee's regular work hours.
b. Attendance is, in fact, voluntary. c. The course, lecture or meeting is not directly related to the
employee's job. d. The employee does not perform any productive work during such attendance.
*Training designed to help a nonexempt employee handle his/her job more effectively is directly
related to his/her job. However, time spent in training that, although it incidentally improves the
employee's skill at his/her regular work, is primarily intended to prepare him/her for another job
or to give the employee a new skill not directly related to an employee's job and, thus, can be
excluded from hours worked. Example: The time an employee spends voluntarily pursuing
continuing education such as a degree program at a university is not counted as time worked and
is not compensable. e. Attendance must be counted as time worked for nonexempt employees if
attendance is required by the company or if the employee is led to believe that his/her
employment would be adversely affected by non-attendance. Such attendance will also count as
time worked for purposes of overtime determination.




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EXPENSE REIMBURSEMENT

Legitimate expenses tendered while on Gryphen Specialty Product and Services’ business will be
documented on an Expense Reimbursement Form, presented to the appropriate supervisor for
approval.

Employees MUST be granted prior approval before incurring any company expenses.
Reimbursement under $250 will be included in the employee's next regular paycheck. If the
reimbursement amount is in excess of $250, the expense report or request for reimbursement will
be processed as an invoice. All completed reimbursement request forms should be submitted in a
timely manner to Director of Operations.




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MILEAGE REIMBURSEMENT

Approved use of a personal vehicle for Gryphen Specialty Product and Services business
purposes will be reimbursed at the current Gryphen Specialty Product and Services’ mileage rate.
Such mileage must be documented and submitted to the Director of Operations on the Expense
Reimbursement Form.




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DEDUCTIONS

TAX DEDUCTIONS: Deductions to comply with federal and state regulations will
automatically be made from each employee's paycheck. This includes federal and state
withholding for income and other taxes. Any changes in the employee's withholding must be
reported to the Director of Operations. The employee will be supplied with the necessary forms
to change records.


SOCIAL SECURITY AND MEDICARE: Gryphen Specialty Products and Services
withholds income tax from all employees' earnings and participates in social security and
Medicare withholding and matching programs as outlined in the Federal Income Insurance
Contribution Act (FICA).

Old Age and Survivors' Insurance, commonly referred to as social security, became effective
January 1, 1937, and provides benefits for employees after they retire or otherwise qualify under
the provisions of the Act. The plan is designed to protect the future security of employees and
their dependents.

In accordance with FICA, a required percentage of each employee's salary is deducted from their
paycheck; the company matches employees' deductions dollar for dollar.

Employees are encouraged to contact their local Social Security office to find out more about
their Social Security benefits, including a record of your past wages that were subject to Social
Security taxes.

BENEFIT DEDUCTIONS: If an employee is eligible and has chosen to accept all or part of
the benefits package offered (e.g. health insurance, life insurance, etc.) related deductions will be
made from the employee’s paycheck. The entire amount for the first month’s premiums will be
deducted from the employee’s paycheck issued on the closest payday preceding the employees
first day of eligibility for benefits. Subsequent deductions for monthly premiums will be divided
between two paychecks during each calendar month. On those months where three paychecks
are issued during the calendar month, only two paychecks will be subject to deductions for
benefits.

GARNISHMENT AND WAGE ATTACHMENTS: Garnishments or wage attachments will
be deducted from an employee's paycheck in accordance with applicable law. Whenever possible
the employee will be informed of the deduction by his/her supervisor before it becomes effective
with the next paycheck. It is each employee's responsibility to inform Gryphen Specialty
Products and Services and provide withholding forms subject to child support garnishment
locally or elsewhere.

EMPLOYEE AUTHORIZED DEDUCTIONS: Payroll deductions may be authorized by the
employee for required and/or authorized withholdings. Written authorization is necessary in
order to initiate, change or terminate these deductions.




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PAYDAYS

Gryphen Specialty Products and Services employees are paid on a biweekly basis. As required
by law, Gryphen Specialty Products and Services will deduct Federal Social Security and Income
Tax from your paycheck each pay period. Applicable group insurance premiums for eligible
employee and dependent family members will also be deducted each pay period, upon
completion of appropriate authorization forms.

Gryphen Specialty Products and Services encourages its employees to take advantage of Direct
Deposit of biweekly pay; this service saves time and provides added security. With Direct
Deposit, each paycheck will be automatically deposited to employees' checking or savings
account per their instruction. Each payday, employees will receive a pay stub for their records.

For the purposes of calculating employee benefits and pay periods, the workweek is considered
Monday at 12:00 a.m. through Sunday at 11:59 p.m. Employees are paid by check or direct
deposit every other Friday or 26 times per year. In the event that a scheduled payday falls on a
day when Gryphen Specialty Products and Services is officially closed, employees will be paid
on the last day of work before the regularly scheduled payday. If a regular payday falls during
an employee's vacation, the employee's paycheck will be available upon his/her return from
vacation.

An employee's paycheck will not, under any circumstances, be given to any person other than
that employee without appropriate written authorization. Paychecks may also be mailed to the
employee's listed address upon request.




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WAGE AND SALARY INCREASES

Each employee's hourly wage or annual salary will be reviewed at least annually. The employee
review date is generally on, or about, the anniversary of employment or date of the previous
review. Such reviews may be conducted more frequently under some circumstances (i.e. for a
newly created position or following a recent promotion).

Any wage or salary increase will be determined on the basis of performance, attendance,
Gryphen Specialty Products and Services established salary matrix. For more information on
performance appraisals, employees may refer to the Gryphen Specialty Products and Services
Performance Evaluations policy in this handbook.




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BENEFIT INFORMATION




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               57
HEALTH INSURANCE

Gryphen Specialty Products and Services makes health insurance coverage available to all full-
time employees, and their eligible dependents. Gryphen Specialty Products and Services pays
50% of the premiums for the group benefits and the employee shares the balance of the cost.
Single and family plans and/or additional enhanced plans may have different contribution rates.

The low cost of these benefits to employees is an important part of each eligible employee's
compensation package.

To be eligible for Gryphen Specialty Products and Services health insurance coverage an
employee must be an employee, and have performed 3 months of continuous service.
Management positions are eligible for health insurance benefits on their hire date. Eligible
employees may elect to begin health insurance benefits on the first day of the month following
the completion of the introductory period.

Specific details on coverage and benefits may be found in the Summary Plan Description (SPD)
for the health plan. Employees may contact the Director of Operations for more information on
health insurance benefits.




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DENTAL INSURANCE

Gryphen Specialty Products and Services makes dental insurance coverage available to all
employees and their eligible dependents. The low cost of these benefits to employees is an
important part of each eligible employee's compensation package.

To be eligible for Gryphen Specialty Products and Services dental insurance coverage an
employee must be an employee, and have performed 3 months of continuous service.
Management positions are eligible for dental insurance benefits on their hire date. Eligible
employees may elect to begin dental insurance benefits on the first day of the month following
the completion of the introductory period.

Specific details on coverage and benefits may be found in the Summary Plan Description (SPD)
for the health plan. Employees may contact the Director of Operations for more information on
dental insurance benefits.




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VISION INSURANCE

Gryphen Specialty Products and Services makes vision insurance coverage available to all
employees and their eligible dependents. The low cost of these benefits to employees is an
important part of each eligible employee's compensation package.

To be eligible for Gryphen Specialty Products and Services vision insurance coverage an
employee must be an employee, and have performed 3 months of continuous service.
Management positions are eligible for vision insurance benefits on their hire date. Eligible
employees may elect to begin vision insurance benefits on the first day of the month following
the completion of the introductory period.

Specific details on coverage and benefits may be found in the Summary Plan Description (SPD)
for the health plan. Employees may contact the Director of Operations for more information on
vision insurance benefits.




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LIFE INSURANCE

An important facet of your benefits at Gryphen Specialty Products and Services is your life
insurance. In keeping with the company's benefits philosophy you are offered life insurance
coverage.

To be eligible for Gryphen Specialty Products and Services life insurance coverage an employee
must be an employee, and have performed 3 months of continuous service. Management
positions are eligible for life insurance benefits on their hire date. Your life insurance will be
payable to your beneficiary upon proof of your death from any cause while you are insured. You
may request a change in beneficiary at any time.

This is just an outline of Gryphen Specialty Products and Services life insurance policy. It is not
intended to give you each and every detail of the plan, but rather to provide you the highlights of
the plan in an easy-to-understand format. For additional details on the Company's specific life
insurance plan, contact the Director of Operations for a complete explanation of the plan's
coverage.




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QUALIFYING EVENTS FOR CHANGES TO BENEFITS

Once enrolled, employees may change their election under this program only if a qualified event,
as listed below, occurs and they submit completed enrollment/ change form within 31 calendar
days of the qualified event. A supply of enrollment and qualified event change forms are
maintained by CEO/President or designee. Qualified events for these programs include the
following:

       (1). Change in legal marital status: Marriage, divorce, legal separation, annulment and
       death of a spouse.
       (2). Change in the number of dependents: Birth, adoption, legal guardianship, death of a
       dependent and ineligibility due to age and/or student status.
       (3). Change in work schedule: Increase or decrease in hours worked by employee, spouse
       or dependent.
       (4). Change in employment status: Change in status of employment that results in
       employee, spouse or dependent becoming eligible or ineligible for medical benefits
       coverage, such as commencement or termination from employment, return from leave of
       absence, etc.
       (5). Significant cost or coverage charges: Significant change to the cost and/or coverage
       made to the benefit plan of the employee, spouse or dependent.
       (6). Entitlement to Medicare or Medicaid (applies only to Premium Only Plan)
       (7). Employee, spouse or dependent becomes qualified to enroll in Medicare or Medicaid.




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COBRA

The Consolidated Omnibus Budget Reconciliation Act (COBRA) provides eligible employees
and their qualified beneficiaries the opportunity to continue coverage under group health plans
when a "qualifying event" would normally result in a loss of coverage. Under these
circumstances, the employee will be offered group rates but is responsible for the full cost of the
monthly premium.

Some common qualifying events are: resignation; termination of employment; death of an
employee; a reduction in an employee's hours; leave of absence; divorce or legal separation; or a
dependent child no longer meeting eligibility requirements.

It may be possible to convert other group plans to individual plans. Conversion of benefits will
be discussed at the time of termination. Employees may consult Director of Operations at any
time for more information on continuation of benefits.

Under COBRA, the employee or beneficiary pays the full cost of coverage at Gryphen Specialty
Products and Service's group rates plus an administration fee. Gryphen Specialty Products and
Services will provide each eligible employee with a written notice describing rights and
obligations under COBRA upon eligibility.

NOTIFICATION REQUIREMENTS:
The employee, or family member, has the responsibility to inform the Plan Administrator of a
divorce, legal separation, or a child losing dependent status within 60 days of the event. Gryphen
Specialty Products and Services has the responsibility to notify the Plan Administrator of the
employee's death, termination of employment, or reduction in hours.

Once the notification has been made to the Plan Administrator, the Plan Administrator will
inform the employee that he or she has the right to chose continuation of coverage. If employees
choose to continue coverage, Gryphen Specialty Products and Services is required to provide
coverage which is identical to the coverage provided under the plan to similarly situated
employees or family members.

An employee's continuation of coverage may be cut short for any of the following reasons:
Gryphen Specialty Products and Services no longer provides group health coverage to any of its
employees; the premium for your continuation coverage is not paid; you become covered under
another group health plan that does not contain any exclusion or limitation with respect to any
pre-existing condition; you become entitled to Medicare; or you are no longer disabled.

SUBSIDIZED PREMIUMS
Employees involuntarily terminated between September 1, 2008 and May 31, 2010 are eligible
for a 65% government subsidy for 15 of the 18 months they are eligible for COBRA coverage.
Eligible employees would therefore be responsible for paying 35% of their health insurance
premiums.




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For purposes of receiving subsidy payments, an involuntarily terminated individual is one who is
terminated for reasons other than gross misconduct. It does not include employees who choose to
leave the company voluntarily. A qualifying event of involuntary termination is the only
circumstance in which employees are eligible to receive a subsidy for their COBRA payments.
Questions regarding subsidized COBRA payments should be directed to the Director of
Operations.




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WORKER’S COMPENSATION

Employees who are injured on the job at Gryphen Specialty Products and Services are eligible
for Workers' Compensation benefits. Such benefits are provided at no cost to employees and
cover any injury or illness sustained in the course of employment that requires medical
treatment.

Employees who sustain work-related injuries or illnesses must notify their supervisor
immediately so that Gryphen Specialty Products and Services can notify the workers'
compensation insurance carrier as soon as possible.

Lost time or medical expenses incurred as a result of an accident or injury which occurred while
an employee was on the job will be compensated for in accordance with workers' compensation
laws. This protection is paid for in full by Gryphen Specialty Products and Services. No
premium is charged for this coverage and no individual enrollment is required. Gryphen
Specialty Products and Services will provide medical care and a portion of lost wages through
our insurance carrier.

All job-related accidents or illnesses must be reported to an employee's supervisor immediately
upon occurrence. Supervisors will then immediately contact the Director of Operations to obtain
the required claim forms and instructions. Failure to report an accident or resulting injury may
jeopardize the injured employee's receipt of Worker's Compensation benefits. Prompt reports
may also help prevent a similar accident in the future.
Employees who qualify for Worker's Compensation may supplement their Worker's
Compensation income replacement benefits with PTO hours the employee has already accrued
and which are available to bring them to their regularly scheduled hours. PTO would need to be
used in whole hour increments.




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ATTENDANCE




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ATTENDANCE AND PUNCTUALITY

Employees are expected to arrive at work prior to their scheduled start times so that they may
begin work at their scheduled start times. All time off must be requested in writing, in advance,
as outlined in the Gryphen Specialty Products and Services Paid Time Off (PTO) policy.

Gryphen Specialty Products and Services considers excellent attendance to be the foundation of
great performance and, as such, attendance is assessed during performance appraisals. All
unapproved absences will be documented in employee personnel files. Excessive absence will
result in disciplinary action, up to and including termination.

Absenteeism and tardiness place an undue burden on other employees and on the company itself;
Gryphen Specialty Products and Services expects regular attendance and punctuality from all
employees.

Employees unable to report for work for any reason must notify as early as possible, but always
before their scheduled start time. Employees are responsible for notifying their supervisor
directly of absence or tardiness. It is not acceptable to leave a message on a supervisor's voice
mail, except in extreme emergencies. In the case of leaving a voice-mail message, a follow-up
call must be made later that day.

Should occurrences of absence or tardiness become regular or excessive, disciplinary action may
be taken, up to and including termination of employment.

Requests for special work hours will be considered on a case-by-case basis, depending on both
the needs of the employee and of Gryphen Specialty Products and Services.




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PAID TIME OFF (PTO)

Paid Time Off (PTO) is an all-purpose time off policy for eligible employees to use for vacation,
illness, injury, or personal business. PTO combines traditional vacation and sick leave plans into
one flexible, inclusive policy. PTO is payable in the same manner as the regular salary and is
subject to the same withholding elections.

Employees in the following employment classification(s) are eligible to earn and use PTO as
described in this policy:

      Full-time employees (i.e. employees hired to work 35 hours or more)

Employees must successfully complete 90 days of service before using PTO; employees may
then request use of PTO accrued during the 90 day period. Upon entering an eligible
employment classification, employees will begin to earn PTO according to the following
schedule:

      After 1 year of service, employees are eligible for 5 PTO days
      After 3 years of service, employees are eligible for 10 PTO days
      After 7 years of service, employees are eligible for 15 PTO days
      After 10 years of service, employees are eligible for 20 PTO days

In the event that available PTO is not used by the end of the benefit year, employees will forfeit
any unused PTO.

PTO may be used in minimum increments of one-half day. Employees with an unexpected need
(i.e. sudden illness or emergency) to request PTO should notify their direct supervisor as early as
possible. Employees must also contact their direct supervisor on each additional day of absence.

Any employee that is absent from work and using PTO for any period longer than 3 days must
provide a doctor's notice, certifying the nature of the illness and verifying the employee's fitness
to return to work.

Paid Time Off (PTO) cannot be used by any employee (e.g. non-exempt, exempt, etc.) on any of
the holidays listed in the GSPS ―Holidays Policy‖.

No employee is permitted to be gainfully employed in any capacity while using PTO. Any
employee found to be doing so will be considered to have voluntarily resigned without notice.
Any such employee will not be considered in good standing at the time of resignation.
Furthermore, any employee who does not report to work and fails to notify Gryphen Specialty
Products and Services of his or her status for a period of 2 consecutive days will be assumed to
have resigned.

Employees eligible for retirement from Gryphen Specialty Products and Services will not be paid
for accrued and unused PTO if the number of days is greater than days.



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Work-related accidents and illness are covered by Workers' Compensation Insurance, pursuant to
the requirements of the laws in the state(s) in which Gryphen Specialty Products and Services
operates. The PTO policy outlined above does not apply to those illnesses or injuries that are
covered by an applicable Workers' Compensation policy.




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FAMILY AND MEDICAL LEAVE ACT (FMLA)

Family and Medical Leave Policy: Gryphen Specialty Products and Services recognizes that
medical and family needs can require employees take time off from work. To comply with the
federal Family and Medical Leave Act and similar state laws, Gryphen Specialty Products and
Services offers the following leave provisions for employees needing time to attend to medical or
family members.

To be eligible for family and medical leave, employees must have worked for the company at
least 12 months. In addition, employees must have worked as least 1,250 hours during the past
twelve months.

1. Amount of Leave Employees can take up to 12 weeks of leave during any 12-month period.
Leave can be taken all at once or, if required by a medical condition, on an intermittent basis. To
accommodate an intermittent leave schedule, Gryphen Specialty Products and Services and the
employee can agree to a modified work schedule, flexible work hours or days, or temporary
transfer to another position.

An employee who otherwise satisfies the eligibility requirements for leave under FMLA and
who is the spouse, son, daughter, parent, or next of kin (nearest blood relative) of a member of
the Armed Forces with a serious injury or illness that was incurred while on active duty may take
up to 26 weeks of leave during a single 12-month period to care for the service member.

During a single 12-month period, an employee is entitled to a combined Total of 26 weeks to
provide care to an injured service member and any other leave taken under the FMLA.

2. Uses of Leave - An employee can take family and medical leave for: a. The birth of an
employee's child. b. The placement of a child in adoptive or foster care with the employee. c.
The serious health condition of a spouse, child or parent that requires the employee to attend to
the relative's basic needs. d. The employee's own serious health condition that interferes with his
or her ability to perform job duties. e. Any qualifying exigency arising from an employee's
spouse, child or parent who is on active duty or who has been notified of an impending call or
order to active duty to a contingency operation. (A qualifying exigency could be arranging child
care, seeing a service member off at the airport, welcoming service member home, pre-
deployment activities, etc.) f. The serious injury or illness incurred by a spouse, child, parent or
next of kin while on active duty in the Armed Forces that may render the service member
medically unfit to perform the duties of the member's office, rank or rating and require the
employee to provide care to the service member. A covered "service member" is defined as a
member of the Armed Forces, who, as a result of a serious injury or illness is undergoing
medical treatment, recuperation or therapy, is in an outpatient status or is on the temporary
disability retired list due to an injury or illness incurred in the line of duty.

3. Married Co-Workers: When an employee and his or her spouse both work for Gryphen
Specialty Products and Services, their combined time off for birth, adoption, foster care, or care
for an ill parent cannot exceed 12 weeks during any 12-month period. However, each spouse can
take 12 weeks leave for his or her own health condition or to care for an ill child or the other
spouse.


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When an employee and his or her spouse both work for Gryphen Specialty Products and
Services, their combined time off cannot exceed 26 weeks to care for an injured service member
during a 12-month period. The 26 weeks may be taken on an intermittent basis. To accommodate
an intermittent leave schedule, Gryphen Specialty Products and Services and the employee can
agree to a modified work schedule, flexible work hours or day, or temporary transfer to another
position.

4. Pay Provisions: Family and medical leave can be paid or unpaid, depending on the conditions
for which the leave is needed and the employee's accrued PTO and short-term disability leave
entitlement.

5. Use of PTO and Short-Term Disability Leave Employees who take family and medical leave
for their own serious health condition must use their entitlement to PTO and short-term disability
benefits to receive pay during their absence.

If the condition is due to a work-related injury or illness, an employee might be entitled to
receive Worker's Compensation benefits during the leave period. In either situation, Gryphen
Specialty Products and Services requires the paid leave and family/medical leave periods to run
concurrently; for example, an employee cannot use four weeks of PTO and then take another 12
weeks of family and medical leave during a 12-month period.

If an employee has exhausted his or her short-term disability or the condition does not qualify for
coverage by short-term disability or Worker's Compensation benefits, the employee must use
accrued PTO leave during the family and medical leave period. If all paid leave has been
exhausted the family and medical leave is unpaid.

6. Notice and Certification: Employees requesting family or medical leave must give 30 days
notice of their need for such leave. When emergencies make 30 days notice impossible,
employees must inform Gryphen Specialty Products and Services as soon as they become aware
of the need for leave. In either case, employees should complete a Request for Family Medical
Leave form and submit it to their supervisor.

When a serious health condition necessitates leave, Gryphen Specialty Products and Services
requires certification from a health care provider. This certification must state: a. The date on
which the condition began or became serious enough to merit leave. b. The likely duration of the
condition. c. The diagnosis and other appropriate medical facts about the condition. d. If the
employee is taking leave to care for a relative's serious health condition, the medical certification
also must contain: (1) A statement verifying that the relative requires the employee's care. (2) An
estimate of how long the relative will require care from the employee. (3) During leave,
employees must keep their supervisor informed of the estimated duration of leave and their intent
to return from leave.

When requesting a leave for a qualifying exigency, Gryphen Specialty Products and Services
requires the employee to provide a certification related to Active Duty or Call to Active Duty for
the affected spouse, child or parent.




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When an employee needs to care for an injured service member who is a spouse, child, parent or
next of kin, Gryphen Specialty Products and Services requires a certification issued by the health
care provider of the service member being cared for by the employee.

7. Health Benefits During Leave: While on family and medical leave, employees are entitled to
continued coverage under the company's health care plan. However, employees are required to
pay their share of the group health premiums during their leave. Employees should contact
CEO/President or designee to arrange for payment of their share of the group health premiums
during leave.

If an employee fails to return from leave, Gryphen Specialty Products and Services reserves the
right to require the employee to reimburse the company for its share of premiums during the
leave. However, reimbursement is not required when an employee fails to return from leave due
to legitimate medical reasons or other circumstances beyond his or her control.

8. Return from Leave: An employee returning from family and medical leave is entitled to his or
her former position or one with equivalent pay, benefits and other employment terms and
conditions.

Employees returning from family and medical leave retain all benefits accrued prior to the start
of the leave and unused during the leave. Any changes in benefit levels, plans, or terms
implemented during an employee's absence automatically apply to the employee upon his/her
return to active work. An employee's leave does not count as a break in service. Employees do
not accrue additional PTO leave benefits while on family and medical leave that are not covered
by available PTO hours, and any paid leave benefits used during the employee's family and
medical leave will be deducted from the employee's entitlement.




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PERSONAL LEAVE OF ABSENCE

Personal Leave of Absence Eligibility for an unpaid personal leave of absence will be
determined in the sole discretion of management on a case-by-case basis. In general, an unpaid
personal leave of absence will not be granted for more than six (6) weeks. Employees may
request a personal leave only after having completed six months of service with Gryphen
Specialty Products and Services. All accrued PTO must be used by the employee prior to the
effective date of the personal leave of absence.

       1. Employees must request a personal leave of absence in writing, stating the reason for
       the leave, the intention to return to work, and the estimated date of return. Additional
       information and/or details regarding the request may be required by management.

       2. Benefits based on paid hours do not accrue while an employee is on a personal leave of
       absence pursuant to this policy. An employee may continue group insurance at his/her
       own expense.

       3. Gryphen Specialty Products and Services cannot guarantee that the employee's
       position will be available upon return from a personal leave of absence. If business needs
       require that Gryphen Specialty Products and Services fill the employee's position while
       he/she is on leave, efforts will be made to reinstate the employee to an appropriate
       available position. If an employee fails to return to work at the conclusion of a personal
       leave, or an appropriate position cannot be found within a reasonable period of time,
       employment will be terminated unless otherwise required by law.




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BEREAVEMENT LEAVE

Gryphen Specialty Products and Service's bereavement leave policy allows (3) days time off to
all employees for a death in the immediate family. Immediate family includes spouse,
significant other, children, mother, father, brother, sister, father-in-law, mother-in-law,
grandparents, and grandchildren.

Employees in the following employment classification(s) are eligible for (3) paid bereavement
leave:

      Exempt Full Time Employees

You may request up to an additional (2) days, which must be approved by your immediate
supervisor and Gryphen Specialty Products and Services management. If accrued PTO is
available, it may be used for the additional 2 days; otherwise, the additional two days will be
unpaid.

Bereavement leave for a death outside of an employee's immediate family must be approved by
his or her immediate supervisor and the department head.




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ADMINISTRATIVE LEAVE

An Administrative leave is a leave of absence implemented at the discretion of management for
up to 30 consecutive calendar days to address specific business needs (e.g., to remove an
employee from the work setting while management investigates alleged misconduct, etc.). An
Administrative leave may be paid or unpaid depending on the circumstances necessitating the
leave.




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JURY DUTY

Gryphen Specialty Products and Services encourages employees to fulfill their civic
responsibilities by serving jury duty when required. Employees must provide an immediate
supervisor with a copy of their jury summons as soon as possible so that the supervisor may
make arrangements to accommodate their absence.

Employees are required to report to work as permitted by the court schedule. If you are released
from jury duty with at least four (4) hours remaining in your work day, you should return to
work for the remainder of the day. Either Gryphen Specialty Products and Services or the
employee may request an excuse from jury duty if it is determined that the employee's absence
would create serious operational difficulties.

Benefit accruals such as vacation, sick leave, or holiday benefits will be suspended during jury
duty leave and will resume upon return to active employment.




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MILITARY LEAVE

Gryphen Specialty Products and Services proudly grants employees time off of work for military
service. All employees requesting time off for military service must provide a copy of their
report orders to their immediate supervisor as early as possible.

Under the Uniformed Services Employment and Reemployment Rights Act (USERRA),
employees on military leave from employment are subject to the following conditions: no break
in employment is considered to have occurred; no benefits will be forfeited; and no re-
qualification for participation in a pension plan is necessary.

Length of service continues to accrue during military leaves of absence. If active employment is
not re-established, length of service is calculated with respect to the last day worked.

Health Coverage During Leave: During an unpaid military leave of absence, Gryphen Specialty
Products and Services continues to subsidize an employee's group health care benefits for up to
30 days.
Employees on military leave for 31 days or longer are eligible for family health benefit coverage
from the military. They can also arrange to continue their own coverage under Gryphen
Specialty Products and Services’ group health plan for up to 24 months. Employees opting for
continued coverage under Gryphen Specialty Products and Services’ health plan are responsible
for 102% of the premium cost.
Impact of Leave on Other Benefits: Employees on military leave do not accrue PTO. However,
the time off counts toward an employee's length of service in determining the rate at which
employees accrue PTO, pay and other benefits after returning from military leave.

In accordance with USERRA, employees are eligible for re-employment for up to five (5) years
from the date their military leave began. A leave of absence for long-term active duty guarantees
re-employment if the employee applies for re-employment within 90 days of their release from
active duty. Employees who qualify will return to active employment at a pay level and status
equal to that which they would have attained had they not entered military service.

Questions regarding this policy should be directed to the Director of Operations.




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HOLIDAYS

Gryphen Specialty Products and Services observes the holidays below and will grant time off to
all employees on the holidays listed below:

      New Year's Day
      Memorial Day
      Independence Day
      Labor Day
      Thanksgiving Day
      Christmas Day

A recognized holiday that falls on a Saturday may be observed on the preceding Friday.

A recognized holiday that falls on a Sunday may be observed on the following Monday.

Non-exempt employees are not paid for time off on the holidays listed above.

Paid Time Off (PTO) cannot be used by any employee (e.g. non-exempt, exempt, etc.) on any of
the holidays listed above. If a recognized holiday occurs during an exempt employee's paid
absence from work (e.g. during scheduled vacation), holiday pay will be provided instead of the
Paid Time Off benefit that would otherwise apply.

Paid holiday time off will not be factored in as hours for the purposes of determining overtime.




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EMERGENCY CLOSURE

On occasion, emergency situations - such as severe weather, power failure, or natural disaster -
may disrupt company operations. The decision to close or delay regular operations will be made
by Gryphen Specialty Products and Services. If a decision is made to close or delay regular
operations, employees will receive notification from a representative of Gryphen Specialty
Products and Services who holds a Director level position or higher.

Time off from scheduled work due to emergency closings will be unpaid for all non-exempt
employees. However, if employees wish to use paid time off (PTO), they may be permitted to do
so, if eligible.




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STANDARDS OF CONDUCT




             Page
              80
STANDARDS OF CONDUCT

Workplace rules and standards of conduct observed by Gryphen Specialty Products and Services
are essential to a healthful and productive workplace. All employees are urged to familiarize
themselves with these rules and standards, as they will be held accountable for upholding them.
Please be aware that any employee who disregards, or deviates, from any of these rules or
standards will be subject to disciplinary action, up to and including termination of employment.

While not intended to be an all inclusive list, the examples below represent behavior that is
considered unacceptable in the workplace. Behaviors such as these, as well as other misconduct,
may result in disciplinary action, up to and including termination of employment.

      Theft or inappropriate removal/possession of property
      Falsification of timekeeping records
      Working under the influence of alcohol or illicit drugs
      Possession, distribution, sale, transfer, or use of alcohol or illicit drugs in the workplace
      Fighting or threatening violence in the workplace
      Boisterous or disruptive activity in the workplace
      Negligence or improper conduct leading to damage of company-owned or customer-
       owned property
      Insubordination or other disrespectful conduct
      Violation of safety or health rules
      Smoking in the workplace
      Sexual or other unlawful or unwelcome harassment
      Excessive absenteeism or any absence without notice
      Unauthorized use of telephones, computers, or other company-owned equipment
      Use of company equipment for purposes other than business
      Unauthorized disclosure of any confidential information




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CODE OF ETHICS

Code of Ethics and Conflict of Interest: Individuals who represent Gryphen Specialty Products
and Services, including employees, volunteers and others are expected to conduct themselves in
a responsible, professional and ethical fashion. Gryphen Specialty Products and Services’
reputation and its ability to fulfill its mission are built upon the ethical conduct and integrity of
its employees and volunteers. As such, certain standards of conduct are necessary for the
efficient operation of Gryphen Specialty Products and Services and the benefit and safety of all
employees, clients and families.

1. Gryphen Specialty Products and Services’ Core Values Understanding Gryphen Specialty
Products and Services’ core values will provide a clear sense of the foundation on which its
ethical expectations are built.

       (a) Act with respect, compassion and a sense of urgency.

       (b) Nurture families, respecting their diversity, rights and the individuality of their
       children.

       (c) Maintain the highest levels of integrity in everything we do.

       (d) Uphold the highest ethical standards.

       (e) Promote cooperation, collaboration and teamwork.

       (f) Be accountable to donors, families, peers and fellow research partners.

       (g) Commit to build, test and model best practices.

       (h) Serve as an international leader in quality research; and (i) Support individuals with
       developmental disabilities throughout their lifetime.

2. Policy - All employees, volunteers and others who represent Gryphen Specialty Products and
Services in delivering services and in all other Gryphen Specialty Products and Services
activities are required to maintain the highest standards of ethics, integrity and professional
conduct. Gryphen Specialty Products and Services does not have an all-encompassing list of
standards and rules. Instead, conduct and actions are evaluated with regard to whether they
satisfy the broad requirements stated above and are in the best interest of the organization and
those whom are served by it.

Many situations are unclear, and whenever doubt exists regarding application of this policy,
employees/volunteers should consult with their manager or CEO/President or designee. For
illustration purposes, and not intended to be all inclusive, the following are offered to provide
clarification of Gryphen Specialty Products and Services’ expectations regarding ethical and
professional conduct.

Employees, volunteers and others associated with Gryphen Specialty Products and Services are
expected to;


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       (a) Conduct themselves in an honest, professional and ethical manner in all matters
       whenever they are representing Gryphen Specialty Products and Services, thus meriting
       the trust, confidence and respect of clients, communities and the industries we serve.

       (b) Comply with all applicable laws, regulations and ethical business and research
       practices.

       (c) Safeguard and foster the rights and interests of clients and others served by the
       organization.

       (d) Not accept gifts, entertainment or benefits from current, former or potential vendors
       or others doing business with Gryphen Specialty Products and Services that may create or
       appear to influence the recipient or Gryphen Specialty Products and Services.

       This does not include matters of nominal value that are customary and proper under the
       circumstances and in the normal course of business and which do not place or appear to
       place the recipient under an obligation to the provider. Generally, gifts with a value of
       less than $100 will be considered nominal; however, each situation is subject to
       management evaluation and determination based on its unique circumstances.

       (e) Avoid any situation which involves an actual or the appearance of a conflict between
       their personal interest and the interest of Gryphen Specialty Products and Services, such
       as, but not limited to financial interest in a competitor, vendor or client of Gryphen
       Specialty Products and Services, or any other arrangement or circumstance, including
       family or other personal relationships, which might influence the individual from acting
       in the best interest of Gryphen Specialty Products and Services and those whom it serves.

       (f) Individuals shall disclose any potential conflicts of interest to Gryphen Specialty
       Products and Services’ CEO/President upon becoming aware of such issue and, where
       appropriate, will absent him/herself during deliberations and shall refrain from
       participating in any decisions or voting in connection with the matter.

       (g) Avoid disclosing any confidential or otherwise proprietary information or materials to
       any person not authorized to receive such information, or using such information or
       materials to the detriment of Gryphen Specialty Products and Services or those whom are
       served by the organization.

       (h) Avoid using affiliation with Gryphen Specialty Products and Services in connection
       with the promotion of partisan politics, religious matters or advocating for a position on
       any issue that does not conform with Gryphen Specialty Products and Services’ official
       position on this matter.

3. Outside Employment Employees are required to obtain written approval from their supervisor
before participating in outside work activities. Approval will be granted unless the activity
conflicts with Gryphen Specialty Products and Services’ interest. In general, outside work
activities are not allowed when they:




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       (a) Prevent the employee from fully performing work for which he or she was hired at
       Gryphen Specialty Products and Services including overtime assignments.

       (b) Involve providing a service Gryphen Specialty Products and Services currently offers
       or plans to offer in the future.

       (c) Involve organizations that are doing or seek to do business with Gryphen Specialty
       Products and Services, including actual or potential vendors or customers.

       (d) Violate provisions of the law or Gryphen Specialty Products and Services’ core
       values, policies or rules.

4. Compliance - Anyone who becomes aware of a violation of this policy must report it
immediately to their manager; if reporting a violation to their manager is not possible, they
should report it to CEO/President or designee or to Gryphen Specialty Products and Services
CEO/President. Violations of this policy will result in corrective action up to and including
termination of employment. In all cases, Gryphen Specialty Products and Services has the right
to determine the appropriate level of corrective action to be applied.




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NONDISCLOSURE AND CONFIDENTIALITY

Gryphen Specialty Products and Services requires all employees to sign a confidentiality
agreement as a condition of employment due to employees' potential access to information that is
confidential and/or intended for company use only. All employees are required to maintain such
information in strict confidence. This policy benefits employees by protecting the interests of
Gryphen Specialty Products and Services and protecting confidential, unique and valuable
information from competitors or others.

Should an occasion arise in which an employee is unsure of his or her obligations under this
policy, he or she must consult Director of Operations. Failure to comply with this policy could
result in disciplinary action, up to and including termination of employment.

The protection of confidential business information and trade secrets is vital to the success of
Gryphen Specialty Products and Services. Such confidential information includes, but is not
limited to, the following examples:

      Any material developed using company resources and/or time
      Compensation data
      Computer processes
      Computer programs and codes
      Conversations between any persons associated with the company
      Customer lists
      Customer preferences
      Financial information
      Labor relations strategies
      Marketing strategies
      New materials research
      Pending projects and proposals
      Proprietary production processes
      Personnel/payroll records
      Research and development strategies
      Technological data
      Technological prototypes

Employees who improperly use or disclose any type of confidential business information will be
subject to disciplinary action and/or legal action, even if they do not personally benefit from the
disclosure of such information.




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SEXUAL AND OTHER UNLAWFUL HARASSMENT

Gryphen Specialty Products and Services will not, under any circumstances, condone, tolerate, or
allow conduct which may constitute sexual harassment on the part of its management,
supervisors or non-management employees. It is our policy that all employees have the right to
work in an environment free from unlawful harassment of any kind.

Any employee found to be engaged in any form of sexual harassment may be subject to
disciplinary action, up to and including termination of employment.

Sexual harassment may be defined as:

   1. Conditioning employment upon employee's submission to unwelcome sexual advances or
      requests for sexual favors;
   2. Basing an employment decision upon an employee's submission or rejection of
      unwelcome sexual advances, requests for sexual favors or verbal or physical conduct of a
      sexual nature; or
   3. Creating an intimidating, hostile or offensive working environment or atmosphere
      through:
          a. verbal conduct, including calling employees by terms of endearment; using
             vulgar, kidding or demeaning language; or
          b. physical actions which may offend or interfere with an employee's work
             performance.

We at Gryphen Specialty Products and Services encourage healthy fraternization among
employees; however, employees - especially those in management and supervisory roles - must
be sensitive to acts of conduct which may be considered offensive by other employees and must
refrain from engaging in or permitting such conduct.

It is expressly prohibited for any employee to retaliate against another employee(s) who brings
sexual harassment charges or assists in investigating charges. Any form of retaliation is
considered a direct violation of this policy and may result in disciplinary action, up to and
including termination of employment. No employee will be discriminated against, or discharged,
for incurring or assisting in the investigation of a complaint of sexual harassment.

Gryphen Specialty Products and Services is committed to providing a work environment that is
free of all types of discrimination and unlawful harassment. Actions, words, jokes, comments, or
any other conduct related to one's sex, race, ethnicity, age, religion, or any other legally protected
characteristic will not be tolerated.

Any employees who believe that they, or any other employee, have been the victim of
harassment are expected to report it immediately. Employees may raise concerns and make
reports without fear of reprisal.




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Any supervisor who becomes aware of possible harassment should promptly advise Gryphen
Specialty Products and Services management and Director of Operations, who will handle the
matter in a timely and confidential manner.




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HARASSMENT INVESTIGATION POLICY

In accordance with all applicable laws, GSPS prohibits sexual harassment and harassment
because of race, color, national origin, ancestry, religion, creed, physical or mental disability,
marital status, age, or any other basis protected by federal, state or local law. All such harassment
is unlawful and will not be tolerated. GSPS is committed to taking all reasonable steps to prevent
harassment from occurring.

Procedure:

   1. Decide upon the order in which investigation interviews will be conducted.
          o Complainant
          o Alleged harasser
          o Coworkers and other witnesses
          o Supervisors of the complainant and alleged harasser
          o Second interview with the alleged harasser to discuss any factual questions as a
              result of the investigation
   2. Interview each witness separately in an office or room where the discussion will not be
      overheard by other witnesses, the alleged harasser, or any other unauthorized persons.
   3. Two uninvolved managers should participate in the interview process. At least one of the
      investigating managers should be thoroughly familiar with harassment law and the
      Company's harassment policies and procedures. One manager should be designated as the
      interviewer, and the other should act primarily as a witness and take notes of the
      discussion.
   4. Before beginning the interview, explain the purpose of the interview by referring
      generally to recent complaints about the relationship between the complainant and the
      alleged harasser. Do not necessarily discuss the issue of unlawful harassment, so that you
      do not taint the witness' recollection of the events.
          o Emphasize that the Company takes these charges very seriously and that the
              Company is investigating these charges by interviewing all potential witnesses in
              compliance with Company policy.
          o Explain that upon completion of the investigation, the Company will attempt to
              determine what occurred, and will take appropriate action based on its
              determination.
          o Both the complainant and the alleged harasser should be advised that each will be
              apprised of the results of the investigation and any action taken.
          o Instruct each witness interviewed not to discuss the matters covered during the
              interview with any coemployee or the alleged harasser.
          o Explain to the witness that confidentiality is necessary to protect the integrity of
              the investigation and to ensure that the Company receives trustworthy information
              in an atmosphere free from coercion.
          o Explain to the witness that Company policy prohibits retaliation against anyone
              who complains of harassment or participates in an investigation, and that any acts
              of retaliation should be reported immediately.
   5. During the interviews:
          o Avoid leading questions.



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       o   Ask open ended, nonjudgmental questions. Use investigation interview forms
           where appropriate.
        o Explain to all witnesses that retaliation will not be tolerated.
        o Avoid the appearance of impropriety or favoritism in conducting interviews.
        o Observe and record all physical and verbal reactions of witnesses.
        o Do not record conclusions regarding credibility.
        o Avoid judgmental statements or furthering of myths or stereotypes.
        o Explore the effect of alleged harassment on the complainant and any others
           affected (i.e., psychological, emotional, physical and financial).
6. Review the complainant's and the alleged harasser's personnel files.
7. Discuss investigation results and proposed action with the investigation team. This
    discussion should be limited to those with a need to know the results of the investigation,
    such as the complainant's supervisor, the alleged harasser's supervisor, and senior Human
    Resources department staff.
8. Consider credibility determinations. Factors include memory, perception, truthfulness,
    corroboration or lack of it, bias of witnesses, consistency, plausibility of accounts and
    prior misconduct.
9. Review all evidence collected.
10. Make a decision.
11. Consider appropriate remedial action: consider a verbal warning, written warning, denial
    of bonus or pay raise, suspension, demotion, termination or some combination. Also
    consider providing harassment training to the harasser and to all employees.
12. Consider the following factors in determining the appropriate remedial action:
        o credibility of the complainant, alleged harasser and other witnesses;
        o prior conduct, if any (e.g., the alleged harasser);
        o prior discipline of the alleged harasser;
        o level of harassment, including the type and frequency of conduct;
        o alleged harasser's knowledge of company rules of conduct;
        o prior disciplinary "precedent" for identical, similar or analogous misconduct; and
        o public and employee relations issues.
13. Review the harassment investigation and findings.
        o Was the company harassment policy adequate?
        o Were the employees aware of the terms of the harassment policy?
        o Was the harassment complaint procedure adequate?
        o Did the investigator uncover other issues which need to be addressed?
14. Implement changes to the harassment policies and procedures where appropriate.




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REPORTING ABUSE AND NEGLECT

Reporting Suspected Child Abuse and Dependent Adult Abuse: Any Gryphen Specialty Product
and Services’ employee, volunteer or independent contractor who reasonably believes that a
child (i.e. minor) or dependent adult (i.e., adult cared for by a legally appointed guardian) has
been the victim of physical injury, abuse, child abuse, a reportable offense, or neglect that
appears to have been inflicted on the minor by other than accidental means or that is not
explained by the available medical history as being accidental in nature must report such
information.

Likewise, anyone who reasonably believes that there has been a denial or deprivation of
necessary medical treatment, surgical care or nourishment with the intent to cause or allow the
death of an infant must immediately report this information. Such information shall be reported
to Gryphen Specialty Product and Services’ CEO/President, and to a peace officer and/ or to
Child Protective Services or Adult Protective Services in the Department of Economic Security.
Except if the report concerns a person who does not have care, custody or control of the minor,
the report shall be made to the peace officer only. This means any individual Gryphen Specialty
Product and Services staff is required by law to report if there is a reasonable concern.
Additional reporting of health and safety incidents (i.e., child abuse, adult abuse, etc.) to the
Division of Developmental Disabilities may also be required by appropriate staff.




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WORKPLACE VIOLENCE

Gryphen Specialty Products and Services, strictly prohibits workplace violence, including any
act of intimidation, harassment, violence, verbal abuse, aggression or coercion. Prohibited
actions, include, but are not limited to the following examples:

      Physically injuring another person
      Threatening to injure another person
      Engaging in behavior that subjects another person to emotion distress
      Possessing or using a weapon while on company premises
      Intentionally damaging property

Violence, threats, harassment, intimidation, and other disruptive behavior in our workplace will
not be tolerated. All reports of incidents will be taken seriously and will be dealt with promptly
and appropriately. Due to the sensitivity of the issue, all threats or acts of violence should be
reported immediately to the local Police Department so that trained professionals can
appropriately take care of the situation. Individuals who commit such acts may be removed from
the premises and may be subject to disciplinary action, civil action and/or criminal penalties.
Employees found to have engaged in violence will be subject to immediate termination.

Employee cooperation is needed to implement this policy effectively and maintain a safe
working environment. Do not ignore violent, threatening, harassing, intimidating, or other
disruptive behavior. If you observe or experience such behavior by anyone on Gryphen Specialty
Products and Services premises, whether or not he or she is a Gryphen Specialty Products and
Services employee, report it immediately to a member of management.

Any member of management who receive such reports should seek advice from CEO/President
or designee regarding investigating the incident and initiating appropriate action.




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DRUG AND ALCOHOL ABUSE

Gryphen Specialty Products and Services considers drug and alcohol abuse a very serious
problem, and is committed to maintaining a work place free of substance abuse. This policy
applies to all employees of Gryphen Specialty Products and Services without exception,
including part-time and temporary employees.

No employee is allowed to consume, possess, sell, or purchase any alcoholic beverage on any
property owned by or leased on behalf of Gryphen Specialty Products and, or in any vehicle
owned or leased on behalf of Gryphen Specialty Products and Services. No employee may use,
possess, sell, transfer or purchase any drug or other controlled substance which may alter an
individual's mental or physical capacity in any way. Exceptions are aspirin or ibuprofen based
products, as well as legal drugs which have been prescribed to that employee and are being used
in the manner prescribed.

Gryphen Specialty Products and Services will not tolerate employees who report for duty while
impaired by use of alcohol or drugs.

All employees should report evidence of alcohol or drug abuse to their supervisor or Director of
Programs immediately. In cases in which the use of alcohol or drugs creates an imminent threat
to the safety of persons or property, employees are required by Gryphen Specialty Products and
Services to report the violation. Failure to do so may result in disciplinary action.

Employees found in violation of Gryphen Specialty Products and Service's Drug and Alcohol
Abuse Policy will be subject to disciplinary action, up to and including termination. It is our
policy at Gryphen Specialty Products and Services to assist employees and family members who
suffer from drug or alcohol abuse. Employees may be eligible for a leave of absence, are
encouraged to contact for details.

As a part of our effort to maintain a workplace free of substance abuse, Gryphen Specialty
Products and Services employees may be asked to submit to a medical examination and/or
clinically testing for the presence of alcohol and/or drugs. Within the limits of state and federal
laws, we reserve the right to examine and test for drugs and alcohol at our discretion. Such
situations may include, but are not limited to, the following:

      The screening of all employees being considered for employment with Gryphen Specialty
       Products and Services.
      Cases in which there are reasonable grounds for believing an employee is under the
       influence of alcohol or drugs.
      As part of an investigation of any accident in the workplace in which there are reasonable
       grounds to suspect alcohol and/or drugs were involved.
      On a random basis, where allowed by statute.
      As a follow-up to a rehabilitation program, where allowed by statute.
      As deemed necessary to maintain the safety of employees, customers, clients or the
       public at large, where allowed by statute.




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      When an employee returns to duty following an absence other than that resulting from
       accrued time off, such as vacation or sick leave.

As a condition of your employment with Gryphen Specialty Products and Services, employees
must comply with the Drug and Alcohol Abuse Policy. Be advised that no part of the Drug and
Alcohol Abuse Policy shall be construed to alter or amend the at-will employment relationship
between Gryphen Specialty Products and Services and its employees.




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SMOKING

Gryphen Specialty Products and Services strives to provide a healthy environment and therefore
prohibits smoking and tobacco use in company buildings.

The use of tobacco products is not permitted anywhere on the Gryphen Specialty Products and
Services premises except in authorized locations. Employees may smoke in designated areas and
must follow all rules posted in such areas.




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GIFT POLICY

GSPS gift policy is a no-gift policy. To avoid a conflict of interest, the appearance of a conflict
of interest, or the need for our employees to examine the ethics of acceptance, GSPS and its
employees do not accept gifts from vendors, suppliers, customers, potential employees, potential
vendors or suppliers, or any other individual or organization, under any circumstances.
GSPS code of conduct requires that all employees demonstrate our organization’s commitment
to treating all people and organizations, with whom we come into contact or conduct business,
impartially. GSPS employees demonstrate the highest standards of ethics and conduct.
Employees practice and demonstrate equal treatment, unbiased professionalism, and non-
discriminatory actions in relation to all vendors, suppliers, customers, employees, potential
employees, potential vendors or suppliers, and any other individual or organization.
Company Gift Policy (or No-Gift Policy) Standards and Requirements
As one effort to demonstrate our commitment to these standards and behavior, all employees
must abide by the following no-gift policy requirements.

      No gifts of any kind, that are offered by vendors, suppliers, customers, potential
       employees, potential vendors and suppliers, or any other individual or organization, no
       matter the value, will be accepted by any employee, at any time, on or off the work
       premises. By ―gift,‖ your company means any item including pens, hats, t-shirts, mugs,
       calendars, bags, key chains, portfolios, and other tschotskes as well as items of greater
       value.
      This ―no-gift‖ policy includes vendor or potential vendor or supplier-provided food,
       beverages, meals, or entertainment such as sporting events.
      This "no-gift" policy includes any business courtesy offered such as a product discount or
       any other benefit if the benefit is not extended to all employees.

GIFT POLICY EXCEPTIONS:

      Exempted from this policy are gifts such as t-shirts, pens, trade show bags and all other
       ―tschotskes‖ that employees obtain, as members of the public, at events such as
       conferences, training events, seminars, and trade shows, that are offered equally to all
       members of the public attending the event. This includes attendance at and food,
       beverages, and ―tschotskes‖ provided at events, exhibitor trade show floor locations,
       press events, and parties funded by conference or event sponsors.
      Exempted are cards, thank you notes, certificates, or other written forms of thanks and
       recognition.

      Exempted are foods, beverages, and moderately priced meals or tickets to local events
       that are supplied by and also attended by current customers, partners, and vendors or
       suppliers in the interest of building positive business relationships. This moderately
       priced entertainment is provided as part of a ―working‖ meeting or session to benefit and
       advance positive working relationships and company interests. These activities are
       expected to be reciprocated by our company in turn.




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                                                95
Employees are required to professionally inform vendors, potential vendors and others of this no-
gift policy, and the reasons the company has adopted the policy. Employees will request that
vendors respect our company policy and not purchase and deliver any gift for our employees, a
department, an office or the company, at any time, for any reason.
If an employee or department receives a gift:


      If feasible, the gift is returned to the vendor.
      If not feasible to return the gift, the gift must be raffled off to all employees. Proceeds
       from the raffle will be donated to a charity that the philanthropy committee has identified
       for the calendar year. If employees are uninterested in the raffled item, the gift will be
       donated to a designated charity.
      Plants or flowers will be displayed in the lobby, or at another central location where all
       employees may enjoy their presence.
      Gifts of food that may arrive during the holidays, and at other times of the year when gift
       giving is traditional, belong to the entire staff even if addressed to a single employee.
      Under no circumstances may an employee take a food gift home; food gifts must be
       shared with and distributed to all staff, with email notice, during work hours, in central,
       worksite locations.

This policy is supplemental to other company codes of conduct, ethics, standards, values, and
policies in the employee handbook and in all other company documents.
If any employee has questions about and / or needs clarification of any aspect of this policy, the
employee should check with their supervisor. If the supervisor is uncertain, the CEO/President or
designee is the arbiter of the gift policy to ensure consistent employee treatment across the
company. Any exceptions to the gift policy may be made only with the permission of the
CEO/President.




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VISITORS IN THE WORKPLACE

To ensure the safety and security of employees, visitors, and property of Gryphen Specialty
Products and Services, only authorized visitors are allowed in the workplace. Restricting
unauthorized visitors protects our staff, decreases possible liabilities, safeguards confidential
information, and helps to avoid potential distractions and disturbances.

All visitors must enter through the main reception area, sign in and out at the reception desk and
obtain a "Visitor" badge to wear while on Gryphen Specialty Products and Services premises.
Authorized visitors will be escorted to their destination and must be accompanied by an
employee of Gryphen Specialty Products and Services at all times.




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PERSONAL APPEARANCE AND DRESS CODE

Employees of Gryphen Specialty Products and Services are to present a clean and professional
appearance at all times when representing the company. Management, sales personnel and those
employees who have regular contact with our clients and the public are expected to dress in
accepted corporate attire. Employees should always be well groomed and observe high standards
of personal hygiene.

GSPS's objective in establishing a casual dress code is to allow our employees to work
comfortably. Yet, we still need our employees to project a professional image for our customers
and clients who visit.

Because all casual clothing is not suitable for the workplace, these guidelines will help you
determine what is appropriate. Clothing that works well for the beach, yard work, dance clubs,
exercise sessions, and sports contests may not be appropriate for a professional appearance at
work. Sun dresses, casual capris, dance club dresses, and midriff bearing tops are examples of
clothing not appropriate in a manufacturing work setting or office.

Clothing that reveals excessive cleavage, back, chest, feet, stomach or undergarments is not
appropriate for a business setting. Even in a casual work environment, clothing should be
pressed and never wrinkled. Torn, dirty, or frayed clothing is unacceptable. All seams must be
finished. Any clothing that has words, terms, or pictures that may be offensive to other
employees is unacceptable. This includes images that are political or religious in nature, are
sexually provocative, use profanity or are insulting of other employees.

Clothing that has the GSPS logo is encouraged. Sports team, university, and fashion brand names
on clothing are generally acceptable. Use common sense when wearing clothing that has words
on it; people are easily offended by words.

The following is a general list of what is and is not appropriate for work attire. Neither list is all-
inclusive and both lists are open to change. No dress code can cover all contingencies so
employees must exercise a certain amount of judgment in their choice of clothing to wear to
work. If you experience uncertainty about acceptable, professional casual attire for work, please
ask your supervisor.

Following are the specific expectations of the casual dress code for work. This dress code
differentiates between program areas and office areas in the dress code.

SLACKS, PANTS, AND SUIT PANTS
Program areas:
Slacks or pants that are similar to Dockers and other makers of cotton or synthetic material pants,
wool pants, flannel pants, jeans, bib overalls, and nice looking athletic pants are acceptable.
Gauchos and capris are acceptable. Pants that are below the knee with finished edges are
allowed.




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                                                  98
Inappropriate slacks or pants in the plant include sweatpants, exercise pants, Bermuda shorts,
short shorts, shorts, leggings, and any spandex or other form-fitting pants such as people wear for
biking. As a general rule, shorts or pants that are above knee length are not allowed.

Office areas:
Slacks that are similar to Dockers and other makers of cotton or synthetic material pants, wool
pants, flannel pants, and nice looking dress synthetic pants are acceptable. Dressier gauchos and
capris are acceptable in the office. Pants that are below the knee with finished edges are allowed.
Inappropriate slacks or pants include jeans (except on dress down days), sweatpants, exercise
pants, Bermuda shorts, short shorts, shorts, bib overalls, leggings, and any spandex or other
form-fitting pants such as people wear for biking. As a general rule, shorts or pants that are
above knee length are not allowed.

SKIRTS, DRESSES, AND SKIRTED SUITS
Casual dresses and skirts, and skirts that are split at or below the knee are acceptable, or skirts at
a length at which you can sit comfortably in public are acceptable.
As a general rule, dresses and skirts that are above knee length and that do not allow bending are
not appropriate. Short, tight skirts that ride halfway up the thigh are inappropriate for work.
Mini-skirts, skorts, sun dresses, beach dresses, bathing suit cover-ups, and spaghetti-strap dresses
are inappropriate.

SHIRTS, TOPS, BLOUSES, AND JACKETS

Program areas:
Casual shirts, dress shirts, sweaters, tops, golf-type shirts, t-shirts, sweatshirts, nice looking
athletic tops, and turtlenecks are acceptable attire for work.
Inappropriate attire for work includes tank tops; midriff baring tops; shirts with potentially
offensive words, terms, logos, pictures, cartoons, or slogans; halter-tops; and tops with bare
shoulders.

Office areas:
Casual shirts, dress shirts, sweaters, tops, golf-type shirts, t-shirts, sweatshirts, nice looking
athletic tops, and turtlenecks are acceptable attire for work.
Inappropriate attire includes tank tops; midriff baring tops; shirts with potentially offensive
words, terms, logos, pictures, cartoons, or slogans; halter-tops; and tops with bare shoulders.

SHOES AND FOOTWEAR

Program areas:
Loafers, boots, dress heels below 2 inches high, athletic shoes, and leather deck shoes, as
examples, are acceptable. Thongs, flip-flops, clogs, slippers, sandals, and any shoes with an open
toe or open heel are not acceptable in the plant.
Office areas:
Conservative athletic or walking shoes, loafers, clogs, sneakers, boots, flats, dress heels, and
leather deck-type shoes are acceptable for work. Wearing no stockings is acceptable in warm
weather. Flashy athletic shoes, thongs, flip-flops, slippers, and any shoe with an open toe are not



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acceptable in the office. Closed toe and closed heel shoes are required in the manufacturing
operation area.

GENERAL GUIDELINE:
Closed toe and closed heel shoes are required for safety reasons in the program area. Shoes that
enclose only part of the heel or toe are not acceptable in the program area. For safety reasons,
heels over two inches high are not acceptable in the program area.
Shoes with a closed toe are required in the office.

JEWELRY, MAKEUP, PERFUME, AND COLOGNE
Should be in good taste, with limited visible body piercing. Remember, that some employees are
allergic to the chemicals in perfumes and make-up, so wear these substances with restraint.

HATS AND HEAD COVERING
Hats are not appropriate at work. Head Covers that are required for religious purposes or to
honor cultural tradition are allowed.

CONCLUSION
If clothing fails to meet these standards, as determined by the employee’s supervisor, the
employee will be asked not to wear the inappropriate item to work again. If the problem persists,
or is especially inappropriate, unprofessional, and/or offensive, the employee may be sent home
to change clothes and will receive a verbal warning for the first offense. All other policies about
personal time use will apply. Progressive disciplinary action will be applied if dress code
violations continue.
Please wear clothing and accessories that will project a professional image of you and the
company for both visitors and coworkers. Wear:
      Attire that is clean, safe, and in good repair.
      Clothes that are not sexually provocative.
      Clothing that does not draw undue attention to one’s self or create a distraction for other
        employees.
      Clothing that will not be offensive to other employees.




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CELL PHONE USAGE


This policy about cellular phone usage applies to any device that makes or receives phone calls,
leaves messages, sends text messages, surfs the Internet, or downloads and allows for the reading
of and responding to email whether the device is company-supplied or personally owned.

COMPANY OWNED AND SUPPLIED DEVICES OR VEHICLES
An employee who uses a company-supplied device or a company-supplied vehicle is prohibited
from using a cell phone, hands on or hands off, or similar device while driving, whether the
business conducted is personal or company-related. This prohibition includes receiving or
placing calls, text messaging, surfing the Internet, receiving or responding to email, checking for
phone messages, or any other purpose related to your employment; the business; our customers;
our vendors; volunteer activities, meetings, or civic responsibilities performed for or attended in
the name of the company; or any other company or personally related activities not named here
while driving. Use of company owned vehicles or devices for personal business is discouraged.

CELL PHONES OR SIMILAR DEVICES AT WORK
GSPS is aware that employees utilize their personal or company-supplied cellular phones for
business purposes. At the same time, cell phones are a distraction in the workplace. To ensure
the effectiveness of meetings, employees are asked to leave cell phones at their desk. Or, on the
unusual occasion of an emergency or anticipated emergency that requires immediate attention,
the cell phone may be carried to the meeting on vibrate mode.




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EMAIL ETIQUETTE POLICY

GSPS implements etiquette rules for the following three reasons:

      Professionalism: by using proper email language your company will convey a
       professional image.
      Efficiency: emails that get to the point are much more effective than poorly worded
       emails.
      Protection from liability: employee awareness of email risks will protect your company
       from costly law suits.

WHAT ARE THE ETIQUETTE RULES?
There are many etiquette guides and many different etiquette rules. Some rules will differ
according to the context of the email. Below is a list of 32 of the most important email etiquette
rules that apply to nearly any situation.
32 most important email etiquette tips:

   1. Be concise and to the point.
      Do not make an e-mail longer than it needs to be. Remember that reading an e-mail is
      harder than reading printed communications and a long e-mail can be very discouraging
      to read.
   2. Answer all questions, and pre-empt further questions.
      An email reply must answer all questions, and pre-empt further questions – If you do not
      answer all the questions in the original email, you will receive further e-mails regarding
      the unanswered questions, which will not only waste your time and your customer’s time
      but also cause considerable frustration. Moreover, if you are able to pre-empt relevant
      questions, your customer will be grateful and impressed with your efficient and
      thoughtful customer service. Imagine for instance that a customer sends you an email
      asking which credit cards you accept. Instead of just listing the credit card types, you can
      guess that their next question will be about how they can order, so you also include some
      order information and a URL to your order page. Customers will definitely appreciate
      this.
   3. Use proper spelling, grammar & punctuation.
      This is not only important because improper spelling, grammar and punctuation give a
      bad impression of your company, it is also important for conveying the message properly.
      E-mails with no full stops or commas are difficult to read and can sometimes even
      change the meaning of the text. And, if your program has a spell checking option, why
      not use it?
   4. Make it personal.
      Not only should the e-mail be personally addressed, it should also include personal i.e.
      customized content. For this reason auto replies are usually not very effective. However,
      templates can be used effectively in this way, see next tip.
   5. Use templates for frequently used responses.
      Some questions you get over and over again, such as directions to your office or how to
      subscribe to your newsletter. Save these texts as response templates and paste these into



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    your message when you need them. You can save your templates in a Word document, or
    use pre-formatted emails.
6. Answer swiftly.
    Customers send an e-mail because they wish to receive a quick response. If they did not
    want a quick response they would send a letter or a fax. Therefore, each e-mail should be
    replied to within at least 24 hours, and preferably within the same working day. If the
    email is complicated, just send an email back saying that you have received it and that
    you will get back to them. This will put the customer's mind at rest and usually customers
    will then be very patient!
7. Do not attach unnecessary files.
    By sending large attachments you can annoy customers and even bring down their e-mail
    system. Wherever possible try to compress attachments and only send attachments when
    they are productive. Moreover, you need to have a good virus scanner in place since your
    customers will not be very happy if you send them documents full of viruses!
8. Use proper structure & layout.
    Since reading from a screen is more difficult than reading from paper, the structure and
    lay out is very important for e-mail messages. Use short paragraphs and blank lines
    between each paragraph. When making points, number them or mark each point as
    separate to keep the overview.
9. Do not overuse the high priority option.
    We all know the story of the boy who cried wolf. If you overuse the high priority option,
    it will lose its function when you really need it. Moreover, even if a mail has high
    priority, your message will come across as slightly aggressive if you flag it as 'high
    priority'.
10. Do not write in CAPITALS.
    IF YOU WRITE IN CAPITALS IT SEEMS AS IF YOU ARE SHOUTING. This can be
    highly annoying and might trigger an unwanted response in the form of a flame mail.
    Therefore, try not to send any email text in capitals.
11. Don't leave out the message thread.
    When you reply to an email, you must include the original mail in your reply, in other
    words click 'Reply', instead of 'New Mail'. Some people say that you must remove the
    previous message since this has already been sent and is therefore unnecessary. However,
    I could not agree less. If you receive many emails you obviously cannot remember each
    individual email. This means that a 'threadless email' will not provide enough information
    and you will have to spend a frustratingly long time to find out the context of the email in
    order to deal with it. Leaving the thread might take a fraction longer in download time,
    but it will save the recipient much more time and frustration in looking for the related
    emails in their inbox!
12. Address the content of the email to the person listed in To:
    When sending an email to ask a question, make sure to direct the question to a particular
    individual. Most often instead of using the CC: tool, email writers send the email to
    everyone they believe should know what is going on or that the question is being asked
    but intend to direct it to one particular individual. For example, a site manager may send
    a request for vehicle maintenance to the Director of Operations, but also sends the email
    to the Director of Programs. The site manager understands that the Director of
    Operations is responsible for processing all vehicle maintenance requests, but he wants to



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    make sure the Director of Programs knows he is making the request and keep him/her up
    to date regarding the overall condition and/or maintenance patterns of the site’s vehicles.
    Therefore, according to this rule, the site manager should send the email ―To:‖ the
    Director of Operations and ―CC:‖ the Director of Programs so that the Director of
    Programs understands that he/she does not have to respond to the email. When sending
    an email with multiple questions to a group of individuals, rather than sending multiple
    emails to each individual in the group, the content of the email should be separated and
    addressed to the individual that it pertains to. This also means that the email should
    include all individuals addressed specifically within the body of the email in the ―To:‖
    line.
13. Read the email before you send it.
    A lot of people don't bother to read an email before they send it out, as can be seen from
    the many spelling and grammar mistakes contained in emails. Apart from this, reading
    your email through the eyes of the recipient will help you send a more effective message
    and avoid misunderstandings and inappropriate comments.
14. Do not overuse Reply to All.
    Only use Reply to All if you really need your message to be seen by each person who
    received the original message.
15. Mailings > use the Bcc: field or do a mail merge.
    When sending an email mailing, some people place all the email addresses in the To:
    field. There are two drawbacks to this practice: (1) the recipient knows that you have sent
    the same message to a large number of recipients, and (2) you are publicizing someone
    else's email address without their permission. One way to get round this is to place all
    addresses in the Bcc: field. However, the recipient will only see the address from the To:
    field in their email, so if this was empty, the To: field will be blank and this might look
    like spamming. You could include the mailing list email address in the To: field, or even
    better, if you have Microsoft Outlook and Word you can do a mail merge and create one
    message for each recipient. A mail merge also allows you to use fields in the message so
    that you can for instance address each recipient personally. For more information on how
    to do a Word mail merge, consult the Help in Word.
16. Take care with abbreviations and emoticons.
    In business emails, try not to use abbreviations such as BTW (by the way) and LOL
    (laugh out loud). The recipient might not be aware of the meanings of the abbreviations
    and in business emails these are generally not appropriate. The same goes for emoticons,
    such as the smiley :-). If you are not sure whether your recipient knows what it means, it
    is better not to use it.
17. Be careful with formatting.
    Remember that when you use formatting in your emails, the sender might not be able to
    view formatting, or might see different fonts than you had intended. When using colors,
    use a color that is easy to read on the background.
18. Take care with rich text and HTML messages.
    Be aware that when you send an email in rich text or HTML format, the sender might
    only be able to receive plain text emails. If this is the case, the recipient will receive your
    message as a .txt attachment. Most email clients however, including Microsoft Outlook,
    are able to receive HTML and rich text messages.
19. Do not forward chain letters.



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    Do not forward chain letters. We can safely say that all of them are hoaxes. Just delete
    the letters as soon as you receive them.
20. Do not request delivery and read receipts
    This will almost always annoy your recipient before he or she has even read your
    message. Besides, it usually does not work anyway since the recipient could have
    blocked that function, or his/her software might not support it, so what is the use of using
    it? If you want to know whether an email was received it is better to ask the recipient to
    let you know if it was received.
21. Do not ask to recall a message.
    Biggest chances are that your message has already been delivered and read. A recall
    request would look very silly in that case wouldn't it? It is better just to send an email to
    say that you have made a mistake. This will look much more honest than trying to recall a
    message.
22. Do not copy a message or attachment without permission.
    Do not copy a message or attachment belonging to another user without permission of the
    originator. If you do not ask permission first, you might be infringing on copyright laws.
23. Do not use email to discuss confidential information.
    Sending an email is like sending a postcard. If you don't want your email to be displayed
    on a bulletin board, don't send it. Moreover, never make any libelous, sexist or racially
    discriminating comments in emails, even if they are meant to be a joke.
24. Use a meaningful subject.
    Try to use a subject that is meaningful to the recipient as well as yourself. For instance,
    when you send an email to a company requesting information about a product, it is better
    to mention the actual name of the product, e.g. 'Product A information' than to just say
    'product information' or the company's name in the subject.
25. Use active instead of passive.
    Try to use the active voice of a verb wherever possible. For instance, 'We will process
    your order today', sounds better than 'Your order will be processed today'. The first
    sounds more personal, whereas the latter, especially when used frequently, sounds
    unnecessarily formal.
26. Avoid using URGENT and IMPORTANT.
    Even more so than the high-priority option, you must at all times try to avoid these types
    of words in an email or subject line. Only use this if it is a really, really urgent or
    important message.
27. Avoid long sentences.
    Try to keep your sentences to a maximum of 15-20 words. Email is meant to be a quick
    medium and requires a different kind of writing than letters. Also take care not to send
    emails that are too long. If a person receives an email that looks like a dissertation,
    chances are that they will not even attempt to read it!
28. Don't send or forward emails containing libelous, defamatory, offensive, racist or
    obscene remarks.
    By sending or even just forwarding one libelous, or offensive remark in an email, you
    and your company can face court cases resulting in multi-million dollar penalties.
29. Don't forward virus hoaxes and chain letters.
    If you receive an email message warning you of a new unstoppable virus that will
    immediately delete everything from your computer, this is most probably a hoax. By



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    forwarding hoaxes you use valuable bandwidth and sometimes virus hoaxes contain
    viruses themselves, by attaching a so-called file that will stop the dangerous virus. The
    same goes for chain letters that promise incredible riches or ask your help for a charitable
    cause. Even if the content seems to be bona fide, the senders are usually not. Since it is
    impossible to find out whether a chain letter is real or not, the best place for it is the
    recycle bin.
30. Keep your language gender neutral.
    In this day and age, avoid using sexist language such as: 'The user should add a signature
    by configuring his email program'. Apart from using he/she, you can also use the neutral
    gender: ''The user should add a signature by configuring the email program'.
31. Don't reply to spam.
    By replying to spam or by unsubscribing, you are confirming that your email address is
    'live'. Confirming this will only generate even more spam. Therefore, just hit the delete
    button or use email software to remove spam automatically.
32. Use cc: field sparingly.
    Try not to use the cc: field unless the recipient in the cc: field knows why they are
    receiving a copy of the message. Using the cc: field can be confusing since the recipients
    might not know who is supposed to act on the message. Also, when responding to a cc:
    message, should you include the other recipient in the cc: field as well? This will depend
    on the situation. In general, do not include the person in the cc: field unless you have a
    particular reason for wanting this person to see your response. Again, make sure that this
    person will know why they are receiving a copy.




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BLOGGING AND SOCIAL MEDIA POLICY

GSPS recognizes the importance of the Internet in shaping public thinking about GSPS our
current and potential products, employees, partners, and customers. GSPS also recognizes the
importance of our employees joining in and helping shape industry conversation and direction
through blogging and interaction in social media. So, GSPS is committed to supporting your
right to interact knowledgeably and socially in the blogosphere and on the Internet through
blogging and interaction in social media.

Consequently, these guidelines in this blogging and social media policy will help you make
appropriate decisions about your work-related blogging and the contents of your blogs, personal
Web sites, postings on wikis and other interactive sites, postings on video or picture sharing
sites, or in the comments that you make online on blogs, elsewhere on the public Internet, and in
responding to comments from posters either publicly or via email. Our internal internet and
email policies remains in effect in our workplace.

These guidelines will help you open up a respectful, knowledgeable interaction with people on
the Internet. They also protect the privacy, confidentiality, and interests of GSPS and our current
and potential products, employees, partners, customers, and competitors.

Note that these policies and guidelines apply only to work-related sites and issues and are not
meant to infringe upon your personal interaction or commentary online.

GUIDELINES FOR INTERACTION ABOUT GSPS ON THE INTERNET
   If you are developing a Web site or writing a blog that may potentially mention GSPS
     and/or our current and potential products, employees, partners, customers, and
     competitors, identify that you are an employee of your company and that the views
     expressed on the blog or Web site are yours alone and do not represent the views of the
     company.
   Unless given permission by your manager, you are neither authorized to speak on behalf
     of the company, nor to represent that you do so.

CONFIDENTIAL INFORMATION COMPONENT OF THE BLOGGING POLICY
   You may not share information that is confidential and proprietary about the company.
    This includes information about trademarks, upcoming product releases, sales, finances,
    number of products sold, number of employees, company strategy, and any other
    information that has not been publicly released by the company.
   These are given as examples only and do not cover the range of what the company
    considers confidential and proprietary. If you have any question about whether
    information has been released publicly or doubts of any kind, speak with your manager
    before releasing information that could potentially harm our company, or our current and
    potential products, employees, partners, and customers. You may also want to be aware
    of the points made in the non-disclosure agreement you signed when you joined our
    company.




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      The GSPS logo and trademarks may not be used without explicit permission in writing
       from the company. This is to prevent the appearance that you speak for or represent the
       company officially.

RESPECT AND PRIVACY RIGHTS COMPONENTS OF THE BLOGGING POLICY
   Speak respectfully about the company and our current and potential employees,
     customers, partners, and competitors. Do not engage in name calling or behavior that will
     reflect negatively on your company's reputation. Note that the use of copyrighted
     materials, unfounded or derogatory statements, or misrepresentation is not viewed
     favorably by GSPS and can result in disciplinary action up to and including employment
     termination.
   GSPS encourages you to write knowledgeably, accurately, and using appropriate
     professionalism. Despite disclaimers, your Web interaction can result in members of the
     public forming opinions about your company and its employees, partners, and products.
   Honor the privacy rights of our current employees by seeking their permission before
     writing about or displaying internal company happenings that might be considered to be a
     breach of their privacy and confidentiality.

COMPETITION COMPONENT OF THE BLOGGING POLICY
   You may not sell any product or service that would compete with any of GSPS’s
    products or services without permission in writing from the president. This includes, but
    is not limited to training, books, products, and freelance writing. If in doubt, talk with
    your manager and the president.

YOUR LEGAL LIABILITY COMPONENT OF THE BLOGGING POLICY
   Recognize that you are legally liable for anything you write or present online. Employees
    can be disciplined by the company for commentary, content, or images that are
    defamatory, pornographic, proprietary, harassing, libelous, or that can create a hostile
    work environment. You can also be sued by company employees, competitors, and any
    individual or company that views your commentary, content, or images as defamatory,
    pornographic, proprietary, harassing, libelous or creating a hostile work environment.

MEDIA CONTACT COMPONENT OF THE BLOGGING POLICY
   Media contacts about GSPS and our current and potential products, employees, partners,
    customers, and competitors should be referred for coordination and guidance to the
    CEO/President or designee. This does not specifically include your opinions, writing, and
    interviews on topics aside from our company and our current and potential products,
    employees, partners, customers, and competitors.




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PUBLIC RELATIONS

Public Relations: Gryphen Specialty Products and Services’ CEO/President is the only individual
authorized to release Gryphen Specialty Products and Services information to the media.
Employees are not permitted to appear in programs on behalf of Gryphen Specialty Products and
Services unless all arrangements are approved through the CEO/President or designee.

Employees contacted by members of the press will immediately refer such calls to the office of
the CEO/President or designee.




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WHISTLEBLOWER PROTECTION

This policy is designed to protect employees and explain Gryphen Specialty Products and
Services commitment to integrity and ethical behavior. In accordance with Whistleblower
Protection regulations, Gryphen Specialty Products and Services will not tolerate harassment,
retaliation, or any type of discrimination against an employee who:

      Makes a good faith compliant regarding suspected Company or employee violations of
       the law
      Makes a good faith complaint regarding accounting, internal accounting controls, or
       auditing matters that may lead to incorrect, or misrepresentations in, financial accounting
      Provides information to assist in an investigation regarding violations of the law; or
      Files, testifies, or participates in a proceeding in relation to alleged violations of the law.

Negative employment sanctions, such as demotion or termination, as a result of an employee's
decision to provide good-faith information regarding violations of the law, will not be tolerated.
In addition, discrimination, threats, and harassment is prohibited.

Anyone violating this policy will be subject to discipline, up to and including termination of
employment.




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USE OF COMPANY RESOURCES




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USE OF COMPANY PROPERTY

Gryphen Specialty Products and Services provides employees with the equipment necessary to
perform their jobs. Some of this equipment may be used for personal use, but may not be
removed from Gryphen Specialty Products and Services premises unless approved by
Management.

Computer equipment may be used, within reason, for personal use; this includes word processing
and internet programs. It is forbidden to install any other programs to a company computer
without the written permission of the department head. Such programs include, but are not
limited to, games, online services, screen savers, etc. The copying of programs from company
computers is not allowed unless you are specifically permitted to do so, in writing, by Gryphen
Specialty Products and Services management.




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INTELLECTUAL PROPERTY AND OWNERSHIP OF WORK

Intellectual Property and Ownership of Work: All inventions, patents, patent applications,
copyrightable materials, trademarks (and associated goodwill), domain names, data, studies,
computer code, improvements, derivative works, and any related intellectual property rights,
produced by an employee based upon an employee's work for Gryphen Specialty Products and
Services, or exposure to a Gryphen Specialty Products and Services class, project, materials,
employment or activity, shall be owned by Gryphen Specialty Products and Services and be
considered a work made for hire, whether developed individually or jointly with Gryphen
Specialty Products and Services or third parties.

       1. The employee assigns all right, title and interest to such items to Gryphen Specialty
       Products and Services and the employee must waive all retained rights.
       2. If Gryphen Specialty Products and Services discovers possible evidence of activity that
       violates this policy, it can take appropriate disciplinary action, up to and including
       discharge.




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COMPANY SUPPLIES

Only authorized persons may purchase supplies in the name of Gryphen Specialty Products and
Services. No employee whose regular duties do not include purchasing shall incur any expense
on behalf of Gryphen Specialty Products and Services or bind Gryphen Specialty Products and
Services by any promise or representation without express written approval.




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COMPUTER USAGE

Computer equipment may be used, within reason, for personal use; this includes word processing
and internet programs. It is forbidden to install any other programs to a company computer
without the written permission of the department head. Such programs include, but are not
limited to, games, online services, screen savers, etc. The copying of programs from company
computers is not allowed unless you are specifically permitted to do so, in writing, by Gryphen
Specialty Products and Services management.




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INTERNET USAGE

Internet access to global electronic information resources on the World Wide Web is provided by
Gryphen Specialty Products and Services to assist employees in obtaining work-related data and
technology. The guidelines in this policy have been established to help ensure responsible and
productive Internet usage.

All Internet data that is composed, transmitted, or received via our computer communications
systems is considered Gryphen Specialty Products and Services property and, as such, is subject
to disclosure to law enforcement agencies or other appropriate third parties. Consequently,
employees must always ensure that the information contained in Internet e-mail messages and
other transmissions is accurate, appropriate, ethical, and lawful.

The equipment, services, and technology provided to access the Internet remain at all times the
property of Gryphen Specialty Products and Services. As such, Gryphen Specialty Products and
Services reserves the right to monitor Internet usage, retrieve and read any data composed, sent,
or received through our online connections and stored in our computer systems.

Employees should keep in mind that every outgoing communication bears the company's logo
and can be read by millions of people, including clients and competitors. To respect any
copyright and licensing agreements, employees should not forward anyone else's messages
without permission. Likewise, employees must not place company material, such as copyrighted
software or internal correspondence, on any publicly accessible Internet site without prior
permission.

The Internet does not guarantee the privacy or confidentiality of information. Sensitive material
transferred over the Internet can be intercepted by a third party. Therefore, employees must
exercise caution and care when transferring such material in any form.

Data that is composed, transmitted, accessed, or received via the Internet may not contain
content that may be considered discriminatory, offensive, obscene, threatening, harassing,
intimidating, or disruptive to any employee or other person. Employees using Gryphen Specialty
Products and Services equipment are forbidden to access any restricted services or websites.
These include, but are not limited to, those that promote or relate to pornography, gambling,
illegal activity, racism, promotion of violence, or gender degradation. Violation of these terms
may result in disciplinary action, up to and including termination of employment.

While Internet use is intended to assist in job-related activities, incidental and occasional brief
personal use is permitted, within reasonable limits.

Employees should be aware that Gryphen Specialty Products and Services can, in the course of
maintaining the system, access and review users' activities. If Gryphen Specialty Products and
Services discovers possible evidence of activity that is illegal or violates company policies or
rules, it can take appropriate disciplinary action, up to and including discharge and/or disclosure
of evidence to law enforcement officials or other third parties.




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Abuse of Internet access provided by Gryphen Specialty Products and Services in violation of
law or Gryphen Specialty Products and Services policies will result in disciplinary action, up to
and including termination of employment. Employees may also be held personally liable for any
violations of this policy.




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EMAIL USAGE

Email Usage: The company has provided email systems to employees so they can work more
productively. Email allows employees to exchange ideas, share files and keep in touch with
colleagues in the next room or thousands of miles away. Use of the email system is intended for
business purposes and should not be used for personal communications.

   1. The email system, including hardware, software and any stored data, is the property of
      Gryphen Specialty Products and Services. In addition, all messages and passwords
      created, composed, sent, received or stored on the email system are Gryphen Specialty
      Products and Services property and not the property of any employee.
   2. Employees cannot use the email system in ways that are disruptive or offensive to others,
      or harmful to workplace morale. There should be no display or transmission of sexually
      explicit images, messages or cartoons.
   3. The company also prohibits any transmission or use of email communications containing
      ethnic slurs, racial epithets or other content that can be construed as harassing or
      disparaging others based on race, national origin, sex, sexual orientation, age, disability,
      religion, or other illegal discriminatory factors.
   4. The email system cannot be used to solicit or proselytize for commercial ventures,
      religious or political causes, outside organizations or other non job-related matters.
   5. The email system cannot be used to send or receive copyrighted materials, trade secrets,
      financial or proprietary information or similar materials without prior proper
      authorization.
   6. Gryphen Specialty Products and Services reserves the right to review, audit, intercept,
      access and disclose all messages created, received or sent via the email system for any
      purpose. The contents of email properly obtained for legitimate business purposes can be
      disclosed within the company without the employee's permission. The company reserves
      the right to override any password and access an employee's email files for security and
      monitoring purposes.
   7. Employees should not assume that any email message is confidential. Even messages that
      are deleted can be retrieved and read. In addition, use of passwords for security does not
      guarantee confidentiality; messages can be reviewed by someone other than the intended
      recipient.
   8. Employees who use the email system for improper purposes or otherwise violate the
      email policy are subject to discipline, up to and including discharge.




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TELEPHONE USAGE
Gryphen Specialty Products and Services telephones are intended for the business purposes only.

Personal calls during business hours are discouraged except in cases of emergency. All personal
telephone calls should be kept brief. In an effort to respect the rights of all employees and avoid
disruption in the workplace, employees must inform family members and friends to limit
personal telephone calls during working hours. No long distance calls are to be made on
company phones which are not strictly business related.

Whenever possible, employees should make their personal telephone calls during meal or break
periods. Employees who make fraudulent, unlawful or abusive calls are subject to discipline and
possible criminal prosecution. Employees should report any threatening, intimidating or
harassing telephone calls received at work to their supervisor or their Department Head.

       (a) Whenever possible, employees should avoid fee-based telephone services, such as
       directory assistance.

       (b) Voice mail, like other components of the company telephone system, is intended for
       business use only, and all messages are company records.

       (c) Employees should respond promptly to their voice-mail messages and delete old
       messages. Although employees need a password to access the voice-mail system, they
       should not expect that voice-mail messages are private.

Any employee found in violation of this policy will be subject to disciplinary action, up to and
including termination.




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FLEET DRIVER AND VEHICLE MANAGEMENT POLICY


MINIMUM STANDARDS FOR DRIVING A GSPS VEHICLE
Only GSPS employees and other authorized agents of the GSPS who sign a Vehicle Use
Agreement (VUA) may drive GSPS vehicles. They may only use GSPS vehicles if they are on
official GSPS business, meet minimum driving standards and are authorized by their site
manager or Director of Operations. Approval will be documented and kept in each employee’s
personnel file. GSPS employees and other authorized agents of the GSPS may be allowed to
drive a GSPS vehicle if the following minimum standards are met and approved by their
employing agency:

      Must have a valid operator’s license issued by the state of Arizona,
      Must have minimum of two years licensed driving experience, and
      Must be twenty-one (21) years of age.

Site managers should consult with their supervisor regarding any requests for an exception to the
minimum standards. Approval will be documented and kept on file at the GSPS agency risk
management office. Approval of any exception to the minimum standards will be documented
and kept in each employee’s personnel file. Drivers denied the use of a GSPS vehicle based on
an unsatisfactory driving record may request a review of the denial with their supervisor.

VEHICLE USE AGREEMENTS AND TRAINING
All drivers must sign a ―Vehicle Use Agreement‖ (VUA), and submit the completed VUA to
their supervisor. Said supervisor will forward the VUA to the Director of Operations for
approval prior to operating a GSPS vehicle. The VUA describes the GSPS’s minimum standards
for driving a GSPS vehicle. All drivers who use GSPS vehicles will have their driving records
reviewed bi-annually. It is the driver’s responsibility to immediately notify the supervisor and the
Director of Operations of any changes or updates in their driving record.

Prior to driving a GSPS vehicle, each driver shall obtain a copy of and become thoroughly
familiar with the
―Fleet Driver and Vehicle Management‖ Policies and Procedures. Once drivers sign the VUA
they acknowledge an understanding of and future compliance with the directives in the
aforementioned policies and procedures. Any failure to comply with the policies and procedures
will be reviewed by the driver’s supervisor and may be considered a violation of work rules
resulting in a loss of GSPS vehicle driving privileges and possible discipline, up to and including
discharge. Any questions should be directed to the driver’s supervisor or the Director of
Operations.

All driver’s of GSPS vehicles will receive training on the proper use of a vehicle and safety
measures related to the use of a vehicle. All driver’s of GSPS vehicles must first pass this
training before operating a GSPS vehicle.




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DRIVER DISQUALIFICATION
GSPS employees and other authorized agents of the GSPS may not drive a GSPS vehicle if their
driving record reflects any of the following conditions:

      One moving violation and/or at-fault accidents in the past two years
      An Driving While Intoxicated (DWI)/Driving Under the Influence (DUI) citation within
       12 months
      Suspension or revocation of driver’s license

The violation occurs when the citation is issued, not when the final court decision is made.
Exceptions to this policy are subject to a review. The Director of Operations should be consulted
regarding any requests for an exception. Approval will be documented and kept in the employees
personnel file. Drivers denied the use of a GSPS vehicle based on an unsatisfactory driving
record may request a review of the denial with their supervisor.

Drivers must inform their supervisor and the Director of Operations in writing whenever they
become disqualified under these policies. Changes include, but are not limited to, DWI/DUI
citation, license revocation, restriction or suspension. Any change in the status of a driver’s
record resulting in disqualification or the failure to report such change may result in revocation
of the privilege of driving a GSPS vehicle and/or discipline up to and including discharge.

SPECIAL CERTIFICATIONS
Depending upon the type of vehicle driven, special training and/or licensing may be required
prior to vehicle use. For example, training is required for driver certification for the operation of
twelve and 15 passenger vans. Commercial Drivers Licenses (CDL) are also required for certain
GSPS positions.

PERMITTED AND PROHIBITED USES
The following policies govern GSPS vehicles:

      Use of a GSPS vehicle must be for official GSPS business only. Incidental use associated
       with official business away from the employee’s site city is strictly limited and may
       include incidental travel mileage
      All drivers and passengers in GSPS vehicles must comply with all Arizona laws,
       including the Arizona seat belt law.
      Drivers are personally responsible for the cost of all traffic citations, parking tickets,
       locksmith calls for retrieving keys, etc.
      Drivers are responsible for compliance with IRS and Arizona Department of Revenue
       requirements that are related to mileage reimbursement and personal use of a GSPS
       vehicle.

Compliance with GSPS vehicle use policies is required of all drivers and passengers. No person
may use a
GSPS vehicle, or permit the use of a GSPS vehicle, in the following prohibited manners:
    Reckless driving or speeding
    The driver is impaired by fatigue, alcohol, drugs or any other condition


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           o Any such vehicle use will be considered a violation of Fleet Driver and Vehicle
               Management Policies and Procedures and may be grounds for disciplinary action
               up to and including discharge.
           o Drivers of GSPS vehicle who feel that their driving abilities may be impaired
               must cease operating the vehicle immediately. Employees who believe another
               employee is impaired have a duty to prevent that person from driving a GSPS
               vehicle.
      Smoking is prohibited in GSPS vehicles
      Transporting non-GSPS employee passengers, including family members, is not
       permitted unless authorized
      Use for personal gain, such as delivering goods or services
      Modifications including affixing signs, stickers, antennas, bike racks, ski racks, etc.
           o Modifications to GSPS vehicles may be undertaken only with the prior written
               consent from the Director of Operations
      Transporting animals
           o Allowed only with prior written consent of the Director of Operations
           o Service animals are allowed. Inclusion of persons with service animals on
               transportation routes must be reviewed on a case-by-case basis to ensure the
               comfort and health of others on the route
      Hauling loads that could structurally damage the vehicle (e.g., firewood, paper, gravel)
      Use of trailer hitches and towing
      Allowed only with prior written consent of the owner agency fleet manager
      Installation or use of any radar-detection devices
      Transporting hitchhikers
      Bicycles transported inside vehicles
      Use for vacations or any other use not expressly authorized by this manual
      Drivers who have questions regarding the appropriate use of a GSPS vehicle should
       consult with their agency fleet manager.

PERSONAL USE OF GSPS VEHICLES
GSPS vehicles shall not be used for personal purposes.

INCIDENTAL TRAVEL AND STOPS
Incidental travel and stops are only permitted when necessary to (1) provide transportation to
consumers to and from their residence and GSPS sites, and (2) the provision of services,
employment, etc. to consumers as part of their program plan. Examples are stops at a restaurant
for a meal, an Automatic Teller Machine (ATM) or financial institution, urgent care or
emergency room or a gas station or convenience store. Incidental stops during transportation to
and from the consumers residence and GSPS sites are the exception and not SOP. Incidental
stops are those stops necessary when a particular situation with a consumer arises during the
transportation of a consumer to and from their residence and a GSPS site that requires staff to
redirect their attention from driving (e.g. consumer needs to use the restroom, medical
emergency, preplanned deviation from route as part of a program activity, refueling, etc.). Note:
See ―Refueling Vehicles‖ regarding safety procedures and requirements for refueling GSPS
vehicles.



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Drivers should remember that public perception of GSPS employees is important and influenced
by how and where the public sees GSPS vehicles being used. Drivers should not make incidental
stops at locations the public would perceive as inappropriate. Examples are gaming venues, adult
themed outlets and other locations where it is unlikely that any GSPS business or allowable
incidental use is involved. Drivers required to stay overnight(s) away from home may, with
permission of their supervisor, use a GSPS vehicle for the types of necessary activity that could
be expected of a traveler away from home. Examples include evening use to go to a pharmacy,
grocery, laundromat, fitness center, or other locations to purchase goods or conduct activities
necessary for the employee’s health and well being.

REIMBURSING PERSONAL MILES TO GSPS
As it pertains to a vehicle assigned specifically to a GSPS employee or when using a vehicle
assigned to a GSPS site for authorized personal use, the Internal Revenue Service (IRS) rules
provide that the personal use of a GSPS vehicle includes commuting to and from work, even if
the vehicle is taken home for the convenience of the GSPS. Personal use is considered a fringe
benefit by the IRS unless the employee reimburses the GSPS for the full value of the personal
mileage based on the IRS Valuation rules. The value of the fringe benefit must be included in the
employee’s wages and is subject to income and employment taxes. No additional employee
wages will need to be calculated if the employee reimburses the GSPS for the value of the
benefit, derived in accordance with the appropriate IRS rule.

Per the IRS, if a vehicle is generally taken home more than once a month, the employee is
required to reimburse the GSPS for personal miles traveled. This section applies to motor pool,
work share, rental and personally assigned vehicles. IRS examples include:

      A GSPS owned pickup truck has the name of the GSPS marked on the vehicle. Usually
       the employee is allowed to take the vehicle home because he/she is ―on call.‖ The vehicle
       is not a qualified non-personal use vehicle, thus the commuting is a non-cash taxable
       fringe benefit.
      An employee takes a GSPS vehicle home in order to avoid exposing it to harm. The
       vehicle has a GSPS seal on the door and is not to be used for personal use. If the vehicle
       is not a qualified non-personal use vehicle, the employee would have a taxable
       commuting benefit if he/she takes a GSPS vehicle home.
      An employee uses a motor pool vehicle for a business meeting. The employer requires
       that motor pool vehicles are returned at the end of the business day but the employee is
       delayed and motor pool is closed when the employee arrives back at the office. The
       employee takes the vehicle home and returns it the next morning. Is the commute home
       and back to the office the next morning taxable to the employee? Per IRS: Assuming that
       this is an infrequent occurrence for that employee, that is, generally happens no more
       than once a month, the commuting value of the trip would be considered a non-taxable
       ―de minimis‖ fringe benefit. If not an infrequent occurrence, the commute would be
       taxable to the employee.

Reimbursable personal miles are determined as follows:
    Actual miles driven between an employee’s home and headquarters are considered
      commuting miles, or,


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      For trips that start or end at an employee's home, the lesser of actual miles driven
       between an employee's home and the work site removed from the assigned headquarters
       or the mileage between an employee's assigned headquarters and the work site, are
       considered business miles. Any miles driven in excess of this amount would be
       considered personal miles that need to be reimbursed to the GSPS.

The operator of the vehicle is required to keep track of all business miles by keeping an Assigned
Vehicle
Log on a daily basis containing the information described below. Any undocumented mileage
will be considered personal miles and considered compensation provided to the employee.
Unless otherwise authorized, all personal mile reimbursements must be submitted along with the
monthly mileage report to the vehicle owner agency. Reimbursement to the GSPS shall be
calculated using one of the following two valuation rules:

VEHICLE COMMUTING RULE
This method applies only to the employee who is required to commute in the vehicle for valid
business reasons and the employee is not compensated for such use. The following method is
used to calculate reimbursement to GSPS:

      Qualifying Employees must reimburse GSPS at the greater of $2.00 per GSPS employee
       each way of the commute or $0.325 per mile plus appropriate tax.
      Example: John commutes to a GSPS site via a GSPS vehicle used for a program route.
       He lives 20 miles from the GSPS site. 20 miles x $0.325 x 2 ways = $13.00 plus tax
       which John must reimburse to the GSPS.

IRS LIABILITY
If an employee utilizes a GSPS vehicle for personal use, including commuting, and the personal
use of the vehicle is not reimbursed to GSPS, the value of any non-reimbursed personal use is
considered a taxable fringe benefit. This rule does not apply to a qualified non-personal use
GSPS vehicle as long as the employee is complying with the assignment requirements.

MILEAGE REPORTING
Monthly mileage reporting is required for every GSPS vehicle. Site Managers are required to
forward to documents following the end of each month. First, the Assigned Vehicle Log
recording the monthly mileage of each vehicle assigned to their site, should be submitted to the
Director of Transportation no later than the second business day following the last business day
of the previous month. Second, Transportation Logs, which record each leg of daily travel,
should be submitted to the Vice President no later than the second business day following the last
business day of the previous month.

The mileage report indicates the beginning and ending odometer readings for each vehicle. A
Site Manger supervisor signature is required on all Assigned Vehicle Logs and Transportation
Logs verifying their accuracy.

RIDING IN A GSPS VEHICLE




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Non-GSPS employees may ride in a GSPS vehicle if on official GSPS business and authorized
by the Site Manager. Approval will be documented and kept on file at the GSPS site. The Site
Manager will forward said approval to the Director of Operations with the Assigned Vehicle
Logs each month.

CITATIONS
Drivers are responsible for promptly paying all vehicle citations. Failure to pay parking tickets
immediately results in late fees and possible vehicle registration revocation or suspension. If this
occurs because a GSPS employee did not immediately pay a parking ticket they are responsible
for, GSPS will pay the amount due upon notice and invoice the employee. In this situation, the
employee may be subject to discipline, as determined by GSPS.

VEHICLE FUEL POLICIES AND FUEL CARD USES
Site Managers will be provided with a list of vendors from which fuel should be purchased. Site
Managers will provide written directions to these locations and instruct their staff that are
assigned as drivers on the procedure for purchasing fuel.

The driver of the vehicle must be trained how to use the fleet fuel card. Use of Driver ID (PIN)
and accurately recorded odometer readings are required when using the fleet fuel card. Fuel
cards may not be used for the purchase of non-vehicle items such as food. If an attendant error
occurs and non-vehicle items are charged to the fuel card, it is the responsibility of the driver to
notify and reimburse GSPS. The Director of Operations is responsible for reviewing fuel card
charges and identifying non-qualified purchases. Failure to reimburse for such purchases may
result in the loss of driving privileges.

GSPS contracts with a fuel card vendor that issues credit cards and has established a transaction
processing, reporting and payment system with respect to purchases of motor fuels. GSPS policy
restricts the use of the fuel card to purchase fuel. The purchase of personal items such as food,
beverages and air fresheners with a GSPS fuel card, as well as automotive products for personal
use, is strictly prohibited. Disciplinary action may be taken for improper use of a GSPS fuel card.
If an inappropriate charge occurs, the driver is responsible for reimbursing the GSPS for the full
amount of the inappropriate purchase.

Refueling Vehicles: Unless otherwise indicated on the vehicle, all GSPS vehicles require
―Regular Unleaded‖ gasoline. ―Regular Unleaded‖ gasoline can be identified at all federally and
state regulated fueling stations by two labels that include the following information: ―Regular
Unleaded‖ and ―87‖. No other grade or type of gasoline should be pumped into GSPS vehicles.
Failure to comply with this rule, may result in GSPS requiring reimbursement for the difference
in cost between ―Regular Unleaded‖ gasoline and the higher grade chosen, or the cost to repair a
GSPS vehicle that was filled with a type of gasoline other than ―Regular Unleaded‖ (i.e.
Diesels).

Vehicles should NEVER be refueled with consumers inside the vehicle. All efforts should be
made to refuel vehicles while consumers are at a GSPS site or somewhere other than the gas
station/convenience store. If refueling must occur at a gas station/convenience store, staff must
remove all consumers from the vehicle and escort them to a safe zone where they are supervised



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by GSPS staff while the vehicle is being refueled. GSPS staff must remain with consumers at all
times.

VEHICLE RELATED PURCHASES, REPAIRS, PREVENTIVE MAINTENANCE AND
RECALLS
The Director of Operations is responsible for determining which automotive service vendors and
gas stations to use. Fuel or other supplies and services needed to operate a GSPS vehicle are
primarily acquired through GSPS contracts.

It is the shared responsibility of each Site Manager and the Director of Operation’s responsibility
to ensure that all preventative maintenance is performed on schedule and have the vehicle
serviced in a timely manner when notified of a recall or preventive maintenance. Failure to
perform the maintenance and repairs in accordance with GSPS policy may result in loss of the
vehicle or, in the event of damage to the vehicle, payment for vehicle repair.

The procedure for initiating and obtaining authorization for repairs and maintenance is as
follows:

   1. Site Manager will contact the Director of Operations using the ―Authorization for Repair
      and Maintenance‖ form regarding necessary repairs and maintenance. If repairs need to
      be expedited, the Site Manager should also call the Director of Operations once the
      ―Authorization for Repair and Maintenance‖ has been sent.
   2. The Director of Operations will authorize or deny the request and email the form back to
      the Site Manager. Vendors will not accept any vehicles without this form.
   3. When obtaining authorization and planning for vehicle repairs and maintenance, it is the
      Site Manager’s responsibility to coordinate these activities within the time parameters of
      transportation provided to and from the consumers residence and the site and
      transportation done throughout the day related to program. Unless an unexpected
      breakdown occurs, ―pick-ups‖ and ―drop-offs‖ should never be late as a result of repair
      and maintenance to a vehicle.
   4. If the request is authorized, the Site Manger is responsible for taking the vehicle to a
      vendor contracted with GSPS. The Site Manager will ensure that the vendor is informed
      of the necessary repair and maintenance to be undertaken and that were authorized by the
      Director of Operations. Said vendor will contact the Director of Operations following
      any diagnosis of problems with vehicles in order to receive authorization to perform the
      needed repair and maintenance derived from said diagnosis. Site Managers are NOT
      permitted to authorize any repair and maintenance that has not already been discussed
      with the Director of Operations.
   5. Upon completion of any repairs and maintenance, the Site Manager is responsible for
      picking up the vehicle from the vendor, obtaining a receipt of payment (if applicable) and
      an invoice of the work performed.
   6. Site Manager will forward the invoice of work to the Director of Operations by the next
      business day.

The following types of services are available through GSPS contracts with vendors for fleet
related items:



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      Tires: new, service (No Retreads Allowed)
      Auto, light truck maintenance and repair
      Towing and storage
      Rental passenger vehicles
      Glass repair or replacement

All repairs and maintenance to vehicles must be approved by the Director of Operations.
Exceptions to this rule include:

      Unexpected replacement of a tire or tires due to a ―blowout‖
      Regularly scheduled oil changes, and related fluid replacement
      Windshield wiper replacement

The work described in these exceptions may be performed only by vendors with which GSPS
has a current contract.

VEHICLE EMERGENCY EQUIPMENT AND REPAIR/SAFETY MEASURES
All drivers of GSPS vehicles must know how to handle unscheduled emergency repairs.
Instructions should be in the information/incident kit found in the GSPS vehicle. If not available,
contact the Director of Operations to obtain a copy.

ACCIDENTS: DRIVER PROCEDURE
Drivers are responsible for immediately reporting all accidents or any damage to GSPS vehicles
to the Site Manager and to the Director of Operations. An Incident Report should be completed
by the driver of the vehicle involved in the accident, reviewed by the Site Manager and
forwarded to the Director of Operations within 24 hours of the accident. Any police report or
information obtained at the scene of the accident should be attached and forwarded with the
Incident Report. Also, pictures of the accident scene, if possible, and/or pictures of the damage
to the vehicle should be taken, attached and forwarded with the Incident Report. If all paperwork
is not submitted in a timely manner, the claim may be denied causing GSPS to be financially
responsible for the cost of any vehicle damage, injuries to bodily damage, etc.

Each GSPS vehicle has an accident kit in the glove compartment advising employees of the
procedures to be followed in the event of an accident. All procedures included in the accident kit
need to be followed.
According to the instructions in the kit, the driver of the GSPS vehicle must follow these
procedures after an auto accident involving a GSPS vehicle:

   1. Contact the nearest law enforcement agency to notify them of an accident.
   2. Obtain relevant information required from other parties involved to complete the
      ―Incident Report‖
   3. Ask for the case number and when the police report will be available.
   4. Driver is required to seek a police report for all vandalism or hit-and-runs that exceed
      $200, accidents resulting in injuries, vehicle damage over $1,000, and/or property
      damage over $200.


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   5. Report the accident immediately to the Site Manager and Director of Operations.
   6. Complete the Incident Report Form the same day including the Site Manager’s signature
      and forward to the Director of Operations within 24 hours. If the driver is unable to
      complete the accident report form, the Site Manager is responsible for completing it. It is
      extremely important that the information is accurate and all blanks are filled in, including
      the driver and Site Manager’s signatures.
   7. If a GSPS employee is injured, the appropriate workers compensation forms should be
      completed by the employee or the employee’s Site Manager if the employee is unable to
      complete the forms.
   8. If not provided to the driver at the scene, the Director of Operations will obtain a copy of
      the police report.

LIABILITY COVERAGE
See current Auto Policy and current DDD regulations for ―Liability Coverage‖.

FLEET MANAGEMENT RESPONSIBILITIES
The Site Managers are responsible for the following:

      Maintain up-to-date knowledge of fleet policies and procedures
      Educate their staff/drivers of all policies and procedures
      Ensure completion of Vehicle Use Agreement for their employees
      Submit requests for a vehicle assignment
      Communicate and forward information regarding vehicle needs (i.e. maintenance,
       replacement) to the Director of Operations
      Manage vehicle use (e.g., mileage logs, routes, maintenance)

The Director of Operations is responsible for the following:

      Designate and review vehicle assignments for each site
      Establish maintenance procedures
      Evaluate and recommend vehicle procurement needs
      Identify surplus vehicles for sale disposition
      Maintain vehicle history records
      Monitor direct and indirect fleet costs
      Ensure adherence to fleet maintenance procedures
      Identify underutilized/replaceable vehicles
      Monitor costs that must be reimbursed by the employee
      Investigate citizen driver complaints
      Process accident claims

MONITORING VEHICLE USE AGREEMENTS
Biannually, the Vice President will review the driving records for all employees with active
Vehicle Use Agreements. An employee who, as a result of the review, no longer meet minimum
standards for driving a GSPS vehicle shall have his/her agreement voided and their driving
privileges suspended until such time that he/she can demonstrate meeting the standard. If an



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employee is unable to drive due to an unacceptable driving record and driving is required in
order to fulfill his/her job duties, this will necessitate a reassignment. If reassignment is not
possible because a non-driving position is not available, the employee may be suspended until
such time as a non-driving position is available or terminated. (See policies related to driver
disqualification.)

CITIZEN DRIVER COMPLAINTS
If a call is received from a citizen regarding the driver of a GSPS vehicle, gather as much
information as possible about the incident including date, time, location, license plate, vehicle
ID, description of driver
(e.g., gender), make, model, color of the vehicle and a detailed description of the incident. Obtain
the caller’s name and telephone number if they are willing to give it.

Depending on who is contacted by the citizen driver, the Site Manager or the Director of
Operations should record the complaint in detail and communicate with the driver or the driver’s
supervisor. While these are not moving violations in the manner reviewed for driver
disqualification, they may become the basis for suspending driving privileges if there are
multiple complaints logged.




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ENERGY CONSERVATION AND COST SAVINGS POLICY


In a typical GSPS site, space heating, cooling, and lighting together account for nearly 70 percent
of energy use. Plug loads, such as stoves/ovens, refrigerators, TV’s and computers are typically
the remaining electricity end uses, after lighting and heating/cooling.

By implementing energy-efficient operations and maintenance strategies and incorporating
energy efficient equipment into each site, GSPS can generate substantial energy cost savings
while improving the physical environment of each facility.

To better manage a building's energy costs, it helps to understand how GSPS is charged for those
costs. Electricity can be charged based on two measures: demand and consumption. The
consumption component of the bill is based on the amount of electricity in kilowatt-hours that
the building consumes each month. The demand component is the peak demand in kilowatts
occurring within the month or, for some utilities, during the previous 12 months. Demand
charges can range from a few dollars to upwards of $20 per kilowatt-month. Depending on the
utility provider for a particular site, the electric bill may include demand charges. If this is the
case, that site should reduce demand whenever possible.

Understanding a site’s energy consumption in a given month can also help in the effort to control
costs. The Director of Operations can provide monthly data for a site’s electricity consumption.

CONSERVATION MEASURES
The following conservation measures presented will save money and enhance both the aesthetics
and the learning and productivity environment of your site. Each site can achieve energy savings
of up to 25 percent by implementing these behavioral and operational changes.

TURNING THINGS OFF
The quickest and easiest way to implement load reductions is to ensure that equipment is turned
off when it's not needed. This can be accomplished by recruiting program participants as
monitors. Program participants can be enthusiastic ambassadors of a site’s energy-saving goals,
and an activity such as creating "turn it off" signs to place above light switches, for example, can
be a fun and educational activity.

COMPUTERS, PRINTERS, AND COPIERS
These should be turned off when they are not in use as well as over weekends and holiday
breaks. "Smart" power strips with built-in occupancy sensors can shut off printers and copiers
when no users are present. Also, because a computer monitor can use two-thirds of the total
energy of a desktop system, it is important that they employ sleep-mode settings—this can save
as much as $75 per desktop system annually.

LIGHTS
Lighting strategies are the easiest way to minimize energy consumption without any major
expense. Simply turning off lights in unoccupied rooms can save from 8 to 20 percent on lighting
energy.




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Periodically cleaning light bulbs and fixtures with a dry cloth can increase lighting output levels
that have been reduced by dirt and dust. Plastic diffusers that cover most lamps need to be
periodically replaced because, over time, they can turn yellow or brown—significantly reducing
light output.

TURNING THINGS DOWN
Some equipment cannot be turned off entirely, but turning it down to minimum levels when
possible can save energy.

HVAC
If temperature is not controlled by an energy-management system, a programmable thermostat
can increase energy savings and enhance comfort by automatically adjusting temperature to
preset levels. It can also lower temperatures on weekends and holidays and can save up to $150
on energy costs per year. (See Thermostat Program for HVAC below)

Many AC systems use a dampered vent called an economizer to draw in cool outside air and
reduce the need for mechanically cooled air. It is recommended that a licensed technician check
actuator movement and setpoint and clean and lubricate movable surfaces every three to six
months to keep the system running properly.

WATER HEATERS
Consider adding a timer to automatically shut off electric water heaters when the building is
unoccupied. Installing insulation on hot-water pipes is a low-cost option that reduces heat loss,
allowing for lower water-temperature settings.

LIGHTING CONTROLS
Automatic controls such as occupancy sensors, time controls, photo-sensor controls, and
dimmers save energy and help to reduce maintenance costs. In large restrooms, ceiling-mounted
ultrasonic occupancy sensors detect occupants around partitions. For hallways, a recommended
strategy is to use a combination of scheduled lighting and dimming plus occupancy sensor
controls after hours. Occupancy sensors are also appropriate for storage and offices.

VENDING MACHINE CONTROLS
Use occupancy sensors to power down vending machines when the area is unoccupied. Sensors
can save nearly 50 percent of the $170 to $250 in annual electricity costs to operate vending
machines.

CLEANING AND MAINTENANCE
Regularly scheduled maintenance and periodic tune-ups can extend the life of facility equipment
(e.g. HVAC, water heater, etc.) and ensure proper operation.

BUILDING ENVELOPE
All doors and windows should be periodically inspected for leaks. Caulking and weather-
stripping leaks help minimize air infiltration and can reduce energy waste.

FANS




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Fan blades, bearings, and belts should be inspected at least once a year to prevent failure and
maintain efficiency. During the inspection, fan blades should be cleaned, bearings should be
checked for adequate lubrication, and belts should be adjusted and changed if needed.

FILTERS
Air filters should be changed every one month. More frequent filter changes may be required for
HVAC units located next to highways, construction sites, agricultural areas and the time of year.

LEAKS
A leak in an HVAC rooftop unit can cost $100 per unit per year in wasted energy. On a quarterly
basis, cabinet panels and ducts on rooftop HVAC equipment should be checked for leaks. A
check should also be made to ensure units are secure, with all screws in place. On an annual
basis, inspect all access panels and gaskets, particularly on the supply-air side, where pressure is
higher.

CONDENSER COILS
Cleaning the condenser coil is one of the most cost-effective maintenance steps that can be done
on HVAC systems. A dirty coil that raises condensing temperatures by as little as 10° Fahrenheit
can increase power consumption by 10 percent—resulting in about $120 in electricity costs for a
10-ton unit operating 1,000 hours per year. Condenser coils should be checked for debris on a
quarterly basis and cleaned at least once a year.

HOT WATER SYSTEMS
To maintain optimum efficiency and prevent waste, the burners of gas- or oil-fired water heaters
should be tested and adjusted annually. Fixtures should be periodically flushed with hot water to
control bacteria growth. Storage-type water heater tanks should be flushed out annually to
remove sediments that reduce heat-transfer efficiency.

UPGRADING TO MORE-EFFICIENT LIGHTING
Lighting retrofits can save as much as 30 to 50 percent of lighting energy, plus 10 to 20 percent
of cooling energy. In addition, incorporating a design strategy that uses a mix of both natural and
artificial light sources increases visual comfort and further reduces energy costs.

High-performance T8 fluorescent lamps with electronic ballasts are the best choice for most
general lighting applications (such as work rooms, offices, multipurpose rooms, and cafeterias)
and can reduce lighting energy consumption by 35 percent if they replace T12 fluorescents.
Adding specular reflectors, new lenses, and occupancy sensors or timers can double the savings.
In rooms where ceilings are more than 15 feet high (such as gymnasiums, auditoriums, and
libraries), high-intensity fluorescent lamps are a better alternative to the high-intensity discharge
lamps that are more commonly used.

Compact fluorescent lamps (CFLs) can replace incandescent lamps in a variety of applications,
reduce energy use by two-thirds, and save up to $20 per lamp per year.

An Energy Star–rated light-emitting diode (LED) exit sign can last 25 years without lamp
replacement, compared with less than 1 year for an incandescent sign. LEDs are also appropriate
for gymnasium scoreboard applications.



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EVAPORATIVE COOLING
Evaporative Cooling can save 60 to 80 percent of cooling energy by reducing levels of
compressor cooling. Most effective in warm, dry climates, evaporative coolers are generally not
well suited for high-humidity environments. However, hybrid systems are available that include
compressor-based cooling capabilities for times of high humidity. The best units utilize high-
efficiency fans driven by variable-speed drives on premium-efficiency motors.

THERMOSTAT PROGRAMS FOR HVAC
If a site does not have the operations manual for their thermostat, said manuals can be
downloaded and printed from the manufacturer’s website. A copy of the manual should be filed
and kept on site at all times for future use.

Spring/Summer: Program Heat/Air Conditioners (HVAC)

      Peak times are 7am to 7pm M-F in terms of what electricity costs

      In the mornings, at 6:30am, Monday thru Friday, HVAC’s should be set on ―Cool‖ at 74
       degrees

      In the afternoons, Monday thru Friday, HVAC’s should be set on ―Cool‖ at 82 degrees as
       soon as the building(s) are empty (i.e. approximately 5pm in Tempe and 4pm in Casa
       Grande)

      On the weekends, the HVAC will run on ―Cool‖ at 86 degrees when the buildings are
       empty

      HVAC will run on ―Cool‖ at 86 degrees any other time not included above when the
       buildings are empty

      As the weather begins to change and cool down, your HVAC program will revert to the
       ―Fall/Winter Program‖

Fall/Winter: Program Heat/Air Conditioners (HVAC)

      Peak times are 6am to 6pm M-F in terms of electricity costs

      In the mornings, at 5:30am, Monday thru Friday, HVAC’s should be set on ―Heat‖ at 70
       degrees

      In the mornings, at 11:00am, Monday thru Friday, HVAC’s should be set on ―Heat‖ at 68
       degrees

      In the afternoons, Monday thru Friday, HVAC’s should be set on ―Heat‖ at 65 degrees as
       soon as the building(s) are empty (i.e. approximately 5pm in Tempe and 4pm in Casa
       Grande)

      On the weekends, the HVAC should be OFF when the buildings are empty



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   HVAC will run on ―Heat‖ at 65 degrees any other time not included above when the
    buildings are empty

   As the weather begins to change and cool down, your HVAC program will revert to the
    ―Spring/Summer Program‖




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DAY-TO-DAY ADMINISTRATIVE
FOCUS




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COMPANY HOURS

Gryphen Specialty Products and Services is operates from 7:30 am to 5:30 pm, Monday through
Friday; except for holidays recognized by Gryphen Specialty Products and Services. Contact
your supervisor to determine the specific hours of operations for your assigned work location.

The standard workweek for full-time employees is 35 hours of work, and less than 35 hours for
part-time employees. For the purposes of calculating employee benefits and pay periods, the
workweek is considered Monday at 12:00 a.m. through Sunday at 11:59 p.m.




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SAFETY AND SECURITY

SAFETY
Gryphen Specialty Products and Services strives to provide a clean, hazard-free, and safe
environment for employees in accordance with the Occupational Safety and Health Act of 1970.
Each employee is expected to take an active role in maintaining this safe environment.
Employees must observe all posted safety rules, adhere to all safety instructions, and properly
use safety equipment when required. Workspaces must be kept neat, clean and organized.

It is the responsibility of employees to familiarize themselves with the location of all safety and
emergency equipment, as well as safety contact phone numbers. All safety equipment will be
provided by Gryphen Specialty Products and, and employees are responsible for the reasonable
upkeep of this equipment. Any problems with, or defects in, equipment should be reported
immediately to a supervisor.

Each employee is required to comply with all safety rules observed by Gryphen Specialty
Products and, assist in maintaining a hazard-free environment, immediately inform management
of any accidents or injuries, and report any unsafe equipment, working conditions, processes,
procedures, or potential breach of safety to a supervisor.

Any employee may report safety violations or injuries anonymously to a supervisor, if he or she
is not the injured or violating party. No employee will be punished or reprimanded for reporting
safety violations or hazards.

Any deliberate or ongoing safety violation, or creation of a safety hazard by an employee, will be
dealt with through disciplinary action by Gryphen Specialty Products and, up to and including
suspension or termination.

Work-related accidents are covered by Workers' Compensation Insurance, pursuant to all
applicable state and local laws.

Gryphen Specialty Products and Services provides information and assistance to employees on
workplace safety and health issues via internal communication, such as:

      Training sessions
      Team meetings
      Bulletin board postings
      Memorandums
      Miscellaneous written communication
      Newsletters

Employees are expected to obey safety rules and exercise caution and common sense in all work
activities. Employees must immediately report any unsafe conditions to their supervisor.
Employees who violate safety standards, cause hazardous or dangerous situations, or fail to
report or - if appropriate - remedy such situations, may be subject to disciplinary action up to and
including termination of employment.


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In the case of an accident that results in injury, regardless of how minor the injury may appear,
employees must notify their supervisor.

SECURITY
All employees who are issued keys are solely responsible for their safekeeping. These employees
may be required to sign a Key Disbursement Form upon receiving the key. The last employee, or
a pre-designated employee, to leave the premises at the end of the business day assumes
responsibility for ensuring that all doors are securely locked, the alarm system is armed,
thermostats are set on appropriate evening and/or weekend setting, and all appliances and lights
are turned off with exception of lights regularly left on for security purposes.

Employees are not permitted on Gryphen Specialty Products and Services property after hours
without prior authorization from a supervisor. These employees must demonstrate a legitimate
need to be on the premises.




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PARKING

Gryphen Specialty Products and Services provides parking for employees in the building parking
lot. There should be ample space for all employees. Employees may only park in open spaces or
those designated for use by Gryphen Specialty Products and Services. Vehicles parked in spaces
that are not open or designated for Gryphen Specialty Products and Services may be towed at the
owner's expense.




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PERSONAL PROPERTY

Gryphen Specialty Products and Services assumes no responsibility for personal property located
on its premises. Employees are to use their own discretion when choosing to bring personal
property into the workplace, and do so at their own risk. Additionally, employees may not
possess or display any property that may be viewed as inappropriate or offensive on Gryphen
Specialty Products and Services premises.




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PRIVACY EXPECTATIONS

Searches/Privacy Expectations: Company operations necessitate ready access to business-related
information, and situations may arise in which the best interests of the organization would be
served by conducting a search. No assurance of privacy is given nor should it be assumed by
employees regarding items stored in or conveyed by company equipment, such as desks,
telephones, personal computers, e-mail, vehicles, etc.

Searches may only be conducted for reasonable business-related purposes. A second member of
management shall be present at all searches to serve as a witness.

       1. Access: Management may access company property and equipment, such as
          employee desks, workstations, personal computers and computer files, filing cabinets,
          lockers, etc., at any time and for any business-related reason deemed appropriate by
          management.
       2. Investigations: Employees have a duty to cooperate fully with all investigations
          conducted in the workplace by management or other appropriate authorities, and to
          submit to a search in conjunction with the investigation if so directed.

Searches conducted as part of an investigation may include all property and equipment supplied
by the company such as desks, workstations, personal computers, filing cabinets, lockers, etc.

       1. In addition, all personal property brought onto company property is subject to search
          as part of an investigation, including such items as a purse, briefcase, coat, vehicle,
          container of any sort.
       2. Searches may not be made of a person's body, only of property, equipment, etc., as
          defined in this policy. However, employees may be directed as part of a search to
          empty pockets or other areas in clothing they are wearing.
       3. Failure or refusal to cooperate fully with an investigation or search is a major
          violation of Gryphen Specialty Products and Services policy and the employee is
          subject to corrective action, up to and including termination of employment.




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INTERNAL COMMUNICATIONS

Effective and ongoing communication within Gryphen Specialty Products and Services is
essential. As such, the company maintains systems through which important information can be
shared among employees and management.

Bulletin boards are posted in designated areas of the workplace to display important information
and announcements.

To facilitate communication and share access to documents employees may correspond and send
files via e-mail. For more information on the appropriate usage of e-mail in the workplace,
employees may refer to the Internet Usage and Computer Usage policies.

All employees are responsible for checking internal communications on a frequent and regular
basis. Employees should consult their supervisor with any questions or concerns on information
disseminated.




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INTERNAL INCIDENT REPORTING

The following policy pertains to incidents not related to DDD incident reporting requirements.
Gryphen Specialty Products and Services staff must complete an Internal Incident Report and
submit it to their immediate supervisor within 24 hours of a qualifying incident. GSPS expects
that staff will use common sense when evaluating if an incident report is necessary. If in doubt,
GSPS expects that the staff will contact their supervisor to discuss or complete and submit an
incident report.

Internal Incidents include, but are not limited to:

   A. Motor vehicle accidents
   B. Work related injuries
   C. Traffic violations
   D. Allegations of harassment sexual, physical, programmatic, verbal/emotional abuse
   E. Fraud by a GSPS employee
   F. Misuse of company funds or property
   G. accidental injuries which may or may not result in medical intervention
   H. theft or loss of individual’s money or property
   I. community disturbances
   J. circumstances which pose a threat to health, safety or welfare of individuals such as loss
      of air conditioning, loss of water or loss of electricity
   K. Natural disaster or unusual weather conditions or other disasters resulting in an
      emergency change of operations
   L. Staff drug use
   M. Staff violating no-smoking policy

When an incident occurs, the Staff will take the following steps:

   A. Staff should assess the level of severity and determine what method of first notification is
      appropriate (i.e., calling 911, GSPS, colleague, etc.)
   B. Staff should make sure the involved parties are all right and contact the appropriate
      entities if necessary (i.e., performing CPR or First Aid, calling 911, intervene, etc.)
   C. Call your GSPS supervisor as soon as possible following the incident and notify of any
      corrective action
   D. Notify the Emergency Contact Person if necessary
   E. Note the timelines of occurrences as accurately as possible
   F. Write the incident report
   G. Provide the incident report to GSPS as soon as possible, but no later than within 24
      hours

GSPS expects that staff will use common sense when evaluating if an incident report is
necessary. If in doubt, GSPS expects that the staff will contact their supervisor to discuss or
complete and submit an incident report.




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HOUSEKEEPING

Housekeeping: In order to maintain low operating expenses for the purpose of maintaining
higher programmatic budget, Gryphen Specialty Products and Services conducts its own
housekeeping on a daily basis. With the cooperation of all employees, it is essential to keep the
premises presentable during working hours. Since the all sites operate as an "open house," where
visitors pass through or are exposed to work areas, it is important to maintain a neat and orderly
appearance at all times. While all staff are required to help maintain a clean center, Site
Managers will be held responsible for ensuring that the guidelines and rules below are followed.

The following guidelines and rules should be noted:

       1. All employees are responsible for cleaning up after themselves in the coffee/lunch
       areas.
       2. Coffee or beverage spills should be cleaned up immediately.
       3. Employee cooperation is requested in discarding of all trash and keeping the
       refrigerator free of spoiled food.
       4. Personal items should be kept in designated areas.
       5. Program, office and cleaning supplies should be kept stocked and organized at all
       times.
       6. Floors should be vacuumed, swept or mopped each work day depending on the type of
       flooring present.
       7. All bathrooms should be stocked with all necessary paper products and soap and
       regularly cleaned each week. This would include sanitizing the sink and toilet.
       8. Surfaces that collect dust should be dusted each week.
       9. Clutter of any kind should be discouraged. If organizational supplies are required to
       meet this requirement, staff and/or site managers should obtain said supplies or order
       them via the monthly supply order and submit said order to their department head.




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BREAKS AND MEAL TIMES

Definition as directed by the U.S. Department of Labor (DOL) and the State of Arizona:

Breaks and lunch time off are periods of time, specified by GSPS, during which employees are
not actively working on the job. Employees use break time, which generally lasts from 5 – 20
minutes per four hours worked, to eat, visit the restroom, read, talk with friends, smoke, and
handle personal business.

The U.S. Department of Labor (DOL) has no requirements for employer supplied breaks and
lunch free time at work. However, if the employer does supply coffee breaks away from the job,
the employer is required to count these hours as compensated. They also count toward the
accumulation of hours eligible for overtime payment. .

Meal periods, that typically last from 30 – 60 minutes, during which an employee eats breakfast,
lunch, or dinner, are looked at differently by the DOL and various states. Lunch or meal breaks
are not considered to be work time by the DOL and are not compensable, unless at the
employer’s discretion or unless required by state law.

Non-exempt employees are most often assigned lunch times. Exempt employees take their hour
when they find convenient time.

Employers do not need to permit employees to leave the work premises if they are otherwise
completely freed from duties during the meal period.

Arizona does not require its employers to provide its employees with a mandatory break, but
employers may voluntarily provide its employees with break periods and lunch periods. This
information was provided by the Industrial Commission of Arizona.

PROCEDURE
Any employee working more than 4 hours will be provided 2 fifteen minute breaks. These
breaks should be taken separately unless otherwise approved by your supervisor.

As a result of the work done, GSPS requires working lunches from its direct service staff in order
to accommodate the needs of program participants. Deviations from this policy is subject to
approval by the site manager. Requests for non-working lunches should be requested in
frequently, if requested at all.




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