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2024 Team Member Handbook

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T able of Contents

100 A WELCOME MESSAGE -----------------------------------------------------------100-1


101 Team Member Handbook Definitions----------------------------------------100-2
102 Team Member Handbook Disclaimer----------------------------------------100-2
103 Purpose of Team Member Handbook ---------------------------------------100-3
104 Mission Vision and Values ------------------------------------------------------100-4

200 EMPLOYMENT CLASSIFICATIONS ------------------------------------------200-1


201 Full-Time Team Members ------------------------------------------------------200-1
202 Part-Time Team Member -------------------------------------------------------200-1
203 Supplemental/Seasonal Team Members -----------------------------------200-1
204 Exempt Team Members ---------------------------------------------------------200-1
205 Non-Exempt Team Member----------------------------------------------------200-1

300 EMPLOYMENT POLICIES--------------------------------------------------------300-1


301 Employment-at-Will ---------------------------------------------------------------300-1
302 Hiring Practices --------------------------------------------------------------------300-1
303 Onboarding Period ----------------------------------------------------------------300-2
304 Performance Appraisals ---------------------------------------------------------300-3
305 Promotions and Transfers ------------------------------------------------------300-3
306 Separation from Employment --------------------------------------------------300-4

400 COMPANY AND TEAM MEMBER RECORDS -----------------------------400-1


401 Confidentiality ----------------------------------------------------------------------400-1
402 Personnel Records ---------------------------------------------------------------400-2
403 Electronic Documents Retention ----------------------------------------------400-3
404 The SHIELD Act -------------------------------------------------------------------400-3
405 Electronic Monitoring Law ------------------------------------------------------400-4
406 Records Disposal -----------------------------------------------------------------400-5
407 Outside Requests for Information---------------------------------------------400-5

500 COMPLIANCE POLICIES ---------------------------------------------------------500-1


501 Equal Employment Opportunity -----------------------------------------------500-1
502 Anti-Harassment and Sexual Harassment ---------------------------------500-4
503 Complaint Procedure and Investigations -----------------------------------500-8

600 OPERATIONAL POLICIES -------------------------------------------------------600-1


601 Work Schedules -------------------------------------------------------------------600-1
602 Meal and Break Periods ---------------------------------------------------------600-1
603 Business and Travel Expenses -----------------------------------------------600-2
604 Remote/Distributed Work Policy ----------------------------------------------600-4
605 Nursing Mothers Accommodation --------------------------------------------600-8
606 Pets in the Workplace ------------------------------------------------------------600-9
700 ATTENDANCE, TARDINESS AND LEAVES OF ABSENCE ----------700-1
701 Attendance Leave/Tardiness---------------------------------------------------700-1
702 Time Records ----------------------------------------------------------------------700-3
703 Jury and Witness Duty -----------------------------------------------------------700-4
704 Military and Reserve Leaves ---------------------------------------------------700-5
705 Military Spousal Leave -----------------------------------------------------------700-6
706 Bereavement Leave --------------------------------------------------------------700-6
707 Family and Medical Leave Act (FMLA) --------------------------------------700-7
708 New York Paid Family Leave ------------------------------------------------ 700-12
709 Leaves of Absence ------------------------------------------------------------- 700-15
710 Time Off to Vote ----------------------------------------------------------------- 700-15
711 Time Off to Donate Blood or Bone Marrow ------------------------------ 700-15
712 Volunteer Emergency First Responders ---------------------------------- 700-16

800 COMPENSATION -------------------------------------------------------------------800-1


801 Pay Rates and Pay Increases -------------------------------------------------800-1
802 Overtime -----------------------------------------------------------------------------800-1
803 Payroll Period and Payday -----------------------------------------------------800-2
804 Payroll Deductions ----------------------------------------------------------------800-2

900 TEAM MEMBER BENEFITS -----------------------------------------------------900-1


901 Team Member Benefits Administration -------------------------------------900-1
902 Medical Insurance-----------------------------------------------------------------900-2
903 Dental Plan--------------------------------------------------------------------------900-2
904 Vision Insurance -------------------------------------------------------------------900-3
905 Continuation of Insurance Benefits -------------------------------------------900-3
906 Section 125 Plan ------------------------------------------------------------------900-5
907 Health Savings Accounts -------------------------------------------------------900-5
908 Flexible Spending Accounts ----------------------------------------------------900-6
909 Life Insurance ----------------------------------------------------------------------900-7
910 Retirement Plan--------------------------------------------------------------------900-7
911 Paid Time Off (PTO)--------------------------------------------------------------900-7
912 Paid Sick Leave (non-full-time team members) ---------------------------900-9
913 Holidays---------------------------------------------------------------------------------- 10
914 Disability Coverage ------------------------------------------------------------- 900-11
915 Workers' Compensation ------------------------------------------------------- 900-12
916 Unemployment Insurance----------------------------------------------------- 900-13
917 Social Security and Medicare ------------------------------------------------ 900-13
918 Safety Shoe Program ---------------------------------------------------------- 900-13
919 Team Member Purchase Policy --------------------------------------------- 900-13
920 Team Member Assistance Program --------------------------------------- 900-14
921 Recognition Awards ------------------------------------------------------------ 900-14
922 Team Member Referral Program ------------------------------------------- 900-14
923 Wellness Center ----------------------------------------------------------------- 900-16

1000 PERSONAL CONDUCT ------------------------------------------------------ 1000-1


1001 Personal Appearance ------------------------------------------------------- 1000-1
1002 Misrepresentation ------------------------------------------------------------ 1000-2
1003 Substance Free Workplace ----------------------------------------------- 1000-3
1004 Outside Employment -------------------------------------------------------- 1000-5
1005 Driving on Company Business ------------------------------------------- 1000-5
1006 Personal Conduct ------------------------------------------------------------ 1000-7
1007 Corrective Discipline -------------------------------------------------------- 1000-8
1008 Fraternization------------------------------------------------------------------ 1000-9
1009 Ethics ---------------------------------------------------------------------------- 1000-9
1010 Conviction Notification ---------------------------------------------------- 1000-10

1100 COMPANY PREMISES AND WORK AREAS ------------------------- 1100-1


1101 Company Property ----------------------------------------------------------- 1100-1
1102 Personal Belongings -------------------------------------------------------- 1100-1
1103 Work Areas -------------------------------------------------------------------- 1100-2
1104 Parking -------------------------------------------------------------------------- 1100-2
1105 Smoking ------------------------------------------------------------------------ 1100-2
1106 Charitable Solicitation and Distribution --------------------------------- 1100-3

1200 SAFETY AND SECURITY --------------------------------------------------- 1200-1


1201 Safety Program --------------------------------------------------------------- 1200-1
1202 Accidents/Injury --------------------------------------------------------------- 1200-1
1203 Building Evacuation --------------------------------------------------------- 1200-2
1204 Infectious Disease Control ------------------------------------------------- 1200-2
1205 OSHA --------------------------------------------------------------------------- 1200-5
1206 Building/Campus Security ------------------------------------------------- 1200-5
1207 Identification Badge --------------------------------------------------------- 1200-5
1208 Visitors -------------------------------------------------------------------------- 1200-5
1209 Restricted Areas -------------------------------------------------------------- 1200-6
1210 Workplace Violence --------------------------------------------------------- 1200-6
1211 Security Inspections --------------------------------------------------------- 1200-6
1212 Safe Quality Food (SQF) Certification ---------------------------------- 1200-7

1300 COMMUNICATION AND TECHNOLOGY------------------------------- 1300-1


1301 Team Member Questions and Concerns ------------------------------ 1300-1
1302 Team Member Communications ----------------------------------------- 1300-1
1303 Use of Electronic Communications Systems and Equipment ---- 1300-1
1304 Social Media ------------------------------------------------------------------- 1300-4
1305 Telephone/Wireless Device Usage ------------------------------------- 1300-5
1306 Mail------------------------------------------------------------------------------- 1300-6
1307 Team Member Suggestions ----------------------------------------------- 1300-6
1308 Customer and Media Relations ------------------------------------------ 1300-6
1309 Internet Usage ---------------------------------------------------------------- 1300-7
1310 Email Use ---------------------------------------------------------------------- 1300-9

ADDENDUM A – NY HERO ACT -------------------------------------------------------------- 1


100 A Welcome Message

Dear New Team Member:

Welcome to G&C Foods. You are now a part of an organization that has a culture which is
very unique and to which you have very likely never been exposed to before, it will hopefully
be a refreshing experience for you. It is also my hope, and the hope of senior management
that you will embrace and become part of the culture that makes up our company!

G&C Foods has for over thirty years been providing quality distribution services to the
perishable food industry, and our ability to attract and keep the most talented people has
taken us to where we are today, at the very pinnacle of the Food Re-Distribution Industry.
You are the latest in a long line of quality people who have joined our organization, I have
every expectation that you will be up to the challenge.

We are constantly striving to find ways to improve our onboarding and on-boarding process
because we feel that how you are introduced will be critical to your future success here at
G&C. As you go through the next several days of onboarding feel free to ask questions, make
observations, but most importantly take advantage of the learning experience that it is meant
to be.

As I said at the beginning, you have now become part of a very unique company, one that
places value on every individual, yet at the same time believes that only by coming together
as a team can we ever hope to be successful. In order for that to happen you will have to
commit to becoming part of that team, to become a person who “cares” about doing the best
in everything that you do each day, we all have each other’s back and no one here is alone.
We are not perfect, we still struggle to get where we need to be sometimes, but every day we
work at it and get a little bit better, and that is my commitment to you. If you are ready to
make that same commitment, then your future here is unlimited so enjoy and come and grow
with us.

Welcome aboard!
Rich Chapman, President

G&C Foods 100-1 January 2024


101 Team Member Handbook Definitions

For the purpose of this team member handbook, the following terms are defined as follows:

G&C Food Distributors, Inc. known as G&C Foods or the Company.

Corporate Office - The corporate office is located at 3407 Walters Road, Syracuse, New York 13209
and serves as the base of operations for the Distribution, Warehousing, Accounting, Customer
Service, Human Resource, Purchasing, Sales Departments and Marketing.

Anniversary Date - The date of a team member's first paid day of employment (hire date) with G&C
Foods. This date is used to compute certain team member benefits. A team member may be offered
employment prior to their hire date.

Team Member - An individual who is employed by G&C Foods as a full-time or supplemental worker
as defined in Section 200 Employment Classifications. Independent contractors and individuals
employed by temporary employment agencies who are assigned to work at G&C Foods on a short-
term basis are not considered team members.

Immediate Family Member - A team member's spouse, domestic partner, child, stepchild, parent,
stepparent, grandparent, grandparent-in-law, grandchild, sibling, step sibling, mother-in-law, father-
in-law, sister-in-law, brother-in-law, daughter-in-law, son-in-law, and any other member of the team
member's household. *This includes a married spouse of the same or opposite sex.

Senior Management Team (SMT) – individuals selected as a team to perform the highest level of
management in the organization.

Mid-Level Managers - an individual who has been designated by SMT to be responsible for planning
and directing the work of a group of individuals, monitoring their work, and taking corrective action
when necessary.

Supervisor - An individual who has been designated by the Company to assign, direct, and/or
appraise the work of a designated group of team members.

102 Team Member Handbook Disclaimer

Not an Employment Contract - The policies, procedures, and rules set forth in this team member
handbook are general guidelines only and are not meant to be all-inclusive. The team member
handbook should therefore not be interpreted as forming an express or implied contract of
employment.

The Company reserves the right, at its sole discretion, to change, modify or rescind any section of
this Team member Handbook at any time with or without cause or notice, except for the employment-
at-will policy or where prohibited by law.

Policy Exceptions - The team member handbook should not be interpreted as a guarantee that the
policies discussed in it will be applied in all cases. At its sole discretion, the Company may make
exceptions to its policies from time to time for legitimate business reasons.

Policy Interpretation - The Company reserves the right to make the final decision as to the
interpretation of all information presented in this team member handbook.

G&C Foods 100-2 January 2024


Government Regulations - In the event that a federal, state, or local regulation conflicts with any
provision contained in this team member handbook, the regulation shall prevail, and the provision
deemed amended to the extent necessary to comply with said regulation.

Protected Activity Under the NLRA - Conduct that is protected under the National Labor Relations
Act is not prohibited by this team member handbook or the policies of G&C Foods. Nothing in this
team member handbook is intended or will be interpreted or applied, to interfere with, restrain, or
prohibit team members from exercising their rights protected under federal and state laws, including
the labor law right to discuss wages, hours or other terms and conditions of employment and to
engage in other concerted, protected activity. This team member handbook is intended to comply
with all federal, state, and local laws and regulations, and will not be interpreted, applied, or enforced
in a manner that violates such regulations.

103 Purpose of Team Member Handbook

Purpose - The purpose of this team member handbook is to familiarize team members with the
Company and to communicate important information about many of the personnel policies that affect
employment and guide daily operations. The team member handbook provides an overview of the
Company's policies that relate to rules, regulations, procedures, practices, compensation, and team
member benefits.

Previous Team Member Handbook - Unless otherwise notified, this team member handbook
supersedes and replaces any previous team member handbook issued by the Company and verbal
or written policy statements.

Team member Handbook Updates - Every effort is made to keep the information in this Team
member Handbook up to date. From time to time, policies may be added, revised, or revoked before
a written revision is made to the Team member Handbook. A team member is required to abide by
updated policies communicated by the Company.

Team Member Responsibility - The team member handbook answers many questions about
employment with G&C Foods. Each team member is therefore expected to read, understand, and
comply with all provisions of this team member handbook and to retain it for future reference.

Questions - A team member is encouraged to ask the Human Resource Department questions
regarding the information provided in this team member handbook.

G&C Foods 100-3 January 2024


104 Mission Vision and Values

OUR MISSION:
At G&C Foods, our people make all the difference, driving innovative solutions to meet each
customer’s unique food industry needs.

OUR VISION:
To transform the food industry, one customer, one innovative solution at a time.

OUR VALUES:
• Service Excellence
• Agility
• Invest in Our People
• Transparency & Empowerment
• Customer-Centered Solutions
• Community Enrichment

OUR SERVICE PHILOSOPHY:


We believe that our team’s relentless commitment to excellence unifies us in our shared desire to
serve, constantly innovating in ways that meet our customers’ and suppliers’ unique food industry
needs…getting people on all sides what they need, when they need it.

OUR EMPLOYEE VALUE PROPOSITION:


G&C Foods is a food industry leader with a rich history and a reputation for significant innovation.
We are dedicated to the success of our Associates, and offer competitive pay and benefits
combined with opportunities to learn, grow, and advance throughout the company. As a member of
the G&C team, you can look forward to being part of an organization that cares about its people,
shares information transparently, and values autonomy – allowing you to plan your day and make
decisions that support the best results for our customers and the team. We encourage fun and
camaraderie and place an emphasis on enriching our communities. Come join our growing team
and be part of something special!

G&C Foods 100-4 January 2024


200 EMPLOYMENT CLASSIFICATIONS

Policy Statement - Each team member is classified as full-time, part-time, or supplemental. Each position
is also designated as exempt or non-exempt from federal and New York State minimum wage and overtime
provisions. Team members are notified of their employment classification and exempt/non-exempt status at
the time of hire and if changed during employment.

For the purpose of this team member handbook, the following terms are defined as follows:

201 Full-Time Team Members

A full-time team member is a team member who is regularly scheduled to work 30 hours or more per
week.

202 Part-Time Team Member

A part-time team member is a team member who is regularly scheduled to work less than 30 hours
per week.

203 Supplemental/Seasonal Team Members

A supplemental/seasonal team member is a team member who is hired for an unspecified period of
time. Supplemental/Seasonal team members may work part-time or full-time hours. Employment
beyond any initially stated period does not imply a change in employment classification nor does the
Company guarantee employment for any set period of time.

204 Exempt Team Members

An exempt team member is a team member whose position meets specific tests established by the
Fair Labor Standards Act (FLSA) and applicable state law for an exemption from federal and state
overtime provisions. In accordance with these regulations, an exempt team member is not eligible
for overtime compensation.

205 Non-Exempt Team Member

A non-exempt team member is a team member who is subject to federal and state minimum wage
and overtime provisions. In accordance with such regulations, a non-exempt team member is paid
the current statutory minimum wage or higher and overtime compensation when more than 40 hours
are worked during a workweek.

Non-exempt team members may be paid on an hourly, salary, piece rate, or commission basis, etc.
as long as their weekly compensation equals at least minimum wage for all hours worked and
overtime is paid for hours in excess of 40 in a workweek.

G&C Foods 200-1 January 2024


300 EMPLOYMENT POLICIES

301 Employment-at-Will

Policy Statement - G&C Foods follows the practice of employment-at-will. The Company does not
promise or guarantee employment for any specified period of time. Either a team member or the
Company may end the employment relationship at any time, for any reason, with or without cause
or notice.

Employment Contract - No manager, supervisor or other representative of G&C Foods except the
President has the authority to enter into a binding employment contract. Any such employment
contract must be in writing and signed by both the President and the team member. No other oral or
written statements or representations can limit G&C Foods right to terminate employment at-will.

302 Hiring Practices

Selection Process - G&C selects and hires individuals on the basis of many factors including, but
not limited to, their ability, experience, education, skills, and cooperative spirit. The selection process
includes an online application, personal interviews, reference, and background checks.

Employment Application - All applicants are required to complete an Employment Application.


Misrepresentations or omissions on an Employment Application may remove an applicant from
consideration for employment, or if already hired, subject the team member to termination of
employment.

Verification of Employment Information - Prior to making an offer of employment, the Company


may conduct a job-related verification of the data provided on the employment application (i.e., prior
employment verification, education confirmation, and other verification of statements and skills
claimed on the application and/or the resume.

Background Checks - After making a conditional offer of employment, the Company may conduct
drug screening, criminal background, and/or credit checks, as permitted by law. Third-party services
may be hired to perform these checks. All offers of employment and continued employment are
contingent upon a satisfactory background check.

Criminal Convictions - A criminal conviction does not necessarily bar an applicant from
employment. Employment decisions based on criminal convictions take into consideration many
factors, including but not limited to, the public policy of New York State to encourage the employment
of individuals previously convicted of criminal offenses, the specific duties and responsibilities
necessary for the position sought, the extent to which the offense bears upon the ability of the
applicant to perform the duties and responsibilities of the particular job sought, the seriousness of
the offense, length of time since the conviction, the age of the applicant at the time of the criminal
offense, and information produced by the applicant indicating rehabilitation and good conduct.

Former Team Members - A former team member may be considered for re-employment with G&C
Foods based on the reason for the previous separation and the Company's current business needs.
A team member who resigns without giving or completing the requested notice or who is terminated
for misconduct is generally not considered for re-employment.

If rehired, the individual is considered a new team member as of the date of re-employment and a
new onboarding period must be completed. Eligibility for group insurance programs is the same as
for all new hires. Prior service under the 401(k) plan is restored in accordance with government
regulations and the terms of the plan.

G&C Foods 300-1 January 2024


With the exception of the 401(k) plan, there is no credit for prior service for purposes of seniority or
paid leave benefits.

Minors - Individuals who are 14 to 17 years of age may be employed to work for the Company in
accordance with federal and state regulations regarding child labor. Due to the nature of the work
performed, individuals who are 14 to 17 years of age are not hired to work in safety sensitive
positions.

Relatives or Domestic Partners - Employment of relatives and domestic partners is permitted,


except in circumstances where he or she would be directly or indirectly supervised by a relative, or
in a situation where influence could be exerted on future decisions concerning the status of
employment, promotion, or compensation.

303 Onboarding Period

Policy Statement - All new team members participate in an onboarding period that is conducted by
the Human Resource Department, Department Trainer, and Safety Manager. The purpose of the
onboarding period is to welcome new team members and to familiarize them with the Company and
their jobs. It also gives a team member's supervisor the opportunity to evaluate the team member's
job performance and potential for development in the position so that any concerns can be addressed
with the team member.

Length - The onboarding period generally extends for the first 90 days of employment. The Company
reserves the right to extend or shorten the onboarding period at its sole discretion.

Topics Covered – Topics generally covered during the onboarding period include, but are not limited
to, a tour of the facility, review of this team member handbook, and enrollment in Company-
sponsored benefits, if applicable. In addition, the team member's supervisor is responsible for
introducing the team member to coworkers, scheduling on-the-job training, and reviewing the job
description and performance requirements of the position.

Performance Appraisal - Throughout the onboarding period, the team member's supervisor
monitors and evaluates the team member's job performance, work habits, attendance, cooperation,
and potential for development in the position. Any problems or deficiencies are normally addressed
with the team member. It is the policy of G&C Foods that regular ongoing feedback be given to team
members by their supervisor and manager. The manager also determines if continued employment
is appropriate.

Employment Contract - The onboarding period is not a contract of employment for any set period
of time, nor does completion of the onboarding period guarantee continued employment or alter the
at-will employment relationship.

Promotions and Transfers- A team member who is transferred or promoted after the completion
of 6 months of service within the Company is not required to complete a new onboarding period for
this new position. The team member remains eligible for all applicable Company-sponsored benefits
during the onboarding period. If a team member does not perform satisfactorily in the new position,
the team member may be returned to the original job held, if a vacancy exists, or is subject to
termination, at the Company's sole discretion.

G&C Foods 300-2 January 2024


304 Performance Appraisals

Policy Statement - Regular performance evaluations are an important aspect of professional


relationship building between team member and supervisor as well as an opportunity for open
dialogue and discussion of goal development. The performance review will provide the team
member with an appraisal of his/her progress, success, and/or shortcomings in meeting job
expectations. It is designed to provide guidance to the team member in career development, to
assist the supervisor in understanding the team member's interests and concerns, set goals, and to
provide for a candid exchange of ideas.

Employment Decisions - A team member's performance appraisal can be a factor in decisions


affecting transfer, promotion, compensation, layoff, and disciplinary action. However, performance
appraisals do not guarantee continued employment or otherwise alter the at-will nature of the
employment relationship.

Wage Adjustments - A team member does not automatically receive a pay increase at the time of
a formal appraisal. Any pay increase received is based on merit and financial capability of the
Company.

Frequency - Thereafter, informal performance discussions occur on a regular basis throughout the
year. Formal performance appraisals are generally conducted on an annual basis. Formal appraisals
may occur more or less frequently at the discretion of the team member's supervisor. In addition,
informal performance discussions occur on a regular ongoing basis throughout the year.

Leaves of Absence - The annual performance appraisal is based on 12 months of active service. If
a team member's service with the Company is interrupted by a leave of absence or temporary layoff,
the performance appraisal is generally not conducted on the team member's anniversary date but is
delayed by the length of the absence.

Promotions and Transfers - A written performance appraisal is generally conducted at the time a
team member is promoted or transferred to a new position. Thereafter, a team member’s appraisal
date is adjusted to the anniversary date of the promotion or transfer.

305 Promotions and Transfers

Policy Statement - G&C Foods encourages the career development and growth of team members
through promotions and lateral transfers to other positions within the Company for which they are
qualified.

Job Vacancies/Postings - When there is a job vacancy, management will consider current team
members who possess the minimum qualifications required for the position. With the exception of
department/position restructuring, positions are posted internally. Positions may also be posted
externally. A team member who is interested in being considered for a job vacancy should notify the
team member's supervisor and the Human Resource Department. In order to ensure the most
qualified person is hired, the Company reserves the right to recruit external applicants for any job
vacancy at any time.

The purpose of the Job Posting Policy is to ensure all team members are informed of open positions
and can apply for those they are qualified for. G&C Foods believes in promoting from within when
possible and is committed to employing the best candidates for approved positions and engaging in
effective recruitment and selection practices in compliance with all applicable employment laws. We
provide equal employment opportunity to all applicants and team members.

G&C Foods 300-3 January 2024


Eligibility Requirements - To apply for a promotion or transfer, a team member must meet the
following eligibility requirements:

• Possession of the minimum qualifications of the position as indicated on the job posting notice;
and
• A satisfactory work and attendance record.

Exceptions to the above requirements may be considered on a case-by-case basis.

Application and Posting Procedure - Once an open position is approved for recruitment, HR will
generate a job announcement and post it on the ADP Career Center page. Appropriate external
recruitment sources will vary depending on the position and will be determined by HR and the hiring
manager.

The position will be posted internally for up to 2 weeks, to the discretion of the hiring manager, during
which time eligible team members may apply ahead of external candidates. In some cases, external
recruiting may take place simultaneously to expedite the process as business needs require. Internal
candidates may or may not be given preference depending on the circumstances. A team member
who is interested in applying for a posted position should complete an application on the ADP Career
Center. Candidates are required to notify their supervisor or manager when applying for another
position. Each job posting will have a closing date by which time applications must be received to be
considered for the position.

All internal applicants will receive notice from HR or their manager as to whether they will be
interviewed for the position. The supervisor or manager will be notified should you become a final
candidate. If hired for the position, the current and the new supervisor/manager will work together to
determine an appropriate transfer date.

306 Separation from Employment

Notice of Resignation - A team member who elects to resign or retire from employment with G&C
Foods is asked to submit a written notice to the team member's supervisor two weeks before the
date of resignation/retirement is to be effective. Supervisory/Management staff are asked to give 4
weeks written notice to Human Resources. The resignation letter should include the reason for
resigning and the date the resignation is to take effect. If a team member provides more notice than
requested, the Company will determine whether the additional notice is necessary for efficient
operations.

A team member is generally not allowed to rescind a verbal or written notice of resignation once it
has been submitted to the team member’s supervisor/manager.

Completion of Notice Period - When a resignation notice is submitted, the Company reserves the
right to provide a team member with two weeks pay in lieu of notice.

Use of Paid Benefits - A team member will generally not receive authorization to use credited,
unused PTO during the notice period unless the time off was approved before the Company received
the notice of resignation.

To receive PTO during the notice period, a team member may be required to provide verification of
the illness from the team member's health care provider.

Exit Interviews - Exit interviews are generally conducted by the Human Resource Department in
order to discuss cancellation of team member benefits, COBRA eligibility, return of Company

G&C Foods 300-4 January 2024


property, and/or G&C Foods’ policy regarding employment references. The exit interview also
provides a team member the opportunity to ask any employment-related questions and give
suggestions, concerns, and constructive recommendations about the Company and its policies.

Return of Company Property - All Company property in the team member's possession, such as,
but not limited to, the team member's copy of this team member handbook, customer and Company
files (i.e., electronic and paper files), equipment, name badge, keys, credit cards, fuel cards, etc. and
Company issued electronic devices must be returned to the team member's supervisor in good
working order when requested, but no later than the team member's last day of work. If a team
member fails to return any Company property, the Company may initiate legal proceedings.

Team member Lockers - Any personal items left in your G&C locker will be maintained for 30 days
and then discarded. Please contact HR to arrange a time to pick up your personal items within 30
days from your termination date. G&C is not responsible for the contents of your locker past 30 days.

Credited Benefits - Refer to Section 900 Team member Benefits to review the PTO policies for
information regarding forfeiture and/or payment for benefits at the time of separation from the
Company.

Final Paycheck - A team member's final paycheck for all hours worked is provided on the next
regularly scheduled payday after the team member's last day of work. The final paycheck will be
issued in the same manner as your previous payments and will include payment for credited, unused
PTO if applicable. Former team members are not permitted to be on premises without prior approval
of Human Resources or their former manager.

G&C Foods 300-5 January 2024


400 COMPANY AND TEAM MEMBER RECORDS

401 Confidentiality

Policy Statement - All Company and customer information is to be treated with discretion and
confidentiality. A team member is prohibited from discussing, photocopying, duplicating, recording,
or otherwise revealing G&C’s proprietary information or customer information that is not generally
known to the public in any form to anyone outside the Company. Disclosure of confidential or
sensitive information via any software application or text message is prohibited – this includes taking
or sending pictures of such information. The proper use and disclosure of sensitive information
applies to both current and former team members.

Confidential Company Information - All records and files maintained by the Company are
confidential. This confidential information includes, but is not limited to personnel records, trade
secrets, and information relating to customers, products, processes, know-how, designs, drawings,
formulas, test data, marketing data, accounting records, pricing information, business plans and
strategies, training materials, negotiations, contracts, sales reports, inventions, discoveries, and any
other proprietary information. Confidential information does not include a team member’s own
compensation or other terms or conditions of employment if the team member chooses to disclose
such information.

Confidential information may be in physical form or may be learned through conversations with
others regarding G&C Foods or its customers. Confidential information obtained as a result of
employment with G&C Foods and from contact with customers is considered proprietary and can
only be used in the course of employment with the Company.

All company information, whether generated through a personal or corporate device, belongs to the
employer, not to the team member, and is subject to company policies limiting use and disclosure of
such information. Confidential information should only be shared with other team members within
the Company who have a business need to receive such information. Confidential information should
not be disclosed to external parties, including customers, family members, and friends, except as
authorized by the Company or as required or allowed by government regulation.

Company Property - All confidential information and products developed by a team member, such
as computer programs, designs, or inventions, remain the sole property of G&C Foods.

Personal Identifying Information - The Company will take reasonable measures to ensure the
privacy and confidentiality of its team members’ Personal Identifying Information. The Company does
not publicly post, display, or share a team member’s personal identifying information with the general
public nor are team members allowed to divulge such information. Personal Identifying Information
includes, but is not limited to, any information regarding an individual which, because of name,
number, personal mark, or other identifier, can be used to identify said person in combination with
any one or more of the following: birthdate, social security number, driver's license number, non-
driver identification card number, mother's maiden name, home address or telephone number,
personal e-mail address, financial services or banking account number or code, electronic serial
number, credit or debit card number, password, security questions and answers, unique biometric
information, or personal identification number.

Security and Removal of Confidential Information - A team member is responsible for properly
securing and maintaining confidential information obtained or learned during employment. This
includes Company information stored on flash drives, laptops, and wireless devices, as well as home
computers that have been approved to be used to conduct G&C Foods business. A team member
must exercise caution when using a wireless device for business purposes in public areas to ensure

G&C Foods 400-1 January 2024


that confidential information cannot be viewed by others or that equipment is not stolen.
Unauthorized removal of confidential information from Company premises is prohibited.

Confidentiality/Non-Disclosure Agreement - As a condition of employment, a team member may


be required to sign a confidentiality/non-disclosure agreement at the time of hire or at the time of
promotion or transfer into certain positions of the Company.

Confidentiality Breach – A team member is responsible for reporting any breach of confidential
Company or team member information to the Human Resource Department immediately.

Separation from the Company - The obligation to maintain confidential Company information
remains in effect after a team member separates from employment with G&C Foods.

402 Personnel Records

Policy Statement - G&C Foods maintains records and/or confidential personnel files on team
members, former team members, and applicants in accordance with government recordkeeping and
reporting requirements. Each team member is responsible for completing any employment-related
forms that are required by government regulation or necessary for efficient Company operations.

Control and Review of Personnel Files - Team member personnel records and medical
information is confidential and is maintained and controlled by Human Resources. Access to
personnel files is limited. A supervisor may only review a team member's personnel file if there is a
business reason to review the record. Based on the reason for the request, a current team member
may review the contents of the team member’s own personnel file by submitting a written request to
the Payroll Administrator. The Payroll Administrator or an authorized member of management must
be present when the personnel file is reviewed. A team member may not copy, remove, or place any
material in the team member’s personnel file.

Control of Medical Records - A separate confidential medical file is maintained on all team
members by Human Resources. Any protected health information (PHI) that is maintained by the
Company is confidential, and only Company officials who have a business need to know have access
to these medical records. Information can only be released to others with the expressed, written
authorization of the team member or if the Company receives a court order to do so.

Employment Eligibility Verification – G&C Foods does not knowingly hire or continue to employ
undocumented persons who are not authorized to work in the United States. All team members
must complete and sign Section 1 of Form I-9 and provide documents to prove the team member’s
identity and eligibility to work in the United States on the first day of work. Documentation is subject
to verification. I-9 Forms are confidential and are maintained separately from team member
personnel files in a secure location.

Changes in Status - A team member is responsible for ensuring that G&C Foods receives all
information needed to maintain up-to-date personnel records. A team member may be required to
provide written notification to the Payroll Administrator of a change in name, address, telephone
number, emergency contact, insurance beneficiary, insurance enrollees, tax withholding status, or
marital/dependent status. This list is not all-inclusive. The Company is not responsible for any errors
that result from a team member’s failure to inform the Company of changes in this information in a
timely manner.

Rhison Williams
G&C Foods 400-2 January 2024
403 Electronic Documents Retention

Policy Statement – It is Company policy that team members retain electronic documents that are
needed for business purposes or to comply with government regulations.

Potential Litigation - A team member is responsible for saving any electronic documents that are
needed for legal and/or business reasons. If a team member believes documents may be relevant
to potential litigation or the team member has been notified of pending litigation, all applicable
electronic documents must be saved and preserved in their natural form until informed by
management that they are no longer needed.

Retention Period - The retention period for electronic documents depends on the subject matter
and must be looked at on a case-by-case basis.

Method of Retention - E-mails that are to be retained should be printed and saved in the appropriate
file. Text messages can be saved as a picture/screenshot. If any electronic documents that are
stored on laptops, wireless devices, and/or home computers are to be retained, they should be
forwarded to a team member’s business e-mail so that they can be saved on the Company’s network
server.

404 The SHIELD Act

Policy Statement - In accordance with New York State regulations, G&C complies with the "Stop
Hacks and Improve Electronic Data Security" (SHIELD) Act, implemented to broaden New York’s
security breach notification requirements, and requiring businesses to implement safeguards for the
"private information" of New York State residents. The SHIELD Act pertains to all Company
communication, storage, and transmission systems used by G&C (see Use of Electronic
Communications Systems and Equipment policy in this Team member Handbook).

Safeguards to Protect Private Information - It is the policy of G&C that all private information shall
be protected against unauthorized access to the information collected, including that held in
electronic format on G&C computer systems.

G&C has established and maintains administrative, electronic, and physical safeguards to protect
the security, confidentiality and integrity of private information, including an individual's name, social
security number, driver’s license number, non-driver identification card number, mother’s maiden
name, home address or telephone number, credit or debit card number, financial account number
(with or without security code, as long as an unauthorized person could gain access to the account),
unique biometric information, and usernames or e-mail addresses with a password that permit
access to any online account.

G&C has implemented reasonable safeguards to protect sensitive electronic information, consistent
with our Company size, industry, and level of risk to our team members and consumers. Safeguards
include but are not limited to specific policies and procedures, vendor management and oversight,
restriction of access to private information, designation of at least one person to coordinate cyber
security and breach reporting, team member training, routine risk assessments of data, internal
audits, and annual vulnerability scanning and testing.

Internal Access to Information - Access to private information shall be limited to team members
who have a business-related reason to access such information in the course of normal business
operations. All team members are required to protect private information from inappropriate access
and disclosure.

G&C Foods 400-3 January 2024


Private Information Risk Management and Control Assessment - To identify any reasonably
foreseeable internal and external threats to the security of private information that could result in the
disclosure, misuse, alteration or destruction of private information or systems, G&C will take cyber
security steps as follows:

• Ensure the security of all computer systems so that only trained team members using individually
assigned security codes and passwords can access private information;
• Train and advise all team members of the Company policy with respect to private information;
• Maintain a complete computer backup system to recover private information stored in the system
in the event of damage to or destruction of the system;
• Periodically test the controls, systems and procedures that are in place to safeguard private
information;
• Evaluate the effectiveness of the information security programs and make adjustments
necessary due to changes in technology or changes in business operations;
• Require service providers to safeguard private information; and
• Securely destroy private information within a reasonable amount of time after it is no longer
needed for business purposes.

Notification in the Event of a Data Breach - In case of a breach of private information, G&C will,
in compliance with the protocols of the SHIELD Act, report the breach to the appropriate authorities.

Disciplinary Action - Team members who violate this policy will be subject to disciplinary action, up
to and including termination from employment.

405 Electronic Monitoring Law

Policy Statement - New York State requires private employers to provide notice to team members
of its electronic monitoring practices. Team members may be subject to such electronic monitoring
at any and all times and by any lawful means. Electronic monitoring may include monitoring of:

1. any and all telephone conversations or transmissions (including text messages if on a


Company issued device);
2. electronic mail or transmissions (including team member communication programs); and/or
3. internet access or usage (including social media profiles).
Monitoring may occur on any electronic device or system, including but not limited to a computer,
telephone, company-issued mobile phone, electronic key card, tablet, or any other device that
provides for such communications and usage.

Disciplinary Action - In accordance with the disciplinary provisions in this team member handbook
and in light of the potential implications for the Company and its business practices, including any
regulatory compliance obligations, G&C Foods will take appropriate action against a team member
or team members who are discovered via such electronic monitoring to have violated any established
rules or practices associated with the sending and receiving of electronic communications.

G&C Foods 400-4 January 2024


406 Records Disposal

Policy Statement - The security of all confidential Company, team member, and customer
information is a top priority of G&C Foods. Documents that no longer need to be retained for business
purposes are to be disposed of in accordance with government regulations and Company policy.

Disposal of Paper Documents - Any paper document containing confidential information or


personally identifiable information regarding a team member or customer must be shredded,
destroyed, and/or modified to make it unreadable prior to its disposal.

Disposal of Electronic Documents - A team member should routinely delete outdated or otherwise
unnecessary E-mails and computer files that no longer need to be retained.

407 Outside Requests for Information

Reference Requests - All requests for information regarding current and former team members that
are received from individuals outside the Company must be referred to the Human Resource
Department. No other supervisor or team member is authorized to provide information to any outside
source or to “recommend” or comment on the job performance of a former team member via LinkedIn
or other social media. G&C Foods is not responsible for information provided by an unauthorized
team member.

Employment Verification - The Human Resource Department will verify dates of employment and
position(s) held without the signed consent of the individual.

G&C Foods does not guarantee that it will release employment-related information to an outside
source even with written consent. The Company will provide information that is legally required by
court order or subpoena.

G&C Foods 400-5 January 2024


500 COMPLIANCE POLICIES

501 Equal Employment Opportunity

Policy Statement - G&C Foods is an Equal Opportunity Employer. The Company does not
discriminate and will not tolerate discrimination on the basis of a person's race, religion, creed, color,
sex, age, national origin, citizenship or immigration status, disability, sexual orientation, gender
identity or expression, transgender status, gender dysphoria, marital or familial status, pregnancy,
military status, veteran status, genetic information including predisposing genetic characteristics or
carrier status, arrest or conviction record, domestic violence victim status, or any other protected
class, status, or activity recognized by applicable federal state or local law.

G&C Foods will not prohibit, discipline, discriminate, or retaliate against a team member for
discussing their wages or other terms and conditions of employment with others. However, if a team
member makes the disclosure based on information obtained in the course of performing his or her
essential job functions, they may be subject to disciplinary action, up to and including termination
(i.e., Payroll Clerk revealing another team member’s salary without their permission). Further, a team
member is prohibited from accessing, discussing or disclosing the wages of another team member
without that team member’s permission.

Equal employment opportunity applies to all terms and conditions of employment including, but not
limited to, advertising recruiting, hiring, placement, promotion, disciplinary action, termination, layoff,
recall, transfer, leave of absence, compensation, benefits, training, working conditions and
participation in all Company sponsored social and recreational programs.

New York State Human Rights and Labor Regulations - In compliance with New York State
Human Rights and labor regulations, G&C will not discriminate or retaliate against a team member
or intern for opposing prohibited practices or for filing a complaint, testifying or assisting in a
proceeding brought under the New York State Human Rights Law, including, any of the following:

• Requesting or taking lactation breaks;


• Donating blood or bone marrow;
• Requesting or taking time off from work to vote;
• Wearing a representation of the American flag or displaying an American flag at the team
member’s workstation;
• Engaging in lawful, leisure-time recreational activities outside of working time (e.g., sports,
games, hobbies) unless such activity creates a material conflict of interest;
• Being a member in a union;
• Participating in political activities outside of working time;
• Legally using consumable products, including cannabis in accordance with state law, during non-
working time off G&C premises unless it violates the Company’s substance free workplace or
substance testing policy or affects the team member during working time;
• Being a victim of a crime and requesting time off from work to seek medical attention, assistive
services or counseling related to the violence, to obtain legal services, or to participate in the
legal process related to a domestic violence incident; or
• Grooming and dressing in a manner consistent with the team member’s race or religion, including
but not limited to, religious attire, clothing, facial hair, hair texture and protective hairstyles.

G&C Foods 500-1 January 2024


Workplace Bullying - Repeated inappropriate behavior either direct or indirect, conducted by one
or more persons against another or others in the course of employment, will not be tolerated.
Examples of bullying include but are not limited to:

• Verbal Bullying - slandering, ridiculing or maligning a person or his/her family; persistent name
calling, which is hurtful, insulting or humiliating; using a person as the butt of jokes; abusive and
offensive remarks.
• Physical Bullying - pushing; shoving; kicking; poking; tripping; assault, or threat of physical
assault; damage to a person’s work area or property.
• Gesture Bullying – non-verbal threating gestures; glances which can convey threatening
messages.
• Exclusion – socially or physically excluding or disregarding a person in work-related activities.

Diversity and Fair Treatment - G&C Foods recognizes the rich diversity of its team members and
the varying cultures, backgrounds, and experiences they each bring to the workplace. The Company
is committed to maintaining and promoting a work environment where team members' and
customers' similarities and differences are respected and valued. A team member is expected to
treat coworkers, customers, vendors, suppliers, and other non-team members that the team member
comes in contact with on the job with fairness, dignity, and respect. The Company prohibits a team
member from engaging in any form of discrimination, harassment, or other offensive behavior based
on any of the protected classes or groups listed above.

Discrimination by Others - The Company prohibits team members, vendors, suppliers, visitors,
customers, and any other individual that a team member comes in contact with during the course of
employment from harassing or discriminating against G&C Foods team members based on any
protected class or status.

Americans with Disabilities Act - In compliance with the Americans with Disabilities Act (ADA) and
New York State Human Rights law and related regulations, G&C Foods provides an equal
employment opportunity to applicants and team members with disabilities in regard to all terms and
conditions of employment. The Company does not discriminate against qualified applicants and
team members who have a physical or mental impairment or a record of such impairment. In
addition, the Company does not discriminate based on a person’s relationship or association with an
individual with a disability.

Reasonable Accommodation - G&C Foods does not discriminate against qualified individuals with
disabilities who, with or without reasonable accommodation, can perform the essential functions of
the employment position held or desired. G&C will provide a reasonable accommodation unless it
imposes an undue hardship on the Company. If the need for accommodation is related to pregnancy
or childbirth, the team member’s condition does not need to rise to the level of disability, and
accommodation may be requested even if they can’t perform their essential job functions on a
temporary basis. Any team member with a disability and any pregnant team member who believes
an accommodation is needed should contact the Human Resources Department. The Company
may require medical documentation verifying the requested reasonable accommodation is needed.
When more than one option will satisfy a reasonable accommodation, the Company reserves the
right to choose the accommodation.

G&C Foods 500-2 January 2024


Genetic Information Nondiscrimination Act - GINA prohibits employers and other entities covered
by GINA from using genetic information in making employment decisions or requesting or requiring
genetic information of an individual or family member of the individual, except as specifically allowed
by law. "Genetic information" as defined by GINA includes an individual's or an individual's family
member's genetic tests, the fact that an individual or an individual's family member sought or received
genetic services, and genetic information of a fetus carried by an individual or an individual's family
member or an embryo lawfully held by an individual or family member receiving assistive
reproductive services.

Victims of Domestic Violence - A victim is any person older than 16, married, or a parent
accompanied by the parent’s minor child in a situation where the person or their minor child is the
victim of an act committed by a family or household member that would violate the penal law, and
results in physical or emotional injury or creates substantial risk of physical or emotional harm to the
person or their child. The Company will not refuse to hire, will not discriminate against, nor terminate
a team member solely because they are a victim of domestic violence. Further, no information will
be printed or circulated about someone's status as a victim. The Company will provide reasonable
accommodations to team members who must be absent from work for a reasonable time unless
such accommodation would pose an undue hardship on the employer’s business.

Reproductive Health Decisions – G&C will not access a team member’s personal information
regarding the team member or team member’s dependents’ reproductive health decision-making,
including information related to the decision to lawfully use or access a particular drug, device or
medical service without the team member’s prior written consent. The Company will not require
team members to sign a waiver or other document that would prevent the team member from making
their own reproductive health care decisions, including the lawful use of a particular drug, device or
medical service.

G&C will not tolerate any discrimination or retaliation against team members based on the team
member or their dependents’ reproductive health decision-making, making or threatening to make a
complaint to G&C or any court or agency, or participating in any investigation, hearing or inquiry
related to a potential violation of this policy.

Complaint Procedure - A team member who believes that the actions or words of a team member
or non-team member have violated this policy is required to report the behavior to the Company
immediately. Refer to Policy 503 Complaint Procedure and Investigations for information on filing a
complaint and the Company’s investigation procedures.

Policy Violations - Any team member who violates this policy will be subject to disciplinary action,
up to and including termination. Any vendor, supplier, visitor, customer, or other non-team member
who violates this policy will be subject to remedial action, as determined by management.

G&C Foods 500-3 January 2024


502 Anti-Harassment and Sexual Harassment

Policy Statement - This policy applies to all team members, applicants for employment, paid or
unpaid interns, contractors, vendors, consultants or anyone conducting business with or on behalf
of G&C. Sexual harassment is a form of workplace discrimination that subjects a team member to
inferior conditions of employment due to their gender, gender identity, gender expression (perceived
or actual), and/or sexual orientation and is against the law. Sanctions will be enforced against
individuals engaging in sexual harassment and against supervisory personnel who knowingly allow
such behavior to continue. Sexual harassment and harassment based on any protected
characteristic is strictly prohibited. The Company takes all necessary measures to prevent
harassment in the workplace or, in the event it occurs, to stop the conduct immediately. All team
members have a legal right to a workplace free from sexual harassment, and team members can
enforce this right by filing a complaint internally with G&C, with a government agency, or in court
under federal, state or local anti-discrimination laws (see Legal Protections and External Remedies
section of this policy).

What is Sexual Harassment? - Sexual harassment includes harassment or discrimination on the


basis of sex, gender, sexual orientation, self-identified or perceived sex, gender identity, gender
expression and the status of being transgender. Sexual harassment is not limited to sexual contact,
touching, or expressions of a sexually suggestive nature. It includes all forms of gender discrimination
including gender role stereotyping and treating team members differently because of their gender.

Understanding gender diversity is essential to recognizing sexual harassment because


discrimination based on sex stereotypes, gender expression, and perceived identity are all forms
of sexual harassment. The three most common ways people identify are cisgender, transgender,
and non-binary. A cisgender person is someone whose gender aligns with the sex they were
assigned at birth – generally, the binary of male or female. A transgender person is someone
whose gender is different than the sex they were assigned at birth. A non-binary person does not
identify exclusively as a man or a woman. They might identify as both, somewhere in between,
or completely outside the gender binary. Some may identify as transgender, but not all do.
Respecting an individual’s gender identity is a necessary first step in establishing a safe
workplace.

Sexual harassment is unlawful when it subjects an individual to inferior terms, conditions, or


privileges of employment. Harassment does not need to be severe or pervasive to be illegal. It can
be any harassing behavior that rises above petty slights or trivial inconveniences. Human Rights
Law specifies that whether harassing conduct is considered petty or trivial is to be viewed from the
standpoint of a reasonable victim of discrimination with the same protected characteristics.
Generally, any behavior in which a covered individual is treated worse because of their gender
(perceived or actual), sexual orientation, or gender expression is considered a violation of G&C’s
policy. The intent of the behavior, for example, making a joke, does not neutralize a harassment
claim. Not intending to harass is not a defense. The impact of the behavior on a person is what
counts.

Sexual harassment includes any unwelcome conduct which is either directed at an individual
because of that individual’s gender identity or expression (perceived or actual), or is of a sexual
nature when:

• The purpose or effect of this behavior unreasonably interferes with an individual’s work
performance or creates an intimidating, hostile or offensive work environment. The impacted
person does not need to be the intended target of the sexual harassment;
• Employment depends implicitly or explicitly on accepting such unwelcome behavior; or

G&C Foods 500-4 January 2024


• Decisions regarding an individual’s employment are based on an individual’s acceptance or
rejection of such behavior. Such decisions can include what shifts and how many hours a
team member might work, project assignments, as well as salary and promotion decisions.

There are two main types of sexual harassment:

Hostile Work Environment - A hostile work environment consists of words, signs, gestures,
jokes, pranks, intimidation, or physical actions or violence, either of a sexual nature or not of a
sexual nature, which is directed at an individual because of that individual’s sex, gender identity,
or gender expression. Sexual harassment also consists of any unwanted verbal or physical
advances, sexually explicit derogatory or discriminatory statements that a recipient finds
offensive or objectionable, causes discomfort or humiliation, and/or interferes with a team
member’s job performance.

Quid Pro Quo Sexual Harassment - Sexual harassment also occurs when a person in authority
trades, or tries to trade, job benefits for sexual favors. This type of harassment usually occurs
between a team member and someone with authority, like a supervisor, who has the ability to
grant or withhold job benefits. This can include hiring, promotion, continued employment or any
other terms, conditions or privileges of employment.

Examples of Prohibited Conduct - The following describes some of the acts that may be unlawful.
This list is just a sample of behaviors and should not be considered exhaustive. Any team member
who believes they have experienced sexual harassment, even if it does not appear on this list, should
feel encouraged to report it.

Prohibited conduct includes, but is not limited to:


• Insulting, lewd, or sexually-oriented words, jokes, pranks, slurs, innuendoes, or stories. This
includes verbal harassment as well as written, recorded, and electronically transmitted material.
• Intimidation or physical violence which is of a sexual nature, or which is directed at an individual
because of that individual’s sex.
• Leering, ogling, obscene gestures or sounds, or whistling.
• Sexually oriented gestures, noises, remarks, jokes, or questions and comments about a person’s
sexuality, sexual experience, or romantic history which create a hostile work environment. This
is not limited to interactions in person. Remarks made over virtual platforms and in messaging
apps when team members are working remotely can create a similarly hostile work environment.
• Physical acts of a sexual nature, including, but not limited to, touching, groping, grabbing,
hugging, kissing, massaging, fondling, patting, pinching, hitting, pushing, or brushing up against
or poking another person's body or impeding and/or blocking movements.
• Rape, sexual battery, molestation or attempts to commit these assaults, which may be
considered criminal conduct outside the scope of this policy.
• Sexual or discriminatory displays or publications anywhere in the workplace, such as: displaying
pictures, posters, calendars, graffiti, objects, promotional material, reading materials or other
materials that are sexually demeaning or pornographic. This includes such sexual displays on
workplace computers or cell phones and sharing such displays while in the workplace, as well
as anything on display in the background of an individual’s work from home set up during a virtual
meeting.
• Hostile actions taken against an individual because of that individual’s sex, sexual orientation,
self-identified or perceived sex, gender expression, gender identity and the status of being
transgender, such as: interfering with, destroying or damaging a person’s workstation, tools or
equipment, or otherwise interfering with the individual’s ability to perform the job; sabotaging an
individual’s work or excluding an individual, parent or caregiver from work meetings; bullying,
G&C Foods 500-5 January 2024
yelling, name-calling, including the intentional misuse of preferred pronouns; creating different
expectations for individuals based on their perceived identities; or dress codes that place more
emphasis on women’s attire.
• Unwanted sexual comments, advances or propositions, such as requests for sexual favors
accompanied by implied or overt threats concerning the target’s job performance evaluation, a
promotion or other job benefits; subtle or obvious pressure for unwelcome sexual activities; or
repeated requests for dates or romantic gestures, including gift-giving.
• Sex stereotyping, which occurs when someone’s conduct or personality traits are judged based
on other people’s ideas or perceptions about how individuals of a particular sex should act or
look.

Other Types of Harassment - Harassment based on any protected characteristic is prohibited.


While it is not possible to list all conceivable behaviors which might be considered harassing, the
following are examples of behavior that must be avoided:
• Ethnic, racial, religious or other teasing or slurs, jokes or comments that demean a person on the
basis of race, color, religion, national origin, creed, sex, marital status, citizenship status, sexual
orientation, gender identity or expression, the status of being transgender, age or disability;
• Mimicking or mocking another’s race, color, religion, ethnicity, national origin, creed, sex, marital
status, citizenship status, sexual orientation, gender identity or expression, the status of being
transgender, age, or disability; and
• Racially or religiously offensive pictures, symbols, cartoons, or graffiti.

Who Can be a Target of Sexual Harassment? - Sexual harassment can occur between any
individual, regardless of their sex or gender and can be anyone in the workplace, whether a
supervisor, coworker, independent contractor, vendor, client, customer, patient, constituent, or
visitor.

Discrimination experienced by a team member can be impacted by biases and identities beyond
an individual’s gender. For example:
• Placing different demands or expectations on black women team members than white women
team members can be both racial and gender discrimination;
• An individual’s immigration status may lead to perceptions of vulnerability and increased
concerns around illegal retaliation for reporting sexual harassment; or
• Past experiences as a survivor of domestic or sexual violence may lead an individual to feel
re-traumatized by someone’s behaviors in the workplace.

Where Can Sexual Harassment Occur? - Unlawful sexual harassment can occur anywhere -
while team members are traveling for business, at social functions sponsored by G&C and/or at
any location while representing the Company. Calls, texts, emails, and social media usage by team
members can constitute unlawful workplace harassment, even if it occurs away from the workplace
premises, on personal devices, or during non-work hours. Sexual harassment can occur when team
members are working remotely from home as well.

Supervisory Responsibility - Individuals in a supervisory role have a special responsibility to make


sure team members feel safe at work and that workplaces are free from harassment and
discrimination. They are required to take immediate and appropriate corrective action in the event
they are a witness to, or become aware of, any violations of this policy, even if no one is objecting to
the harassment. The supervisor is also required to immediately notify the HR Manager of any policy
violations. Supervisors who engage in sexual harassment, allow such behavior to continue or fail to
report such behavior likewise will be subject to disciplinary action up to and including termination
from employment.
G&C Foods 500-6 January 2024
Bystander Intervention - Any team member witnessing harassment as a bystander is encouraged
to report it. A supervisor that is a bystander to harassment is required to report it. There are five
standard methods of bystander intervention that can be used when anyone witnesses harassment
or discrimination.

1. Interrupt the harassment by engaging with the individual being harassed and distracting them
from the harassing behavior;
2. Ask a third party to help intervene;
3. Take notes on the incident to benefit a future investigation;
4. Check in with the person who has been harassed after the incident, see how they are feeling
and let them know the behavior was not ok; and
5. If you feel safe, confront the harasser and name the behavior as inappropriate. When
confronting harassment, physically assaulting an individual is never an appropriate response.

Complaint and Reporting Procedure - Refer to the Complaint Procedure and Investigations policy
for information on filing a complaint and the Company’s investigation procedures. Any individual
who feels harassed, witnesses or becomes aware of potential instances of sexual harassment
and/or discrimination should file a complaint internally with G&C so that any violation of this policy
can be corrected promptly. Any harassing conduct, even a single incident, can be discrimination
and is covered by this policy. So long as a person reasonably believes that they have witnessed or
experienced such behavior, they are protected from retaliation.

Legal Protections and External Remedies - Sexual harassment is not only prohibited by G&C but
is also prohibited by state, federal, and, where applicable, local law. Aside from the internal process
at G&C, individuals may also choose to file a complaint and pursue legal remedies with the following
governmental entities at any time.

• New York State Division of Human Rights (DHR) and Human Rights Law (HRL). Complaints
alleging violation of the Human Rights Law may be filed either with DHR or in New York State
Supreme Court under HRL, within three years of the alleged harassment. Team members may
call the DHR sexual harassment hotline at 1-800-HARASS-3 (1-800-427-2773) for more
information about filing a sexual harassment complaint. This hotline can also provide a referral
to a volunteer attorney who can provide limited free assistance and counsel over the phone. The
hotline is operational Monday through Friday, from 9:00 a.m. to 5:00 p.m.

More information about filing a complaint with DHR can be found by visiting www.dhr.ny.gov.
The website has a digital complaint process that can be completed on a computer or mobile
device and has the option of a complaint form that can be downloaded, filled out, notarized, and
mailed to DHR. Contact information for DHR’s regional offices across New York State is also
available.

Filing a complaint internally to G&C does not extend the time to file with DHR or in court. An
attorney is not needed to file a complaint with DHR, and there is no cost to file. DHR will
investigate the complaint and determine whether there is probable cause to believe that sexual
harassment or discrimination has occurred. Probable cause cases receive a public hearing
before an Administrative Law Judge (ALJ). If sexual harassment and/or discrimination is found,
DHR has the power to award relief, which may include requiring the employer to take action to
stop the harassment or redress the damage caused by the harassment, including paying
monetary damages, punitive damages, attorney’s fees, and civil fines. If the DHR concludes that
unlawful discrimination did not occur, the claim will be dismissed.

G&C Foods 500-7 January 2024


• United States Equal Employment Opportunity Commission (EEOC). An individual can file
a complaint with the EEOC anytime within 300 days from the most recent incident of harassment.
There is no cost to file, and an attorney is not needed. A complaint must be filed with the EEOC
before filing in federal court. For more information, contact the EEOC by calling 1-800-669-4000
(1-800-669-6820 (TTY)), visiting their website at www.eeoc.gov or via email at info@eeoc.gov.
If an individual filed an administrative complaint with the New York State Division of Human
Rights, DHR will automatically file the complaint with the EEOC to preserve the right to proceed
in federal court.

• Local Protections. Many localities enforce laws protecting individuals from sexual harassment
and discrimination. Contact the county, city or town to find out if such a law exists.

• Contact the Local Police Department. If the harassment involves unwanted physical touching,
coerced physical confinement or coerced sex acts, the conduct may constitute a crime. Those
wishing to pursue criminal charges are encouraged to contact their local police department.

Mandatory Sexual Harassment Prevention Training - Employers are required to provide


interactive sexual harassment prevention training to all team members on an annual basis.

Policy Violations - Any form of harassment, including sexual harassment, is a form of team member
misconduct. Any individual covered by this policy who engages in harassment, discrimination, or
retaliation will be subject to remedial and/or disciplinary action (e.g., counseling, suspension,
termination of employment, termination of their relationship with G&C). Team members and covered
individuals should not feel discouraged from reporting harassment because they do not believe it is
bad enough, or conversely because they do not want to see a colleague fired over less severe
behavior. Just as harassment can happen in different degrees, potential discipline for engaging in
sexual harassment will depend on the degree of harassment.

503 Complaint Procedure and Investigations

Policy Statement - G&C Foods takes all complaints of discrimination, harassment, sexual
harassment, unfair treatment, and retaliation seriously. A comprehensive complaint procedure has
been developed to address any concerns or complaints received from team members and non-team
members.

Reporting Policy Violations - Any Individual who believes he or she has been or is being
harassed, bullied, or has been the victim of unlawful discrimination or retaliation, or who is aware
of harassment, bullying, discrimination, or retaliation at G&C, must promptly report the behavior
to the Organizational Development Manager, Human Resource Manager, or the President
immediately. At the individual’s option, a complaint form provided by the Company may be used
to report the complaint. The form can be obtained from Human Resources. If a team member or
non-team member is not comfortable making such a report to the individuals listed above, he or
she may contact the hotline below to make a complaint.

A team member who works the second or third shift can file a complaint by contacting the
Organizational Development Manager, Human Resource Manager, or the President by calling them
on their cell phone (numbers can be found on the company’s intranet).

Additionally, the Company provides an anonymous hotline for reporting policy violations at:
1-800-634-3364 (Danbee Investigations).

Manager and Supervisory Responsibility - A manager or supervisor who receives a complaint or


information about harassment, discrimination, or retaliation, or who observes or suspects such

G&C Foods 500-8 January 2024


behavior is taking place, is required to report it to the Organizational Development Manager,
Human Resource Manager, or President immediately. Any manager or supervisory personnel who
knowingly allow such behavior to continue will be subject to liability, remedial and/or disciplinary
action, up to and including termination of employment.

Investigation - G&C will conduct a prompt and thorough investigation of the allegations, including
interviews of appropriate individuals (e.g., the person complaining, the alleged harasser, and
possible witnesses) that ensures due process for all parties, whenever receiving a complaint of
harassment or discrimination, or otherwise knows of possible harassment occurring. G&C will
take appropriate corrective action whenever harassment or sexual harassment is found to have
occurred. All team members, including managers and supervisors, are required to cooperate with
any internal investigation.

While the process may vary from case to case, investigations will be done in accordance with the
following steps:

1. Conduct a prompt review of the allegations, assess the appropriate scope of the investigation,
and take any interim actions (for example, instructing the individual(s) about whom the
complaint was made to refrain from communications with the individual(s) who reported the
harassment), as appropriate. If the complaint is verbal, and the person reporting prefers not
to fill out the complaint form, G&C will prepare equivalent documentation based on the verbal
reporting.

2. Take steps to obtain, review, and preserve documents sufficient to assess the allegations,
including emails or phone records that may be relevant to the investigation. G&C will consider
and implement appropriate document request, review, and preservation measures, including
for electronic communications.

3. Seek to interview all parties involved, including any relevant witnesses.

4. Create a written documentation of the investigation (such as a letter, memo or email), which
contains the following:
a. A list of all documents reviewed, along with a detailed summary of relevant documents;
b. A list of names of those interviewed, along with a detailed summary of their statements;
c. A timeline of events;
d. A summary of any prior relevant incidents disclosed in the investigation, reported or
unreported; and
e. The basis for the decision and final resolution of the complaint, together with any corrective
action(s).

5. Keep the written documentation and associated documents in a secure and confidential
location (not in personnel files).

6. Promptly notify the individual(s) who reported the harassment and the individual(s) about
whom the complaint was made that the investigation has been completed and implement any
corrective actions identified in the written document.

7. Inform the individual(s) who reported the right to file a complaint or charge externally.

Confidentiality - An team member's confidentiality will be protected to the greatest extent possible,
consistent with conducting a full investigation. However, the Company cannot guarantee complete
confidentiality. G&C reserves the right to disclose information as reasonably necessary to investigate
and remedy the matter.

G&C Foods 500-9 January 2024


Confidentiality - A team member's confidentiality will be protected to the greatest extent possible,
consistent with conducting a full investigation. However, the Company cannot guarantee complete
confidentiality. G&C reserves the right to disclose information as reasonably necessary to investigate
and remedy the matter.

Retaliation Prohibited - No person covered by this policy shall be subject to adverse action
because the team member reports an incident, provides information, or otherwise assists in any
investigation of a complaint. Unlawful retaliation can be any action that could discourage an
individual from coming forward to make or support a claim. Adverse action need not be job-
related or occur in the workplace to constitute unlawful retaliation (e.g., threats of physical
violence outside of work hours). G&C prohibits retaliation in any form against an individual for
reporting discrimination or harassment, filing a complaint of discrimination or harassment,
assisting in, testifying or appearing as a witness in any investigation or proceeding of
discrimination or harassment, informing a supervisor or manager of harassment, reporting that
another team member has been sexually harassed, encouraging a fellow team member to report
harassment, and engaging in any other lawfully protected activity.

Examples of retaliation may include, but are not limited to:


• Demotion, termination, denying accommodations, reducing hours, or assigning less desirable
shifts;
• Publicly releasing personnel files;
• Refusing to provide a reference or providing an unwarranted negative reference;
• Labeling an team member as “difficult” and excluding them from projects to avoid “drama;”
• Undermining an individual’s immigration status; or
• Reducing work responsibilities, passing over for a promotion, or moving an individual’s desk
to a less desirable office location.

Even if the alleged harassment does not turn out to rise to the level of a violation of law, the individual
is protected from retaliation if the person had a good faith belief that the practices were unlawful.
However, the retaliation provision is not intended to protect persons making intentionally false
charges of harassment.

Policy Violations - Any team member who violates the Company’s Equal Employment Opportunity
or Anti-Harassment and Sexual Harassment Policy or engages in harassment or retaliatory conduct
prohibited by this policy or makes a complaint that is demonstrated to be intentionally false, will be
subject to disciplinary action, up to and including termination. Non-team members violating this
policy may have their relationship with G&C terminated or be subject to remedial action, as
determined by management.

Please note that this policy is not designed or intended to limit the Company’s authority to discipline
or take remedial action for workplace conduct which it deems unprofessional, inconsistent with
Company standards, or otherwise inadvisable behavior, regardless of whether that conduct satisfies
the legal definition of unlawful discrimination or harassment.

G&C Foods 500-10 January 2024


600 OPERATIONAL POLICIES

601 Work Schedules

Normal Work Schedules - A team member's work schedule is established by the team member's
supervisor. A team member’s work hours may differ from the normal hours of operation depending
on the particular needs and requirements of the department. An exempt team member who generally
works at a main or satellite office is expected to work in that office on a regular basis. Requests to
work from home must be approved by management and will be limited to unique or extenuating
circumstances. Non-exempt team members are not permitted to work outside of their assigned
workspace.

Changes in Work Schedules - G&C Foods reserve the right to revise a team member's normal
work schedule at any time. This includes the team member's starting and ending times, the total
number of hours worked per day and/or per week, the days worked, and any teleworking
arrangements. Team members are notified of any changes in work schedules.

602 Meal and Break Periods

Meal Periods - Full-time team members receive a 60-minute unpaid meal period, unless a
department has designated a 30-minute meal period for business reasons . Part-time and temporary
team members receive a 30-minute unpaid meal period if they work a shift of more than six hours.

A team member who begins work before 11:00 a.m. and continues working later than 7:00 p.m.
receives an additional paid meal period of 20 minutes between 5:00 p.m. and 7:00 p.m.

Observance of Meal Periods - In accordance with New York State regulations, a team member
who works more than six hours in a given day is required to take the scheduled meal period. A team
member is not allowed to work through the meal period to make up lost work time or to leave work
early. In addition, the meal period may not be taken at the end of a team member's work shift in
order to leave work before the normal quitting time.

Break Periods - Team members who work more than 6 hours in a given day are allowed 2 paid
breaks of up to 15 minutes each. Break periods are designated by the team member’s manager or
supervisor. Team members are expected to remain on company property during paid break periods.

Lactation Breaks - A female team member will be granted time off to express milk during the
workday for up to three years after the birth of a child. The Company will make a reasonable effort
to provide the team member with a private room or other location in close proximity to the work area.
A team member must use her authorized breaks and/or meal period to express milk, whenever
possible. The Company will allow a team member to extend her authorized breaks or meal period
or will grant an additional break period, if needed, to express milk. Any break period of less than 30
minutes will be paid. A team member who chooses to express breast milk in the workplace will not
be discriminated against in any way.

Scheduling of Meal and Break Periods - Meal and break periods are staggered and are scheduled
by the team member’s supervisor in accordance with the needs and requirements of the department.

Extension of Meal and Break Periods - Team members should be punctual in starting and ending
all meal and break periods. A team member may not extend a meal or break period beyond the time
allowed unless prior approval is obtained from the team member’s supervisor.

G&C Foods 600-1 January 2024


Failure to Take Break Periods - A team member who chooses not to take an allowed break period
may not take an extended meal period, arrive at work later than the normal starting time, leave work
before the normal quitting time, or receive extra compensation. Unused break periods cannot be
accumulated for use at a later date.

Location of Meal and Break Periods – A break room is available for team members to use during
their meal and break periods. Unless otherwise specified by departmental rules, a team member
may leave the premises for meal periods but must remain on-site for all break periods.

Policy Violations – Violations of this policy will result in disciplinary action up to, and including,
termination.

603 Business and Travel Expenses

Policy Statement - It is the policy of G&C Foods to reimburse team members for reasonable and
necessary expenses incurred in connection with the performance of their jobs as well as approved
travel on behalf of the company. These expenses include, but are not limited to, mileage, parking
fees, air fare, meals, lodging, seminars, training, conferences, professional /trade membership fees,
and civic/community organizational membership. All business expenses should be limited to
reasonable amounts. G&C Foods strongly encourages use of travel discounts when making travel
arrangements.

Authorization and Responsibility- Travel must be authorized by a manager. Travelers should


verify that planned travel is eligible for reimbursement before making travel arrangements. Within
30 days of completion of a trip, the travelers must submit supporting documentation to obtain
reimbursement of expenses or support any credit card charges made. The Company reserves the
right to deny reimbursement for any business-related expense that was not pre-authorized or
submitted by the deadline date or that is considered unreasonable under the circumstances. When
submitting reimbursement for tolls and mileage please note it can be one or the other – NOT BOTH.

It is important to note that if you are the holder of a G&C Corporate Credit Card, we ask that
you use that form of payment before any other.

Travelers seeking reimbursement should incur the lowest reasonable travel expenses and exercise
care to avoid impropriety or the appearance of impropriety. Reimbursement is allowed only when
reimbursement has not been and will not be received from other sources. If circumstances arise that
are not specifically covered in this travel policy, then the most conservative course of action should
be taken. Business Travel Policies are aligned with company reimbursement rules. All Business-
related travel paid with G&C Food’s funds must comply with company expenditures policies. This
includes any expenses paid for with a G&C Corporate Credit Card.

Personal Funds - Travelers should use their G&C Corporate Credit Card whenever possible.
Travelers should review reimbursement guidelines before spending personal funds for business
travel or related expenses to determine if such expenses are reimbursable. G&C Foods reserves
the right to deny reimbursement of travel-related expenses for failure to comply with policy and
procedures. Expenses made outside the G&C Corporate Credit Card can only be reimbursed via
an expense report.

Vacation in Conjunction with Business Travel - In cases in which vacation time is added to a
business trip, or if a family member accompanies a G&C team member on a trip, any cost variance
in airfare, car rental or lodging must be clearly identified on supporting documentation.

Reimbursable and/or Authorized Expenses - Expenses such as airfare, car rental, meals and
mileage are generally considered acceptable travel expenses when reasonable and necessary. The
following guidelines apply.

G&C Foods 600-2 January 2024


G&C Food Air -The option to use G&C Foods’ private plane should always be considered when
traveling. Seek the assistance of a Senior Manager to determine if the G&C Foods airplane is an
option.

Airfare - Airfare-travelers are expected to obtain the lowest available airfare that reasonably meets
business travel needs. Travelers are expected to book flights at least 30 days in advance, when
possible, to avoid premium pricing. Coach class or economy tickets must be purchased for domestic
or international flights. Exceptions many be made for flights lasting more than 5 hours in duration
(excluding layovers).

Auto Rental - Reimbursement for commercial rental vehicle as a primary mode of transportation is
authorized if deemed necessary and reasonable. Travelers are encouraged to travel together when
possible. G&C Foods authorizes the rental of economy vehicles unless a large vehicle is deemed
necessary to accommodate multiple passengers and/or clients. G&C encourages travelers to
purchase collision damage waiver (CDW) and loss damage waiver (LDW).

Lodging - G&C Foods will reimburse or authorize lodging expenses at reasonable rates for out of
town travel.

Personal Meal Per Diem - G&C Foods per diem rates are based on U.S. General Services
Administration (GSA) guidelines. Per Diem reimbursements or authorized expenditures are based
on departure and return times over the entire 24-hour day and are prorated accordingly. If meals
are included in a conference or hotel stay, such as continental breakfast, this should be deducted
from your daily allowance. Daily Per Diem is $100.00. Any per diem that is not used will not be
reimbursed or carried over. NOTE: Meal per Diems may not be granted when traveling to the
Syracuse Corporate office unless prior approvals have been made. Meal per diems do not apply to
CMV Operators who receive overnight pay or meal stipends.

Business meals - When entertaining clients it is expected that reasonable judgment is used when
spending company funds. It is expected that approval from a Senior Manager be made when
accommodating a large business dinner.

Mileage - Transportation using a personal vehicle for business reasons that are reasonable and
necessary may qualify for reimbursement or authorized expenditure. Travelers using a personal
vehicle must possess a valid driver’s license and have proof of insurance. Mileage will be paid at
the current corporate rate (Please see Accounting). Mileage will be reimbursed in lieu of gas and
tolls. When calculating miles driven, drivers must record the starting mileage and the ending mileage.
Miles normally driven for commuting purposes should be excluded. Approved mileage will be
reimbursed for travel to and from the Syracuse Corporate headquarters beyond a 60-mile radius
from satellite or remote/distributed offices.

Parking - Expenses for parking must be submitted with supporting documentation/receipts in order
to be reimbursed.

Non-Reimbursable and/or Unauthorized expenses-


• Maid tips at lodging facilities
• Items purchased for personal use (toiletries, personal care items, etc.)
• Commuting between home and the team member’s primary work location.
• Evening or formal wear expenses
• Haircuts and personal grooming
• Laundry or dry-cleaning services
• Personal entertainment expenses (in-flight movies, hotel pay-per-view, etc.)
• Other expenses not directly related to business travel.

G&C Foods 600-3 January 2024


Policy Violations – Violations of this policy will result in disciplinary action up to, and including,
termination.

604 Remote/Distributed Work Policy

POLICY STATEMENT - Remote working refers to a work arrangement under which a team
member performs the duties, responsibilities, and other authorized activities per their job
description, from a worksite other than a G&C office from which the team member would otherwise
work. We believe working remotely can be successful when team member, team and customer
needs are aligned. Remote working arrangements are between G&C management and an eligible
team member. Remote working allows eligible team members to fulfill their job responsibilities
during regularly scheduled work hours for an indefinite or finite period. Remote working is a
privilege, not an entitlement and it does not change the at-will nature of the employment
relationship.

This policy is designed to address expectations and conditions surrounding remote work for all
eligible team members. Whether or not your remote work is full-time or incremental, all topics in
this policy apply.

G&C considers remote working to be an alternative work arrangement in cases where the
individual team member, the job, and the manager are well suited to such an arrangement.
However, not all team members and positions are eligible for remote working. Eligibility for remote
working is based on the team member’s position and the department’s goals and is to be
determined by the team member's Senior Manager and approved per this policy.

POLICY GOAL - The combination of advancements in technology and a global shift in how work is
being performed allows our people, under the right circumstances, to be more productive and
efficient with their time. This also expands our geographic reach to hire exceptional people and
service our customers.

Many team members may be able to balance growth, development, collaboration, relationship
building and teaming in situations that allow the team member to work remotely. A team member
can make a request to their direct manager for remote work arrangement; however, it is up to the
Senior Manager’s discretion to approve.

Team members can discuss requests for remote work arrangements with their direct manager. All
such arrangements need to be documented in writing and need to be approved by the Senior
Manager, as appropriate. Remote work arrangements may be partial or fully remote, may be
temporary or ongoing. G&C reserves the right to discontinue any remote work arrangement at any
given time. Every effort will be made to provide 2 weeks’ notice of such change to accommodate
commuting, childcare and other issues that may arise from the discontinuation of a remote work
arrangement. There may be instances when no notice is possible.

Business conditions may require a team member to perform work in the office, attend meetings in
person, or assist in handling critical and/or urgent situations during times that they have been
approved to work remotely. A manager can require a team member to return to the office in these
situations. Whenever possible, the manager will provide 72 hours' notice to the team member.
However, there may be situations where advance notice is not possible, and the team member will
be required to come into the office immediately to best serve the needs of the business.

G&C Foods 600-4 January 2024


Eligibility - Before entering into any remote work agreement, the team member and manager, with
the assistance of HR, will evaluate the suitability of such an arrangement, reviewing the following
areas:

• Job responsibilities: The team member and manager will discuss the job responsibilities
and determine if the job is appropriate for a remote work arrangement.
• Team member suitability: The team member and manager will assess the needs and work
habits of the team member, compared to traits customarily recognized as appropriate for
successful remote workers
• Professional development needs of the team member and how he/she will best learn.
• Equipment needs, workspace design considerations and scheduling issues: The team
member and manager will review the physical workspace needs and the appropriate
location.
• Tax and other legal implications: The team member must determine any tax or legal
implications under IRS, state, and local government laws, and/or restrictions of working out
of a home-based office. Responsibility for fulfilling all obligations in this area rests solely
with the team member.
• All remote work arrangements/agreements must have direct manager AND senior manager
approval.

An appropriate level of communication between the remote worker and their manager will be
agreed to as part of the discussion process. The manager and remote worker will communicate at
a level consistent with team members working at the office or in a manner and frequency that is
appropriate for the job and the individuals involved.

In-office Workspace - For team members who have approval to work remote on a regular basis
for three (3) or more days per week, may be required to share the in-office workspace with other
remote team members. They also may not be permitted to inhabit a private office.

Company-Issued Equipment - G&C issues work from home team members a computer to
perform their work. At their manager's discretion, they may also be issued one or more monitors,
keyboards, or mice. This equipment is owned by G&C, and its use is governed by terms that are
outlined in this Team Member Handbook. Their manager is responsible for tracking this equipment
and has the right to request that they return this equipment to the office at any time.

If a team member requires additional equipment to do their work, they must consult with their
manager and the BSG team before procuring or connecting it to their company-assigned
equipment. As team member may be required to purchase this equipment if it is not deemed
essential for them to do their job.

A SUITABLE WORK ENVIRONMENT - Team members are responsible for ensuring that they
have an environment within their home that is suitable for professional work:
• Quiet & distraction-free (away from noises, pets, etc.)
• Ergonomic (comfortable for sitting/standing at a computer for 8 hours of your day; you are
responsible for procuring appropriate furniture and accessories)
• Professional (your environment looks clean and appropriate for videoconferencing with
other professionals)
• Safe for your company-assigned equipment (ensuring that it doesn't fall on the floor, get
damaged by food or other liquids, etc.)
• Appropriate dress (dress as you would if you were in the office)

G&C Foods 600-5 January 2024


Internet Service & Related Equipment - Team members are responsible for subscribing to and
maintaining a reliable broadband Internet Service Provider (ISP), which is team member paid. If
and team member does not have access to reliable broadband Internet service, then working from
home will not be an option.

Team members are responsible for understanding and configuring their home Internet connection.
If the Internet service goes down, they are responsible for working with their ISP to have them fix
the service.

If a team member chooses to use a wireless (WiFi) connection, they are responsible for
understanding the details of their Router/Wireless Access Point (WAP), including their wireless
network's name (aka SSID, or Service Set Identifier) and its associated password that allow them
to access their wireless network. G&C IT will not be in a position to know these details.

If the job requires a team member to use G&C's Virtual Private Network (VPN) capability or a
company owned desk phone, our expectation is that they do NOT use a wireless connection.
Instead, we ask that they physically connect their assigned PC and/or phone to their home Router
using a physical Ethernet (aka RJ-45) connection.

A team member is responsible for selecting the equipment that serves their needs, and for setting it
up and maintaining it. If you are a new team member, or are new to working from home, BSG will
provide initial assistance to set you on your way. G&C assumes that, once you are off and running,
you will take responsibility for your home work environment, as detailed throughout this policy.

Internet Service Equipment Hygiene - Team members are expected to maintain their equipment
by:
• Applying security updates as needed
• Rebooting your Router occasionally (once every 3 months)

Team members should NOT replace their Router's firmware with third-party firmware (e.g., DD-
WRT or Tomato), as this firmware is not guaranteed to work reliably.

VPN (Virtual Private Network) Access - The VPN allows team members to securely connect to
the computing resources that are located at our headquarters. Team members are responsible for
remembering their password for the VPN, and for keeping it secure.
Internet-based software and services, like Enterprise Cafe, G&C Market, mail (Outlook) and Office
365, do NOT require you to connect to the VPN to access. Only systems that "live" within our
headquarters (like Able/NCR/Shared Files) require VPN access.

Please keep in mind that VPN connections do not like when your laptop or computer goes to sleep.
Neither does Able. If you have to step away from your laptop or computer for more than 10
minutes, it is wise to sign off of Able and disconnect your VPN connection. This will help to limit the
number of “dead sessions” that you may need the BSG to clear out for you and will greatly improve
your experience.

KEEPING YOUR COMPUTER SAFE - Your agreement with the terms outlined in this Team
Member Handbook governs your responsibilities with company-owned equipment. Please be sure
you have read this Team Member Handbook carefully.

Whether or not you need to access Able/NCR/Shared files, we REQUIRE that you connect to the
VPN for at least one hour TWICE per week, so that we may scan your machine for security
vulnerabilities and apply software updates.

G&C Foods 600-6 January 2024


PRINTING - G&C provides digital workflows and tools for all essential work. A printer is never
required to do any of your work. If you choose to print, you are responsible for providing your own
printer, and you must pay for all consumables (toner, ink, paper, parts, etc.) You are solely
responsible for troubleshooting your home printer should you choose to use one.

Security and Removal of Confidential Information - As stated in the Confidentiality Policy, a team
member is responsible for properly securing and maintaining confidential information obtained or
learned during employment. This includes Company information stored on flash drives, laptops, and
wireless devices, as well as home computers that have been approved to be used to conduct G&C
Foods business. A team member must exercise caution when using a wireless device for business
purposes in public areas to ensure that confidential information cannot be viewed by others or that
equipment is not stolen. Unauthorized removal of confidential information from Company premises
is prohibited.

What to Expect from BSG IT Support - G&C’s BSG will provide IT support for all software,
hardware, and systems we assign to you for your job. This includes your assigned computer, its
operating system, and company-installed software (such as Microsoft Office), as well as software
that allows you to access company-owned remote computers (such as Able, NCR, the Intranet,
etc.)

BSG will support you with a quick response time during normal business hours (7 AM - 5 PM EDT,
Monday through Friday). BSG is available outside of these hours, albeit with a slower response
time. Because of this, please try to keep the bulk of your critical work during normal business
hours.

Please note that BSG will not be as readily able to provide support for your home Internet
connection, or for web sites or other systems that are not part of your assigned work
responsibilities.

Accountability - For your position to succeed in a home setting, your manager and your peers
should be able to easily determine that you are producing the outcomes that have been defined for
your role. You are responsible for these outcomes and will be held accountable. If you are unable
to provide a suitable work environment in your home — including reliable access to resources and
peers via your home Internet connection — your manager may require that you work from your
nearest G&C office.

The team member will establish an appropriate work environment within his or her home for work
purposes. G&C will not be responsible for costs associated with the setup of the team member's
home office, such as remodeling, furniture, or lighting, nor for repairs or modifications to the home
office space. Generally, G&C will not be responsible for costs such as phone, internet, etc., that
enable the team member to work remotely when the team member is requesting to voluntarily work
remotely unless reimbursement of such expenses is required by law or due to a reasonable
accommodation.

Workers Compensation and Liability - Team members are expected to maintain their home
workspace in a safe manner, free from safety hazards. Injuries sustained by the team member in a
home office location and in conjunction with his or her regular work duties are normally covered by
the company's workers' compensation policy. Remote team members are responsible for notifying
the employer of such injuries as soon as practicable. Remote workers should not permit business
visitors to their home office. The team member is liable for any injuries sustained by visitors to his
or her home worksite. All such business meetings should take place in an approved business
meeting site or in a G&C office.

G&C Foods 600-7 January 2024


Time Worked - Remote team members who are not exempt from the overtime requirements of the
Fair Labor Standards Act will be required to accurately record all hours worked using the ADP
Portal. Use of the ADP Mobile Application is not permitted. Hours worked more than those
scheduled per day and per work week require the advance approval of the remote worker's
manager. Failure to comply with this requirement may result in the immediate
termination/revocation of the remote work agreement.

Working remotely is not designed to be a replacement for appropriate childcare. Although an


individual team member's schedule may be modified to accommodate childcare needs, the focus
of the arrangement must remain on job performance and meeting business and customer
demands.

Remote team members are expected to work within specific hours identified in the remote work
agreement and approved by the team member's Senior Manager. A manager can establish and
require team members to be available during core hours. Non-exempt remote team member must
request approval for any deviations from the agreed upon schedule. Failure to strictly adhere to the
agreed upon schedule of days and hours will be cause for the remote work approval to be revoked.

Team Member Performance - Team member performance is an important consideration


concerning initial and ongoing approval of remote work arrangements. Team members will not be
penalized, disciplined, or terminated for requesting to work remotely. However, coaching,
mentoring, and developing team member's skills and correcting performance deficiencies can often
be more effective in face-to-face exchanges. If a team member is notified of performance
concerns, the team member should immediately discuss with his/her manager whether the team
member should discontinue or reduce his/her remote work schedule in favor of additional in-office
time to facilitate more effective and efficient performance related communication with the team
member's direct manager and/or benefiting from additional coaching/mentoring opportunities with
co-workers/team members. Such adjustments must be documented and may be either temporary
or permanent depending upon the team member's ongoing performance and the ability to sustain
any performance improvements. The desire of the team member to work remotely must be a
secondary consideration to meeting the position requirements and the customer/team/business
needs.

G&C’s Team Member Handbook - All the provisions of the Team Member Handbook still apply
unless otherwise noted in the remote work policy. As a G&C Team member, you are representing
the company in person or virtually through video conferencing.

605 Nursing Mothers Accommodation

Policy Statement – G&C Foods provides a supportive environment to enable nursing mothers to
express breast milk during work time and makes reasonable efforts to provide a private room or other
location in close proximity to the work area for such activity. This accommodation is available for up
to three years following the birth of a child. Discrimination and retaliation of breastfeeding mothers in
any form is unacceptable and will not be tolerated.

Notification Requirements - Whenever possible, a team member should give advance notice of
her intent to take lactation breaks upon her return to work.

Location of Lactation Breaks – The Company will provide a private room or other private location
that includes a place to sit, a work surface, an electrical outlet, and is near running water. The private
location will not be a restroom.

G&C Foods 600-8 January 2024


Length of Lactation Breaks - The Company will grant a team member reasonable break time of
not less than 20 minutes unless the team member chooses to take a shorter break, at least once
every three hours to express breast milk. If the room is not in close proximity to the workplace, the
break should be at least 30 minutes. At the team member’s option, her lactation break may run
concurrently with her regularly scheduled paid break or meal period.

Payment for Lactation Breaks - A lactation break of less than 30 minutes will be paid. A lactation
break of 30 minutes or more is without pay. Upon election of a non-exempt team member, the team
member will be allowed to make up any work time lost while on unpaid lactation breaks either before
or after the team member’s regular work shift as long as this time falls within the Company’s normal
business hours. Deductions will not be taken from an exempt team member’s pay for lactation
breaks of any length.

Storing Expressed Milk - A refrigerator is available to store expressed breast milk. All expressed
milk must be stored in a closed container and must be taken home at the end of each workday. G&C
Foods is not responsible for the safekeeping of a team member’s milk stored in a refrigerator on its
premises.

606 Pets in the Workplace

Purpose: The Purpose of this policy is to establish guidelines for team members who bring their
pets to work. This policy aims to ensure the safety and well-being of all team members and their
pets, as well as to maintain a clean and hygienic workplace. We believe that pets can foster a
friendlier and happier work experience. They’re fun, playful and can have a positive influence on
our work.

However, we want to make sure that animals won’t disrupt our operations, damage property, or
cause medical issues to other team members. We expect everyone to read and respect this
policy.

Policy statement: Team members are allowed to bring their pets to work, subject to the following
guidelines.

Who and where does this apply to: This policy refers to all G&C team members (including
drivers). Visitors and vendors are strictly prohibited from bringing pets on G&C property. In-Bound
Drivers must keep pets on a leash and clean up after pets.

This policy applies to any space G&C owns where team members perform their job duties
(including company vehicles/trucks). Spaces that are rented/leased require approval and
appropriate guidance from the property owner or building manager.

Prior Approval Required by Manager - Team members who own pets may request approval to
bring them to their workspace (office/truck, etc.). They should always consult with their manager to
review the pet policy and agree to the following:

• Pets must be well behaved and adequately trained, including but not limited to being “house
trained”.
• Owners must respect coworkers with allergies, other medical problems, or phobias.
• Pets must have verifiable up-to-date vaccinations including rabies and must have current
license and identification tags and be free of parasites (fleas, ticks, etc.).
• Pets should be covered under their home/rental insurance policy.

G&C Foods 600-9 January 2024


What pets are allowed? - Workplace pets include dogs or cats only. Young dogs or cats aren’t
allowed until they’re adequately trained.

Owner’s responsibilities – Generally, we want to ensure that our company and team members’
pets are cared for properly. Pet owners must clean up after their pets immediately. They’re solely
responsible for their pet’s behavior and well-being. They should supervise their pets in the
workplace or always know their location. More specifically, the following etiquette should be
followed:

• A team member may not bring a pet into the workplace more than 1 day per week. This does
not include drivers who may be on the road longer and may bring pets along. Team Drivers
must get prior approval from their manager and team members.
• Pets must be kept on a leash or in a carrier while in the workplace, except when they are in a
team member’s personal office or designated area.
• Pets should never fight with other office pets; aggressive or unruly pets will not be allowed in
the workplace.
• Pets should not be allowed to wander.
• Pets should not damage company or team member property. Team members who bring their
pets to work assume liability for any damage, injury, or loss caused by their pets.
• Pets should not annoy coworkers (e.g., barking constantly, playing with squeaky toys,
climbing on their desks, begging, or searching for food)
• Pets should never be left unattended.
• Pets should be well maintained and clean.
• If a pet is unwell, it should be left at home.
• Owners are responsible for any and all clean up. Clean up must be done promptly. Any
“accidents” that occur inside the building must be cleaned with appropriate cleaning
equipment or cleaning supplies provided by the owner. Any cleanup needed outside should
be collected in self-provided clean up baggies and disposed of at home. Placing clean up
bags in G&C receptacles is not allowed.
• Team members are responsible for maintaining a clean and hygienic workplace. This
includes regularly cleaning and disinfecting their work area and ensuring that their pets do not
come into contact with food products or food packaging.

If any of these occur, it falls to the HR department’s discretion to determine the seriousness of the
pet’s/owners’ actions. As a rule, if the pet misbehaves or becomes overly aggressive, their owner
may be prohibited from bringing the pet to the office again. They’ll also be responsible for any
expenses and cleaning resulting from their pet’s behavior.

Owners can leave work to walk their dogs on their lunch breaks. They should avoid using up
excessive work time to look after their pets. If a pet needs constant care and attention, their owner
may be instructed to leave them at home. Same goes for days that their owner has a busy
schedule and won’t be able to supervise them.

Pet owners are advised not to leave pets in their vehicles for great periods of time. In some
jurisdictions, leaving pets in cars confined or unattended, in conditions that may endanger them, is
illegal. Pet owners are obliged to know the law. When team members use company vehicles, we
prohibit them from leaving pets inside, unattended and without proper ventilation, food/drink, or in
extreme temperatures.
G&C Foods 600-10 January 2024
Policy Violations: Any team member who violates this policy will be subject to disciplinary action,
up to including termination. Any vendor, supplier, visitor or customer, or other non-team member
who violates this policy will be subject to remedial action, as determined by management.

Areas where pets are prohibited:


There are certain places and times where our company prohibits office pets:

o Offices/Work Areas of team members with allergies


o Warehouse (including offices, hubs, pods, etc.)
o Vehicle maintenance building
o Production Rooms
o Computer/Server Rooms
o Places with sensitive equipment or material
o Kitchens, Break Rooms, and Client Engagement Center, where food is served, consumed, or
exposed.
o Meeting rooms during meetings with clients or external parties

Managers, Supervisors, or other team members should inform their manager of any unattended or
misbehaving pets at work.

The manager or HR department may instruct team members to restrict their pets at certain
instances (e.g., company parties). We expect team members to follow those instructions.

In cases when the number of pets in the office becomes excessive, we’ll have to restrict or limit
them. Team members can then bring their pets to work according to a schedule.

Complaint Process:
We want all team members to feel safe in their workplace. If a team member has concerns or
problems resulting from a pet at work, they can follow this process:

1. Talk to the pet’s owner in case they can resolve the problem immediately.
2. Reach out to their supervisor explaining their issues.
3. Consult the HR department, if they don’t get a satisfactory response.
4. File an official complaint.

If they have a medical or personal issue (e.g., allergy, phobia), they can directly contact the HR
department.

Supervisors and Managers should take their team members’ concerns seriously and investigate as
soon as they receive complaints. If they’re unable to resolve the problem, they should contact the
HR department and inform their team members.

This policy doesn’t prohibit service animals (animals trained to perform tasks for the benefit of a
person with a disability.) They are allowed to move freely with their owners. If any problem arises
because of service animals, we will make appropriate accommodations to resolve it. This falls to
the discretion of the HR department. A service animal exemption will require ADA approval as an
accommodation as well as full documentation of the service animals training credentials.

We also instruct team members not to feed other team members’ pets at work, if not authorized.

G&C Foods 600-11 January 2024


700 ATTENDANCE, TARDINESS AND LEAVES OF ABSENCE
701 Attendance Leave/Tardiness

Policy Statement - In order to maintain a productive work environment, team members are
required to work all scheduled work hours and to keep unscheduled absences and tardiness
to a minimum. Poor attendance, tardiness, and early departures place a burden on the Company,
other team members, and customers.

Notification of Tardiness – A team member is expected to be on time and ready to begin work at
the start of the team member's scheduled workday. A team member who is going to be tardy must
call the ATTENDANCE HOTLINE #1-315-233-6726 to personally notify the team member's
supervisor at least 30 minutes before the team member’s scheduled starting time. Callers should
select the correct department when calling to ensure the message gets to the correct manager. The
reason for the tardiness and when the team member expects to report to work must be indicated.
Likewise, a team member who needs to leave work early for any reason must notify their supervisor
as soon as possible.

Notification of Unscheduled Absences – In the event of an unscheduled absence the team


member must call the ATTENDANCE HOTLINE #1-315-233-6726 to personally notify the team
member’s supervisor at least 30 minutes before the team member’s scheduled starting time. Callers
should select the correct department when calling to ensure the message gets to the correct
manager. The reason for the absence and a phone number where you can be reached should be
left on the hotline. Asking a relative, friend, or another person to call in on the team member's behalf
is not permitted. Notification requirements may be waived in cases of emergency or where
extenuating circumstances are present.

It is understood that sudden illness and certain situations covered by the New York paid sick leave
law may not allow for ample notice to a team member’s supervisor of the need for absence.
However, a team member is asked to provide as much notice as possible and will not be required to
provide confidential details of the reason for the absence.

Scheduled Absences - Requests for scheduled time off, including the use of PTO, must be
submitted in writing to the team member’s supervisor as far in advance as possible, but no less than
3 workdays in advance. The Company reserves the right to request the reason for the absence.
PTO requests must be submitted in accordance with the PTO leave policy (See Policy 907 PTO). All
time off requests are subject to supervisory approval on a case-by-case basis.

Unexcused Absences and Unexcused Tardiness - Notification of an absence or tardiness to a


team member's supervisor does not automatically mean the absence or tardiness is authorized. Any
time off from work that is without supervisory approval is considered unexcused. An unexcused
absence or tardiness is without pay for non-exempt team members if no PTO is available.

Excessive Unexcused Absences and/or Tardiness – Excessive unexcused absences and


tardiness are defined as follows:
• Unexcused Absences - Two (2) occasions of unexcused absences during the 90-day
onboarding period are considered excessive. Corrective discipline, up to and including
termination of employment, may be initiated upon the second occasion. After the 90-day
onboarding period, five (5) occasions of unexcused absences in a 12-month rolling year are
considered excessive. An absence of two or more consecutive workdays will be considered
as one occasion.

G&C Foods 700-1 January 2024


• Unexcused Tardiness: - Two (2) occasions of unexcused tardiness during the 90-day
onboarding period is considered excessive. Corrective discipline, up to and including
termination of employment, may be initiated upon the second occasion. After the 90-day
onboarding period, five (5) occasions of unexcused tardiness in a 12-month rolling year are
considered excessive.

Daily Notification - If a team member is unable to report to work for more than one workday, the
team member must call the ATTENDANCE HOTLINE #1-315-233-6726 each day of the absence
to personally notify the supervisor, unless the absence was pre-authorized or the team member is
on an approved leave of absence (e.g., FMLA, jury duty, military leave).

Failure to Call in or Report to Work - A team member who does not report for work or contact the
ATTENDANCE HOTLINE for two consecutive workdays will, absent extenuating circumstances, be
considered to have abandoned his/her job and voluntarily resigned his/her position with the
Company.

Documentation of Absences - A team member who demonstrates a pattern of frequent


absences/tardiness may be required to provide documentation of the reason for any future
absences.

Medical Verification - A team member who is absent from work for more than three (3) consecutive
workdays due to illness or injury may be required to provide medical verification of the team
member’s absence. Medical verification may also be required for certain shorter absences. If a
team member is on an authorized leave of absence, the provisions of the Family and Medical Leave
Act Policy (Policy 707) shall apply. Failure to produce the medical verification may result in a team
member receiving the time off without pay and/or jeopardize continued employment with the
Company.

Upon return to work, the team member may also be required to provide a medical statement from
the team member's health care provider indicating that the team member is able to return-to-work
and listing any work restrictions. In the event the medical statement indicates there are work
restrictions, the Company reserves the right to evaluate if the restrictions can be reasonably
accommodated (See Policy 501 Equal Employment Opportunity). A team member is not allowed to
return to work until an adequate medical statement is provided to the team member’s supervisor.

Leaving the Premises - A team member must notify and obtain approval from the team member's
supervisor before leaving Company premises during working time for personal reasons. A team
member who leaves Company premises during the workday due to business/personal reasons must
notify the team member's supervisor in accordance with department policy. Non-exempt team
members leaving the premises for personal reasons must record the time away from work on their
time record. If a team member leaves the premises without advising management, they are subject
to disciplinary actions up to and including termination.

Time Off Without Pay - A team member must use all credited, unused PTO before requesting time
off without pay. Supervisors, at their discretion, may deny requests for unpaid time off except for
time taken off under approved leaves of absence. Excessive unpaid time off will not be allowed.

If an exempt team member has no paid leave benefits available, the team member will generally be
granted unpaid time off in full day increments only.

Making up Lost Time - A non-exempt team member may be allowed to make up lost work time
during the current workweek with prior supervisory approval (up to 40 hours total). Authorization is
granted only if work is available and only at a time that is mutually convenient for the team member
and the team member's supervisor.

G&C Foods 700-2 January 2024


Policy Violations - Violations of this policy may result in disciplinary action, up to and
including termination. This includes falsification of the reason for absence, unexcused absence(s),
a record of excessive tardiness absences or early departures, or a pattern of absenteeism, even if
excused. Management reserves the right to determine what is excessive. Failure to maintain an
acceptable attendance record will result in disciplinary action up to and including
termination.

702 Time Records

Policy Statement - Federal and state employment regulations require G&C Foods to maintain
accurate records of team member work hours. Accurate time records allow the Company to calculate
each team member's compensation for time worked and authorized paid leave taken in a given
workweek.

Working Time - Generally, time worked is considered all time a team member is on duty performing
assigned tasks and all time a team member is required to be on the Company’s premises or at a
designated work site.

Procedures for Non-Exempt Team Members - Non-exempt team members are responsible for
recording their time on the time clock. A non-exempt team member must record the team member's
own time at the beginning and end of each work shift. During regular work hours, a team member
must log out when leaving Company premises for non-work related reasons. A team member who
is having difficulty using the time clock may go to Human Resources for instructions on how to clock
in using an alternate method. Team members are not allowed to clock in/out using an alternate
method (i.e., ADP Mobile device) without expressed permission from Human Resources. If a non-
exempt team member works offsite for travel or special assignment, all work time must be tracked
and submitted to payroll via the ADP portal or manual punch sheet. All time spent performing work
on behalf of the Company, including time worked at home, is paid time and must be recorded.

Performing Work Before/After Scheduled Work Hours - A non-exempt team member is not
permitted to work overtime or unscheduled time without prior authorization from their supervisor. This
includes working before or after the team member’s scheduled work shift, working through the
scheduled lunch period, and working from home.

Arriving at Work Before/After Scheduled Work Hours - Arriving at work before the scheduled
starting time or leaving work after the scheduled ending time for a team member’s own convenience
when no work is performed for the Company is not to be included in working time.

Correction of Errors - Failure to log in/out on the bio-metric time clock should be brought to the
attention of the team member’s supervisor immediately, by completing a manual timesheet. The
supervisor shall investigate the matter and submit the correction to payroll.

Supervisor Responsibility – Supervisors are not allowed to permit or require that team members
work off the clock. If a supervisor becomes aware that work has been performed off the clock, they
are responsible for making the necessary corrections and counseling the team member about this
policy and the importance of accurate time keeping.

Falsification of Recorded Time - Team members are responsible for ensuring that their actual
hours worked and time off are accurately reported. Altering, falsifying, or tampering with a team
member's own time record or a coworker’s time record and/or recording time on another team
member’s time record is prohibited and may result in disciplinary action, up to and including
termination of employment for both team members.
G&C Foods 700-3 January 2024
Questions - Questions about overtime payments, deductions from your pay, issues regarding rate
of pay, and/or time keeping policies should be directed to your supervisor or Human Resources.
G&C Food’s policy prohibits retaliation against any team member who makes a report or complaint
in good faith regarding a violation of this policy.

703 Jury and Witness Duty

Policy Statement - Team members will be granted time off to serve on jury duty or to appear as a
witness in a criminal proceeding. In accordance with New York State law, a team member who is a
victim of a crime will be granted time off to appear in court as a witness, to consult with a district
attorney, or to obtain an order of protection. A team member will not be subject to adverse
employment action as a result of taking time off to serve as a juror or witness.

Notification Requirements - When a team member receives notice to report for jury duty or a
subpoena to testify as a witness, a copy of the notice/subpoena should immediately be submitted to
the Human Resource Department and their immediate supervisor.

Compensation for Non-Exempt Team Members - A non-exempt team member who is required to
report for jury duty on a regularly scheduled workday is paid full pay, for the team member's normally
scheduled work hours at the team member's base rate of pay, up to a maximum of the first 3 (three)
days. Thereafter, a non-exempt team member is paid by the Company but if any stipend is paid by
the court, it will be deducted. Time off for witness duty is without pay.

Compensation for Exempt Team Members - An exempt team member is paid the team member's
regular salary for the first 3 (three) days of jury duty, provided the team member is scheduled to work
for the Company on those days. Thereafter, in accordance with federal regulations, an exempt team
member is paid his or her regular salary for working any partial workweeks offset by any stipend
received from the court. An exempt team member is not paid for any workweeks in which no work is
performed for the Company. Time off for witness duty is without pay.

Verification of Service - A team member must provide written verification from the court noting the
date(s) and time(s) served as a juror or witness in order to receive payment from the Company.

Return to Work - A team member who is excused from court for the entire day must report to work
for the team member's scheduled work hours. If a team member is released early from jury or witness
duty on a given day, the team member must contact the team member’s supervisor to discuss
reporting requirements.

Accrual of Benefits - G&C Foods will continue to provide medical, dental, and life insurance benefits
for an eligible team member during the time spent as a juror or witness. All team member
contributions, if any, must be paid on a timely basis in order to maintain the continuous coverage of
benefits. PTO and holiday benefits also continue to accrue.

Rescheduling of Jury Duty - G&C Foods may request that a team member seek to have the jury
duty rescheduled.

G&C Foods 700-4 January 2024


704 Military and Reserve Leaves

Policy Statement - G&C Foods recognizes the importance of military service and complies with all
federal and state regulations relating to military leaves of absence, encampment, and temporary
military duty. If a team member is called into the military for extended leave, G&C will comply with
the terms of the Uniformed Services Employment and Reemployment Rights Act (“USERRA”) and
other similar federal, state or local laws and regulations relating to the re-employment rights of
persons entering military service.

Notification - A team member is required to give advance notice to the team member’s supervisor
of the dates of military service unless unable to do so because of military necessity or if it is otherwise
impossible or unreasonable to do so. A team member is asked to give as much notice as possible
and to bring his or her military service orders to their supervisor for review prior to commencement
of the leave.

Benefits during Leave - A team member retains and accrues any Company-sponsored benefits
that are tied to seniority during a military leave. The team member is also allowed to participate in
the medical insurance plan and other Company-sponsored benefits that are not determined by
seniority to the same extent as a team member who is granted a leave of absence for other reasons,
so long as the team member meets the eligibility requirements of each benefit plan. During a military
leave of 30 days or less, the Company will make its normal contribution towards a team member’s
insurance benefits.

Return from Leave - Upon returning from leave, a team member will be reinstated to his or her
position, or a similar position, and retains certain rights relating to seniority, status, length of service
promotions, and compensation upon return from military duty, as long as the team member is not
separated with a dishonorable or bad conduct discharge and the team member’s cumulative military
leave with the Company does not exceed five years. Certain types of uniformed service do not count
against a team member’s five-year maximum, including service during war or call-ups during national
emergencies, reserve drills, and annually scheduled active duty for training.

If a team member terminated coverage in G&C Foods health insurance plan or elected COBRA
or New York State health insurance continuation while on a military leave of absence, the team
member will be reinstated in the plan upon return to work without a waiting period or any pre-
existing exclusions.

Temporary Military Duty - The Company will attempt to rearrange a team member’s work schedule,
if possible, when the team member needs to attend a weekend drill or encampment.

Compensation for Exempt Team members - In accordance with federal regulations, an exempt
team member who is on military leave or reserve leave for any partial workweeks is paid the team
member's regular salary for those workweeks. Any military pay received is deducted from the team
member's salary. An exempt team member is not paid for any workweeks in which no work is
performed for the Company. A team member may request to use credited, unused PTO during the
leave.

Compensation for Non-Exempt Team members - Military leave and reserve leave is without pay
for a non-exempt team member. A non-exempt team member may request to use credited, unused
PTO during the leave.

Family and Medical Leave - A team member may be eligible for time off in accordance with the
Family and Medical Leave Act (FMLA) due to a covered family member’s active or impending military
duty or if a covered family member suffers a serious injury or illness while on active duty (See Policy
707 Family and Medical Leave for additional information).

G&C Foods 700-5 January 2024


705 Military Spousal Leave

Policy Statement - In accordance with New York State regulation, G&C Foods will grant an unpaid
leave of absence of up to ten days to a team member whose spouse is on leave from the military
under specified circumstances as described below. A team member who is entitled to Military
Spousal Leave may check with their employer to see if the circumstances overlap with the criteria
for a paid leave under NYPFL. If it does, both leaves will run concurrently.

Basic Leave Entitlements - An eligible team member may take an unpaid military spouse leave if
the following conditions are met:

• The team member’s spouse is a member of the U.S. Armed Forces, National Guard, or reserves;
• The spouse has been deployed during a period of military conflict to a combat theater or combat
zone of operations; and
• The spouse is on a leave from the military.

Eligibility - To be eligible for leave, a team member must work an average of 20 hours or more per
week. There is no minimum length of service requirement.

Notification Requirements – If possible, at least 30-calendar days notice must be given to the
Human Resource Department prior to the requested start date of the leave. When a leave is
unforeseen, a team member must give notice as soon as the need for a leave is known. A Leave of
Absence Request Form must also be jointly completed by the Company and the team member.
Permission or denial of the leave is normally communicated to the team member in writing within
one week after receiving the request.

Benefits during Leave - For the purpose of this policy, the following applies:

• Use of Paid Leave - Credited, unused PTO may be used at the start of the leave. The use of
paid leave benefits does not extend the leave of absence.
• Insurance Benefits – A team member’s insurance benefits will continue at the same level during
the leave of absence. The team member is responsible for his or her normal contributions toward
insurance benefits.

706 Bereavement Leave

Eligibility - In the event of a death of a full-time team member's immediate family member, the team
member is eligible for paid bereavement leave. In accordance with New York State regulation, a
bona fide domestic partner, regardless of gender, will be treated as a team member's spouse in
making a determination of benefit eligibility under this policy. Full-time team members become
eligible for paid bereavement leave upon hire. Part-time and temporary team members are eligible
for paid bereavement leave but on a prorated basis.

Allowance - Full-time team members are eligible for up to 3 (three) workdays off with pay from the
team member's regularly scheduled work hours. In the event that services are not held immediately
following the death, bereavement time may be used at a later date within 1 year of the date of death.

Verification of Need for Leave - The Company requires verification of the need for bereavement
leave (i.e., a copy of the obituary).

G&C Foods 700-6 January 2024


Immediate Family Member - For the purpose of this policy, an immediate family member is defined
as a team member's spouse, domestic partner, child, stepchild, parent, stepparent, grandparent,
grandparent-in-law, grandchild, sibling, step sibling, mother-in-law, father-in-law, sister-in-law,
brother-in-law, daughter-in-law, son-in-law, parent of a dependent child, and any other member of
the team member's household.

Extension of Bereavement Leave - A team member may request to use credited, unused PTO to
extend bereavement leave. If a team member has no paid leave available, unpaid leave may be
granted.

707 Family and Medical Leave Act (FMLA)

Policy Statement - In compliance with the federal Family and Medical Leave Act (FMLA), G&C will
grant an eligible team member unpaid, job-protected leave for specified family, medical, and military
reasons as described in this policy. Leave may also be available for some of the same purposes
under the New York State Paid Family Leave Law (“PFL”). See the PFL Policy below. When such
leave qualifies for both FMLA and PFL, the leaves will run concurrently.

Eligibility - To be eligible for leave under the FMLA, a team member must meet the following
requirements:
• Completion of at least 12 months of service with G&C Foods before the leave begins (the 12
months need not be consecutive, but must have occurred in the last seven years, unless the
break in service was to fulfill a team member’s military service obligation under USERRA); and
• Worked at least 1,250 hours during the previous 12 months prior to the date the leave begins.

Basic FMLA Entitlements - An eligible team member shall be granted up to 12 weeks of unpaid,
job-protected FMLA leave during any 12-month period under any of the following circumstances:

• Incapacity due to pregnancy, prenatal medical care, or childbirth (includes fathers who take leave
for their spouses’ prenatal care and appointments);
• To provide care for the team member’s child during the first 12 months following birth;
• Placement of a child with the team member for adoption or foster care and/or to care for the child
during the first 12 months following placement;
• To provide care for the team member’s spouse (includes same-sex spouse), child (includes son
or daughter of the same-sex spouse), or parent who has a serious health condition; or
• A serious health condition that makes the team member unable to perform the team member’s
job.

Serious Health Condition - The FMLA defines a serious health condition as an illness, injury,
impairment, or physical or mental condition that involves inpatient care in a medical care facility or
continuing treatment by a health care provider for a condition that either prevents the team member
from performing the functions of the team member’s job or prevents the qualified family member from
participating in school or other daily activities.

Continuing treatment by a health care provider includes:

• A period of incapacity of more than three consecutive calendar days combined with at least two
visits to a health care provider;
• One visit to a health care provider and a regimen of continuing treatment;
• Incapacity due to pregnancy or prenatal care; or
G&C Foods 700-7 January 2024
• Incapacity due to a chronic health condition.

Other conditions may also meet the definition of continuing treatment.

Ordinarily, unless complications arise, the common cold, flu, earaches, upset stomach, ulcers,
headaches other than migraines, routine dental problems, etc. do not qualify as serious health
conditions. In addition, routine medical examinations are not considered serious health conditions,
and neither are voluntary cosmetic treatments, unless inpatient care is required, or complications
develop. This list is not all inclusive.

Amount of Leave Available - An eligible team member will be granted up to a maximum of 12


workweeks of leave in any 12-month period for qualified family and medical reasons. A maximum
of 26 workweeks of leave in any 12-month period is available to care for a covered family member’s
serious injury or illness suffered in the line of active military duty.

Twelve-Month Period - The 12-month period used to determine eligibility for Basic FMLA leave is
a rolling period measured backward from the date a team member uses any FMLA leave. Each time
FMLA leave is taken, the Company will compute the amount of FMLA leave that has been used in
the last 12 months and subtract it from the 12 (or 26) weeks of available leave. The balance
remaining is the maximum amount of FMLA leave still available.

Military Family Leave

Qualifying Exigency Leave - Eligible team members whose spouse (includes same-sex spouse),
son, daughter or parent is on covered active duty or call to covered active duty status may use their
12-week leave entitlement to address certain qualifying exigencies. Qualifying exigencies are non-
medical, non-routine activities. Examples of qualifying exigencies may include short-notice
deployment (up to seven days), military events and related activities, childcare and school activities,
financial and legal arrangements, non-medical counseling, rest and recuperation (up to fifteen days),
and attending post-deployment activities (90-day period). G&C Foods and the team member can
agree to consider any other event that may arise out of active duty or a call to active duty status as
a qualified exigency.

Military Caregiver Leave - Eligible team members may take up to 26 workweeks (eligible airline
flight crew team members are entitled to 156 days) of FMLA leave in a “single 12-month period” to
care for a “covered service member” with a “serious injury or illness” if the team member is the
covered service member’s spouse (includes same-sex spouse), parent, son, daughter, or next of
kin.

A covered service member is:

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

(2) a veteran who was discharged or released under conditions other than dishonorable at any time
during the five-year period prior to the first date the eligible team member takes FMLA leave to
care for the covered veteran, and who is undergoing medical treatment, recuperation, or therapy
for a serious injury or illness. *

* Serious Injury or Illness for a Current Service member - FMLA defines a serious injury or illness
for a current service member as:

G&C Foods 700-8 January 2024


(i) an injury or illness incurred by a covered service member in the line of duty on active duty in the
Armed Forces that may render the service member medically unfit to perform the duties of his or
her office, grade, rank, or rating; or

(ii) An injury or illness that existed before the beginning of the service member’s active duty and was
aggravated by service in the line of duty on active duty in the Armed Forces.

Serious Injury or Illness for a Covered Veteran - A serious injury or illness for a covered veteran
means an injury or illness incurred that was incurred or aggravated by the member in the line of duty
on active duty in the Armed Forces and manifested itself before or after the service member became
a veteran, and is:

(i) a continuation of a serious injury or illness that was incurred or aggravated when the covered
veteran was a member of the Armed Forces and rendered the service member unable to perform
the duties of the service member’s office, grade, rank, or rating; or

(ii) a physical or mental condition for which the covered veteran has received a U.S. Department of
Veterans Affairs Service Related Disability Rating (VASRD) of 50 percent or greater, and such
VASRD rating is based, in whole or in part, on the condition precipitating the need for military
caregiver leave; or

(iii) a physical or mental condition that substantially impairs the covered veteran’s ability to secure or
follow a substantially gainful occupation by reason of a disability or disabilities related to military
service, or would do so absent treatment; or

(iv) an injury, including a psychological injury, on the basis of which the covered veteran has been
enrolled in the Department of Veterans’ Affairs Program of Comprehensive Assistance for Family
Caregivers.

Notification Requirements - When the need for FMLA leave is foreseeable, a team member must
submit a completed FMLA Request Form to the Human Resources Department at least 30-calendar
days prior to the requested start date of the leave. Failure to give the required notice with no
reasonable excuse may result in the FMLA leave being delayed or denied.

If unable to provide 30 days advance notice, a team member must request leave as soon as he or
she becomes aware of the need for leave. Such notice must normally comply with the Company’s
call-in procedures (See the Attendance policy for additional information).

The team member must provide sufficient information to enable the Company to determine if the
leave may qualify for FMLA. This may include that the team member is unable to perform his or her
job functions, that a family member is unable to perform daily activities, the need for hospitalization
or continuing treatment by a health care provider, or circumstances supporting the need for military
family leave. Calling in “sick,” without providing the reasons for the needed leave, will not be
considered sufficient notice for FMLA leave under this policy. Team members must respond to
G&C’s questions to determine if absences are potentially FMLA-qualifying. If team members fail to
explain the reasons for FMLA leave, the leave may be denied.

In addition, the team member must notify the Company if the requested leave is for a reason for
which FMLA has previously been taken or certified.

G&C Foods will determine if the team member is eligible for FMLA leave and will notify the team
member within five business days of receiving the team member’s FMLA Request Form or verbal
leave request. If approved, the team member will be notified if the leave will be designated as FMLA-
protected, any additional information required by the Company, the team member’s rights and

G&C Foods 700-9 January 2024


responsibilities, and the amount of leave that will be counted against the team member’s FMLA leave
entitlement. If ineligible for FMLA leave, the reason for the denial will be provided.

Certification - Proper documentation may be required to support a team member’s leave request.
Medical certification from a health care provider or relevant government agency is required for
leave requests due to a team member’s or family member’s serious health condition or the birth,
adoption, or foster placement of a child. Team members requesting leave for a qualifying exigency
must provide documentation of the military member’s active duty orders indicating the dates of their
service.

G&C reserves the right to have a team member or covered family member examined by a health
care provider of its choice for a second opinion at any time at its discretion. Any such second
opinion examination shall be paid for by G&C. In the event a conflict exists between the medical
opinion of the team member’s or covered family member’s health care provider and that of G&C in
the second opinion examination, a third examination will be required to be performed by a health
care provider mutually agreed upon by the team member and G&C, and paid for by G&C. In such
instances, the opinion of the third health care provider.

Use of Leave - Eligible team members may take FMLA leave in a single block of time, intermittently
(in separate blocks of time), or by reducing the normal work schedule when medically necessary for
the serious health condition of the team member or immediate family member, or in the case of a
covered servicemember’s injury or illness. Eligible team members may also take intermittent or
reduced scheduled leave for military qualifying exigencies. Intermittent leave is not permitted for birth
and care for a newly born child, or for the placement of a child for adoption or foster care unless the
employer agrees to allow intermittent leave. Team members who require intermittent or reduced-
schedule leave must try to schedule their leave so that it will not unduly disrupt business operations.

Status Reports - If the medical certification indicates a minimum duration for the period of incapacity,
the Company will generally not request recertification until such period has expired. If the medical
certification indicates the condition is expected to last for an extended period, medical recertification
must be provided every six months. The Company reserves the right to request medical
recertification more frequently if a team member requests a leave extension, circumstances have
changed significantly, or the Company receives information that casts doubt on the reason for the
absence.

Workers' Compensation, Disability, and PFL - Leaves taken under workers' compensation,
disability, or PFL may run concurrently with FMLA if a team member meets the FMLA eligibility
criteria outlined above, and the Company appropriately designates the leave as FMLA.

Benefits during Leave - For the purpose of this policy, the following applies to team member
benefits during a FMLA leave:

• Use of Paid Leave - If leave is running concurrently with workers’ compensation, disability, or
PFL, a team member must use their own available paid time off benefits to cover any mandated
benefit waiting period imposed. After the waiting period, and if the Company agrees, a team
member may have the option of using available paid time off benefits to supplement their wages.
The combination of all benefits paid to the team member may not exceed the team member’s
regular weekly earnings. If a team member is not, or is no longer receiving pay from workers’
compensation, disability, or PFL, the team member is required to use their available paid time off
benefits during the unpaid leave period.

• Accrual of Paid Leave Benefits - A team member will not lose any employment benefit that he
or she accrued prior to the start of the FMLA leave. A team member continues to accrue paid
leave benefits and receive holiday pay during any portion of a FMLA leave that is paid. For the

G&C Foods 700-10 January 2024


purpose of this policy, paid leave is defined as leave during which the team member is using
credited, unused PTO leave. After all such paid time off benefits are exhausted, the remaining
portion of the FMLA leave is unpaid. A team member does not accrue PTO or receive holiday
pay during any portion of a FMLA leave that is unpaid.

• Insurance Benefits - A team member’s FSA, group medical, dental, and vision insurance will
continue at the same level, terms, and conditions as if the team member was working. The team
member is responsible for their portion of the medical insurance premium cost, if any. Failure to
pay the team member portion of the health insurance premiums may result in the termination of
coverage if not paid within the pre-determined grace period. The team member will be given the
opportunity to choose continuation coverage under the COBRA regulations if he/she has not
returned to work at the end of the 12-week period.

Employment Restrictions - While on FMLA leave, a team member may not work for another
employer during the same work hours that he or she is normally scheduled to work for G&C Foods.

Early Return or Extension of Leave - If a team member intends to return to work earlier than
anticipated or extend the leave beyond the time originally requested, the Human Resources
Department must be notified at least two business days from the date the team member became
aware of the need to shorten/extend the leave.

Return-to-Work - At the conclusion of a FMLA leave, the following conditions apply:

• Return Date - If the team member’s leave request indicated a specific return-to-work date, he or
she should contact the Human Resources Department at least two weeks prior to this date. If
the return-to-work date was not known at the time leave was granted, the Human Resources
Department must be notified as soon as a return-to-work date has been established. Failure to
return to work when scheduled may result in disciplinary action, up to and including termination.

• Fitness-for-Duty Certification - If the FMLA leave was due to the team member’s own serious
health condition, a fitness-for-duty certification from the team member’s health care provider is
required prior to returning to work. The certification must address the team member’s ability to
perform the essential functions of the job, indicate any work restrictions, and release the team
member to return to work. In the event work restrictions are indicated, the Company reserves
the right to evaluate if the restrictions can be reasonably accommodated (See the Equal
Employment Opportunity policy). Failure to return the certification may result in delay or denial
of reinstatement; and
• Job Restoration - A team member shall be restored to the position held when the leave began
or to an equivalent position with equivalent benefits, pay, and other terms and conditions of
employment, provided he or she returns to work within the time period allowed under the FMLA
regulations.

• Fraud – A team member who fraudulently obtains FMLA leave is subject to disciplinary action,
up to and including termination.

Non-Retaliation - The FMLA makes it unlawful for employers to 1) interfere with, restrain, or deny
the exercise of any right provided under FMLA; or 2) discharge or discriminate against any person
for opposing any practice made unlawful by FMLA or involvement in any proceeding under or
relating to FMLA. G&C will not retaliate against any team member who exercises his/her rights
under the FMLA. If team members believe their FMLA rights have been violated, they should
contact the Human Resources Department immediately. G&C will investigate any FMLA
complaints and take prompt and appropriate remedial action to address and/or remedy any FMLA
violation. Team members also may file FMLA complaints with the United States Department of
Labor or may bring private lawsuits alleging FMLA violations.

G&C Foods 700-11 January 2024


708 New York Paid Family Leave

Policy Statement - In compliance with New York Paid Family Leave (NYPFL), G&C Foods will
provide eligible team members paid, job-protected family leave during any 12-month period for
specified family reasons as described below.

Eligibility - To be eligible for PFL, a team member must meet one of the two following conditions:
(1) be a G&C team member whose regular employment schedule is 20 or more hours per week and
who has been employed at G&C for 26 consecutive weeks immediately before he or she takes PFL,
or (2) be a G&C team member whose regular employment schedule is less than 20 hours per week
and who has worked 175 days at G&C before he or she takes PFL. Periods of temporary disability
shall not be counted as weeks of employment or days worked for determining eligibility for PFL.
Participation in the PFL program is mandatory for all team members, except for those individuals
eligible for a waiver (explained below).

PFL Waiver – Team members have the option to waive PFL benefits under the following limited
circumstances: (a) The team member is scheduled to work 20 or more hours per week but the team
member will not work 26 consecutive weeks; or (b) The team member is regularly scheduled to work
less than 20 hours per week and will not work 175 days in a 52 consecutive week period. However,
if a team member has elected to waive PFL coverage and their regular schedule changes such that
they work for either 26 consecutive weeks or 175 days in a consecutive 52-week period, the team
member’s waiver shall be deemed revoked and the team member will be obligated to begin making
contributions to the cost of PFL, including any retroactive amounts due from date of hire.

Basic Leave Entitlements - An eligible team member shall be granted paid leave in any 52-
consecutive week period under any of the following circumstances:

• To provide care for the team member’s child during the first 12 months following birth (paid family
leave only begins after birth and is not available for prenatal conditions);
• Placement of a child with the team member for adoption or foster care and/or to care for the child
during the first 12 months following placement;
• For a qualifying exigency as interpreted under the federal FMLA for a spouse, domestic partner,
child, or parent on active military duty (or notified of a call or order to active duty); or
• To care for a family member with a serious health condition. A family member includes a spouse,
domestic partner, child/stepchild, sibling (biological, adopted, step-, and half-siblings), parent
(biological, foster, or adoptive), a legal guardian, or other person who stood in loco parentis to
the team member when the team member was a child, parent-in-law, grandparent and
grandchild.

NYPFL cannot be used for one’s own serious health condition or military event. However, for short-
term disabilities - including pregnancy and other medical conditions - the team member may be able
to collect state disability benefits.

Serious Health Condition – A serious health condition means an illness, injury, impairment, or
physical or mental condition that involves: inpatient care in a hospital, hospice, or residential health
care facility; or continuing treatment or continuing supervision by a health care provider for a condition
that either prevents the qualified family member from working, attending school, performing other
daily activities or is otherwise incapacitated due to a chronic serious health condition. It also includes
transplantation preparation and recovery from surgery related to organ or tissue donation.

Continuing treatment by a health care provider includes, but is not limited to:

G&C Foods 700-12 January 2024


• A period of incapacity of more than three consecutive, full days combined with at least two visits
to a health care provider; or
• One visit to a health care provider and a regimen of continuing treatment; or
• Incapacity due to a chronic health condition.

Voluntary cosmetic treatments are not eligible conditions unless inpatient care is required, or
complications develop. Ordinarily, unless complications arise, the common cold, flu, earaches, upset
stomach, minor ulcers, headaches other than migraines, routine dental or orthodontia problems,
periodontal disease, etc. do not qualify as serious health conditions. In addition, routine medical
examinations do not qualify for NYPFL. This list is not all inclusive.

Cost - Team members are responsible for 100% of the premium based on a percentage of the team
member's weekly wage capped at New York State's current average weekly wage. This "weekly
wage" is reviewed and re-determined July 1st each year by New York State.

Length of Paid Leave and Benefits - The maximum benefit rate and length of paid leave is 67%
of the team member’s average weekly salary or 67% of the maximum average weekly wage as
defined by New York State, whichever is less, and a maximum of 12 weeks of leave.

Notification Requirements - When the need for paid family leave is foreseeable, a team member
must submit a written request to Human Resources at least 30 days prior to the requested start date
of the leave.

If a team member is unable to provide 30 days notice (due to, for example, lack of knowledge, a
change in circumstances, or a medical emergency), notice must be provided as soon as he or she
become aware of the need for leave. Such notice must normally comply with the Company’s call-in
procedures (See Attendance Policy). The team member must indicate the anticipated length of the
leave and provide sufficient information about the reason for absence to allow the Company to
determine if the leave may qualify for NYPFL.

Certification - Medical certification from a health care provider is required for leave requests due to
a family member’s serious health condition or the birth of a child. Documentation from the
appropriate agency is required to support a leave request due to the adoption or foster placement of
a child.

Applying for PFL Benefits - Team members needing PFL must notify the Human Resources
Department. In order to receive income replacement benefits while on PFL, a team member must
submit a claim form to G&C Foods’s PFL insurance carrier using the applicable Paid Family Leave
forms. The claim form(s) will provide details regarding the documentation that will be required to
support the request for PFL benefits. These forms may be obtained from the Human Resources
Department.

Team members are responsible for timely filing their own PFL claim(s) with G&C Foods’s insurance
carrier. Team members have 30 days from the date PFL is taken to file the claim. G&C Foods will
not file a claim on a team member’s behalf. The insurance carrier has 18 days, from the date of
submission, to make an approval decision.

Use of Leave - NYPFL is only available in full day increments, but it can be taken intermittently. A
team member is responsible for making reasonable efforts to schedule leave for planned medical
treatment so as not to unduly disrupt business operations.

Workers' Compensation - A team member that is not working and collecting workers’
compensation is not eligible for NYPFL.

G&C Foods 700-13 January 2024


Interrelationship of NYPFL and NYS Disability Benefits - NYPFL and NYS Disability benefits
cannot be collected at the same time. If a team member is eligible for both, the combined total in
any 52-week period may not exceed 26 weeks. A female team member who is going to have a baby
would be allowed to take the period of incapacitation defined by her physician, followed by the
maximum length of PFL offered. A team member who opts to take NYPFL first may do so, but since
they will no longer be disabled after the 8 weeks of NYPFL, they would not be eligible for paid NYS
Disability benefits at the conclusion of NYPFL.

Interrelationship of NYPFL and Federal FMLA - In certain instances, the NYPFL and FMLA will
overlap. Where leave is taken for a reason specified in both the FMLA and NYPFL, the leave will
run concurrently, this means that PFL time can’t be added to FMLA time to extend the overall leave.
For example, a team member who takes a leave for the purpose of caring for a newborn or adopted
child may have their leave counted simultaneously against their 12-week entitlement under FMLA
and their entitlement under the NYPFL.

If a team member’s need for leave qualifies under both PFL and FMLA, but the team member
declines to apply for PFL benefits (despite being notified that the reason for leave is a PFL-qualifying
reason), any leave taken by the team member for such reason will nevertheless be counted against
the team member’s PFL entitlement.

Benefits During Leave - For the purpose of this policy, the following applies to team member
benefits during a NYPFL leave:

• A team member will not lose any employment benefit that accrued prior to the start of the PFL
leave.

• An employer may not require a team member to use their available paid time off benefits before
using NYPFL.

• If a team member takes PFL but would prefer to receive his/her full pay, the team member may
elect to substitute a full day of accrued paid time off (vacation or personal time). In this instance,
the team member is still required to file a claim with G&C’s insurance carrier, though the team
member will not receive the PFL wage replacement benefit. Any paid time off substituted by the
team member will be counted against his/her PFL allotment.

• A team member has the option to supplement his/her PFL benefit with accrued paid time off
(vacation or personal time) in order to receive full pay. In no event can the combination of PFL
benefits and paid time off result in the receipt of more than 100% of a team member’s regular
wages.

• Accrual of Paid Leave Benefits - A team member continues to accrue PTO leave during any
portion of a NYPFL.

• Insurance Benefits - A team member’s group medical, dental, vision, etc. will continue at the
same level, terms, and conditions as if the team member was working and the team member will
be responsible for their portion of the insurance premium, if any. Failure to pay the team member
portion of the insurance premium may result in the termination of coverage.

• Employment Restrictions - While on NYPFL, a team member may not work for another
employer during the same work hours that he or she is normally scheduled to work for G&C
Foods.

• Early Return or Extension of Leave - If a team member intends to return to work earlier than
anticipated or extend the leave beyond the time originally requested, the Human Resources
G&C Foods 700-14 January 2024
Department must be notified at least two business days from the date the team member became
aware of the need to shorten/extend the leave.

Return-to-Work Date - If the team member’s leave request indicated a specific return-to-work date,
he or she should contact Human Resources at least two weeks prior to this date. If the return-to-
work date was not known at the time leave was granted, the Human Resources Department must
be notified as soon as a return-to-work date has been established. Failure to return to work when
scheduled may result in disciplinary action, up to and including termination.

Job Restoration - A team member shall be restored to the position held when the leave began or
to an equivalent position with equivalent benefits, pay, and other terms and conditions of
employment, provided he or she returns to work within the time period allowed under the NYPFL
regulations. A key team member may be denied reinstatement rights if such reinstatement would
cause substantial and grievous economic injury to G&C Foods.

Fraud - A team member who fraudulently obtains NYPFL is subject to disciplinary action, up to and
including termination.

709 Leaves of Absence

Policy Statement - A team member who does not meet the FMLA or New York Paid Family Leave
eligibility requirements or who has exhausted his or her leave entitlement under the FMLA or NYPFL
may request a leave of absence due to medical, family, or personal reasons. The granting and
duration of each leave of absence is determined by the Company and is not guaranteed. A team
member must give written notice to the HR Manager at least 30-calendar days prior to the requested
start date of the leave.

710 Time Off to Vote

Policy Statement - In accordance with New York State Election Law, a team member who is a
registered voter and does not have sufficient time outside of his or her scheduled working hours
to vote in a public election when the polls are open, will be given up to two hours off with pay at
the beginning or end of the team member’s shift to vote. A team member is deemed to have
“sufficient time to vote” if they have four consecutive hours off either from the opening of the polls to
the beginning of their work shift, or between the end of their work shift and the closing of the polls.

Any additional time off needed is without pay for non-exempt team members unless credited, unused
PTO leave is used.

Time Off Requests - A team member who needs time off from work to vote must submit a time off
request to the team member’s supervisor no more than 10 or less than two workdays before an
election.

711 Time Off to Donate Blood or Bone Marrow

Policy Statement - In accordance with New York State regulation, eligible team members are
granted unpaid time off during regular work hours to donate blood and/or to undergo a medical
procedure to donate bone marrow.

G&C Foods 700-15 January 2024


Eligibility – A team member who works an average of 20 or more hours per week will be granted at
least one leave of absence of up to three hours per calendar year during the team member’s regular
work hours to donate blood at an off-site location.

Time Off Requests - A team member must request time off at least three working days in advance.
If the team member is donating blood for his or her own surgery or surgery of a family member, a
shorter notice period will be accepted.

Verification of Absence – A team member is responsible for providing verification from a blood
bank or similar organization showing that the leave of absence was to donate blood.

Donating Bone Marrow - The combined length of the absence shall be determined by the team
member’s health care provider but may not exceed 24 work hours unless otherwise authorized
by the team member’s supervisor. G&C Foods may require verification by a physician
for the purpose and length of each absence requested by a team member to donate bone marrow.
Exempt team members who have no paid time off benefits available will not be docked for any
partial-day absences for this purpose.

Use of Paid Leave Benefits – A team member may elect to use credited, unused PTO; otherwise,
the time off is without pay. Exempt team members who have no accrued paid time available will
not be docked for any partial-day absences.

712 Volunteer Emergency First Responders

Policy Statement – G&C Foods understands the need for recognized volunteer community services
and companies to provide them. The Company may grant requests to team members who are
volunteer firefighters or members of a volunteer ambulance corps to take reasonable leave to
respond to declared states of emergency.

Declared States of Emergency - In the event the governor declares a state of emergency where
the team member’s volunteer fire department and/or ambulance service is called upon to respond,
the team member must notify the Human Resource Department of their intent to take leave and, if
possible, provide an estimate of the duration of the absence. If the company determines that the
team member’s absence will not create an undue business hardship, the team member will be
granted a leave of absence to respond to the declared emergency.

Local Emergencies - In the event there is a local emergency where the team member’s volunteer
fire department and/or ambulance service is called upon to respond, a team member may be
excused without corrective discipline.

Authorization - A team member may not leave work to respond to a call without the permission of
their supervisor.

Verification of Service - Within 3 business days of return to work, the team member must provide
a letter from the head of the fire department and/or ambulance service confirming the dates and
times of their volunteer service. Failure to provide this documentation will result in the tardiness or
absence being regarded as unauthorized, in which case the team member will be subject to
corrective discipline up to and including termination.

Compensation for Exempt Team members - An exempt team member who is on approved first
responder leave for any partial workdays is paid the team member's regular salary for those
workdays. A team member may request to use credited, unused PTO leave during any portions of
the leave that are unpaid.

G&C Foods 700-16 January 2024


Compensation for Non-Exempt Team members - First responder leave is without pay for a non-
exempt team member. A team member may request to use credited, unused PTO leave during the
excused absence.

Prohibition on Termination and Discipline- No employer shall terminate or discipline a team


member who is a volunteer emergency responder and, in the line of duty, has responded to a call
prior to the time he was due to report for work resulting in an overlap with their normally scheduled
shift/workday.

G&C Foods 700-17 January 2024


800 COMPENSATION

801 Pay Rates and Pay Increases

Pay Rates - G&C Food’s goal is to compensate each team member based on merit, consistent with
their job duties and responsibilities, and competitive with wages being paid for similar work in the
community and industry. In addition, all compensation policy decisions take into consideration the
Company’s overall financial condition.

Notice and Acknowledgement of Pay Rate and Payday - A new team member will receive written
notification within 10 days of hire of the team member’s rate of pay, method of pay (e.g., hourly,
salary), eligibility for overtime, and other information as required by New York State labor regulation.
The Company will provide at least seven calendar days advance written notice to the team member
of any changes to this information or the changes will be reflected on the team member’s pay stub.

Call-In Pay - If a team member who is paid at the New York State minimum wage rate is required or
permitted to report to work and is sent home early, the team member will be paid for 4 (four) hours
or the number of hours in the team member's scheduled shift, whichever is less. In some cases, a
team member who is paid slightly above the minimum wage rate may also be eligible for call-in pay.

Merit Pay Increases - Merit-based pay increases may be awarded by the Company any time it is
warranted. Any pay increase received is based on merit, productivity, quality of work, attendance,
punctuality, work ethic, and financial capability of the Company.

802 Overtime

Policy Statement - To meet operational requirements, a team member may be required to work
beyond the team member's normally scheduled work hours and/or work on a normally scheduled
day off.

Authorization - A non-exempt team member must receive authorization from the team member's
supervisor before working beyond the team member's scheduled work hours. A non-exempt team
member who works overtime without prior authorization may be subject to discipline, up to and
including termination of employment. It is expected that an exempt team member may need to work
beyond the team member's scheduled work hours on an as needed basis. An exempt team member
does not need prior supervisory approval to work overtime hours.

Compensation for Non-Exempt Team Members – An hourly non-exempt team member receives
overtime compensation for all hours worked in excess of 40 during a workweek at 1½ times the team
member's regular rate of pay.

Compensation for Exempt Team Members - An exempt team member is not eligible to receive
additional or overtime compensation for any hours worked in excess of the team member's normal
workday or workweek, including any hours worked over 40 during the workweek. However, exempt
team members may occasionally be eligible for overtime compensation for working extraordinary
overtime hours or for work performed on special assignments.

Mandatory Overtime - Team members are expected to work additional hours as needed to maintain
optimal business operations. A team member’s failure to work overtime hours that have been
required or requested by the team member's supervisor may result in disciplinary action.

G&C Foods 800-1 January 2024


803 Payroll Period and Payday

Payroll Period - The payroll period begins on Saturday and ends seven calendar days later on
Friday.

Payday - Team members are paid weekly on Friday for the hours worked during the previous pay
period. If a payday falls on a designated holiday, team members are normally paid on the preceding
workday. The Company will notify team members in advance of any changes in pay days.

Commissions – Team members who are paid on a commission basis are paid their earned
commission according to the Company’s written commission plan. Refer to Separation from
Employment (Policy 306) for information regarding the payment of commissions at the time
employment ends.

Distribution - First paychecks are generally live/paper checks and can be picked up in Human
Resources after 4pm on Thursdays.

Direct Deposit - A team member may elect to have all, or part of the team member’s paycheck
deposited directly into a checking, savings or pay card account at the team member’s designated
financial institution each payday. All elections and changes are processed through the ADP portal.

Authorized Check Release - A team member’s supervisor shall not release a paycheck to anyone
other than the team member unless the team member has provided a signed, written authorization
to the Company.

804 Payroll Deductions

Statutory and Voluntary Deductions - In compliance with government regulations, G&C Foods
deducts the required portion of a team member's wages for federal, state, and social security and
Medicare taxes and court-ordered wage garnishments. A team member may voluntarily authorize
payroll deductions for items that are for the benefit of the team member, such as insurance benefits
and the retirement plan, by submitting a written authorization to the Company. All statutory and
voluntary payroll deductions are indicated on a team member’s pay stub.

Deductions from Exempt Team Members’ Pay - In accordance with state and federal employment
regulations, exempt team members are paid on a salary or fee basis. Exempt team members receive
a predetermined amount each pay period that is not reduced because of variations in the quality or
quantity of their work. However, there are certain circumstances where deductions from exempt
team members’ pay are permissible. Such circumstances include:

• Absences from work for one or more full days for personal reasons other than sickness or
disability;
• Absences of one or more full days due to sickness or disability if the deduction is made in
accordance with the Company’s plan, policy, or practice of providing compensation for salary
lost due to illness;
• To offset jury and witness fees or military pay;
• Unpaid suspensions of one or more full days for violations of workplace conduct rules;
• Penalties for infractions of safety rules of major significance;
• Weeks in which unpaid FMLA leave is taken; or

G&C Foods 800-2 January 2024


• During the initial or last week of employment if the team member does not work the entire
workweek.

Improper Payroll Deductions - The Company prohibits any deductions from a team member’s
paycheck that are in violation of federal or state regulations. A team member who believes that an
improper paycheck deduction has been made should contact the Payroll Administrator immediately.
If it is determined that an improper deduction was made, the team member will be promptly
reimbursed. A team member will not be subject to any form of retaliation for raising a concern over
payroll or other issues concerning the calculation of their pay.

Overpayment - In the event a team member is overpaid due to a mathematical or clerical error, G&C
Foods will make arrangements to collect the overpayment. Both the HR Manager and the team
member will sign an acknowledgment form signifying agreement to the correction.

Questions - Questions concerning paycheck deductions or how they were calculated should be
directed to the Payroll Administrator.

Wage Garnishments - G&C Foods is required to comply with any court ordered garnishment of
team member wages. A team member is notified as soon as possible if the Company is required by
court order to deduct any garnishments from the team member's wages.

G&C Foods 800-3 January 2024


900 TEAM MEMBER BENEFITS
901 Team Member Benefits Administration

Policy Statement - G&C Foods offers team members a comprehensive benefits package. Eligibility
for benefits is dependent upon several factors, including employment classification and length of
service.

Plan Documents – Team member benefits are administered according to applicable government
regulation, insurance contract, certificate of coverage, plan document, and/or Company policy. In
the event of a discrepancy between the information presented in this Team member Handbook and
the applicable government regulation or insurance document, the government regulation or
insurance document will take precedence. In addition, the Company has discretionary authority to
determine eligibility for benefits and to interpret the terms of each benefit plan.

Changes in Benefits - The Company reserves the right to add, modify, or terminate benefits for all
current, former, and retired team members, to change carriers, and/or offer alternative insurance
plans at any time. Further, all Company contributions are subject to change at any time. G&C Foods
also reserves the right to make determinations of eligibility for benefits in its sole discretion and to
revise these eligibility requirements without notice.

Plan Administrator - The Human Resource Manager is the Plan Administrator of the Company's
benefit plans. The Plan Administrator is responsible for all team member communications and
disclosures concerning Company benefits and is available to answer any questions.

Enrollment Information - A team member must complete the applicable insurance enrollment forms
and payroll deduction authorization forms in order to receive insurance benefits.

Waiver of Benefits - A team member who is eligible to participate in an insurance plan but who
declines coverage must sign a waiver declining such coverage.

Change in Employment Classification - If a team member's employment classification changes


from part-time to full-time, the team member becomes eligible for full-time team member benefits on
the first day of the month following the change of status, or when the waiting period has been
completed. If a team member's employment classification changes from full-time to part-time, the
team member shall be notified of any changes in Company benefits, including insurance coverage
continuation, if applicable. The team member will retain any credited, unused, PTO, credited as a
full-time team member for the remainder of the current benefit year, in accordance with the applicable
policy.

The following is a brief overview of the benefits available to eligible team members. It is intended as
a source of general information only. More detailed information on insurance benefits is available in
the applicable plan document or government regulation.

G&C Foods 900-1 January 2024


902 Medical Insurance

Policy Statement - The Company offers eligible team members comprehensive group medical
insurance coverage.

Eligibility - Full-time, exempt team members are eligible to participate in the medical insurance plan
on the first of the month following their hire/rehire date provided all eligibility requirements of the plan
are met. Eligible team members may also enroll in the medical insurance plan during the annual
open enrollment period or at the time of a qualified change in employment or family status, as defined
by the Internal Revenue Service (IRS) and the insurance carrier. Part-time and temporary team
members are not eligible for medical insurance coverage but have the option of purchasing health
insurance available through the Health Insurance Marketplace at their own expense.

Coverage - Eligible team members have the option of individual, two person, and family coverage.
Other health coverage alternatives may be available to you through the Health Insurance
Marketplace. For more information about health insurance options available through a Health
Insurance Marketplace, visit www.healthcare.gov.

Premium Payment - G&C Foods contributes a percentage towards the premium for individual, two
person, or family medical insurance coverage for each eligible team member.

Cancellation of Coverage – If a team member is making pre-tax deductions, they must experience
a qualifying event to cancel or change coverage. The appropriate insurance cancellation form may
be obtained from the Plan Administrator. Cancellation becomes effective the first of the month
following the date the completed cancellation form is submitted to the Human Resource Department.
Upon separation of employment, a team members’ medical coverage is cancelled effective the same
day that they terminate employment.

Continuation of Coverage - In the event a covered team member, spouse, and/or dependents lose
their medical insurance coverage, they may be eligible to continue such coverage at their own
expense under certain qualifying conditions (See Policy 904 Continuation of Benefits).

903 Dental Plan

Policy Statement - The Company offers eligible team members a comprehensive group dental plan.

Eligibility - Full-time, exempt team members are eligible to participate in the dental plan on the first
of the month following their hire/rehire date provided all eligibility requirements of the plan are met.
Eligible team members may also enroll in the dental insurance plan during the annual open
enrollment period or at the time of a qualified change in employment or family status, as defined by
the Internal Revenue Service (IRS) and the insurance carrier. Part-time and temporary team
members are not eligible for dental insurance coverage.

Coverage - Eligible team members have the option of choosing between individual, double/two
person or family coverage.

Premium Payment – Team members are responsible for 100% of the cost of dental insurance.

Cancellation of Coverage - If a team member is making pre-tax deductions, they must experience
a qualifying event to cancel or change coverage. The appropriate cancellation form may be obtained
from the Plan Administrator. Cancellation becomes effective on the first of the month following the
date the completed cancellation form is submitted to the Plan Administrator. Upon separation of
employment, a team member’s dental coverage is cancelled the same day that they terminate
employment.

G&C Foods 900-2 January 2024


Continuation of Coverage - In the event a covered team member, spouse, and/or dependents lose
their dental coverage, they may be eligible to continue such coverage at their own expense under
certain qualifying conditions (See Policy 904 Continuation of Benefits).

904 Vision Insurance

Policy Statement - The Company offers eligible team members comprehensive vision insurance
coverage.

Eligibility - Full-time, exempt team members are eligible to participate in the vision plan on the first
of the month following their hire/rehire date provided all eligibility requirements of the plan are met.
Eligible team members may also enroll in the vision insurance plan during the annual open
enrollment period or at the time of a qualified change in employment or family status, as defined by
the Internal Revenue Service (IRS) and the insurance carrier. Part-time and temporary team
members are not eligible for vision insurance coverage.

Coverage - Eligible team members have the option of choosing between individual, double/two
person or family coverage.

Premium Payment - Team members are responsible for 100% of the cost of vision insurance.

Cancellation of Coverage - If a team member is making pre-tax deductions, they must experience
a qualifying event to cancel or change coverage. The appropriate cancellation form may be obtained
from the Plan Administrator. Cancellation becomes effective on the first of the month following the
date the completed cancellation form is submitted to the Plan Administrator. Upon separation of
employment, a team member’s vision coverage is cancelled the same day that they terminate
employment.

Continuation of Coverage - In the event a covered team member, spouse, and/or dependents lose
their vision coverage, they may be eligible to continue such coverage at their own expense under
certain qualifying conditions (See Policy 904 Continuation of Benefits).

905 Continuation of Insurance Benefits

Policy Statement - The Consolidated Omnibus Budget Reconciliation Act commonly referred to as
COBRA and New York State insurance regulation give team members and covered dependents the
opportunity to continue their group health coverage at group rates after coverage would normally be
lost due to any of the following qualifying events:

• Team member’s separation from employment for reasons other than gross misconduct;
• Team member’s reduction in work hours;
• Team member’s military leave of absence;
• Team member’s legal separation or divorce;
• Team member’s entitlement to Medicare;
• A dependent’s loss of dependent child status under the plan; or
• Death of the team member.

Eligibility - An individual who meets the definition of a “qualified beneficiary” is eligible for insurance
continuation coverage. A “qualified beneficiary” is an individual who was covered under a group
health plan on the day before a qualifying event as either a covered team member, the spouse of a
covered team member, or a dependent child of a covered team member. A child who is born to, or

G&C Foods 900-3 January 2024


placed for adoption with, the covered team member during a period of continuation coverage is also
a qualified beneficiary.

Cost - A qualified beneficiary who elects continuation coverage is responsible for 100% of the cost
of the insurance premiums. The Company may also charge a 2% administrative fee.

Maximum Continuation Period – Each qualified beneficiary has the option of electing insurance
continuation coverage for a limited period of time. In accordance with New York State insurance
regulation, a qualified beneficiary who elects to continue his or her group health insurance coverage
after experiencing a qualifying event may continue such coverage for up to 36 months, regardless of
the qualifying event. The maximum continuation coverage period for dental insurance varies from
18 to 36 months, depending on the specific qualifying event. The table below indicates the maximum
insurance continuation period available based on each qualifying event.

Maximum Insurance
Continuation Period
Qualified
Qualifying Event Dental Insurance Health Insurance
Beneficiaries
Team member,
Separation from
spouse, and 18 months 36 months
employment
dependents
Team member,
Reduction in team
spouse, and 18 months 36 months
member’s work hours
dependents
Team member,
Military leave of absence spouse, and 24 months 36 months
dependents
Team member,
Qualifying disability spouse, and 29 months 36 months
dependents
Spouse and
Team member’s death 36 months 36 months
dependents
Divorce or legal separation
Spouse and
of team member and 36 months 36 months
dependents
spouse
Team member entitled to Spouse and
36 months 36 months
Medicare dependents
Change in dependent
Dependents 36 months 36 months
status

Change in Status - A covered team member or qualified beneficiary must submit a completed
Qualified Beneficiary Notice of Qualifying Event Form to the Plan Administrator when there is a legal
separation, divorce, the team member becomes covered by Medicare, or a child’s loss of dependent
status. The Plan Administrator must also be notified of a second qualifying event or a Social Security
Disability determination which could extend the continuation coverage period. Notification must
generally be provided to the Plan Administrator no later than 60 days from either the date of the
qualifying event/disability determination or the date the qualified beneficiary would lose coverage due
to such event.

The Company is not responsible for errors in coverage that result due to a team member's failure to
provide timely notification to the Plan Administrator of such an event.

Questions - Full details regarding insurance continuation coverage is available in the plan’s
Summary Plan Description (SPD) or by contacting the Plan Administrator.
G&C Foods 900-4 January 2024
Marketplace Options – Instead of enrolling in COBRA continuation coverage, other health coverage
alternatives may be available to you through the Health Insurance Marketplace where you may be
able to get coverage that costs less than COBRA continuation coverage. For more information about
health insurance options available through a Health Insurance Marketplace, visit
www.healthcare.gov or call 1-800-318-2596.

906 Section 125 Plan

Eligibility - Full-time team members may enroll in a Section 125 plan provided all eligibility
requirements of the plan are met. Part-time and temporary team members are not eligible for this
benefit. The options offered under the Section 125 plan are summarized below.

Pre-Tax Insurance Premiums - A team member may elect to pay the team member's contribution
towards the medical, dental, and vision insurance premiums with pre-tax dollars, which means
deductions are taken from the team member's paycheck before federal, state, and social security
taxes are calculated. This reduces the team member's taxable income and increases net wages.

Cash In-Lieu of Insurance - A team member who is eligible to participate in the medical insurance
plan has the option of receiving cash in lieu of the insurance. To be eligible for this option, the team
member must provide documentation of comparable medical insurance coverage and sign a
waiver declining coverage through the Company. A team member who elects this option receives
up to $1000 per year. The cash benefit paid is determined each plan year. This payment is added
to the team member's paycheck on an after-tax basis.

Flexible Spending Accounts - A team member may elect to have a pre-determined amount
deducted from the team member's paycheck on a pre-tax basis each pay period to be placed in a
medical flexible spending account (FSA), dependent care FSA, or both. Money a team member sets
aside in a medical FSA may be used to cover certain medical, dental, and vision care expenses that
are not reimbursable through the team member's insurance plan(s). Money set aside in a dependent
care FSA may be used to cover eligible day care and nursery school expenses for covered
dependents.

Election Changes - Eligible team members may enroll in or decline coverage in the Section 125
Plan during the annual open enrollment period. Once a pre-tax election is made, it must remain in
effect for the entire plan year. A team member may not drop coverage, change an election, or cease
contributions at any time during the plan year unless there is a qualifying change in employment or
family status, as defined by the IRS and the insurance carrier. A team member must make the
appropriate change in coverage within 31 days of the date of the qualifying event.

907 Health Savings Accounts

Health Savings Accounts- A team member may elect to have an amount deducted on a pre-tax
basis from the team member's paycheck each pay period to be placed in a Health Savings Account.
Money a team member sets aside in an HSA may be used to cover certain medical, dental, and
vision care expenses that are not reimbursable through the team member's insurance plan(s).

Eligibility- To be an eligible individual and qualify for an HSA, you must meet the following
requirements.

• You must be covered under a high deductible health plan (HDHP).


• You are not covered under any other health plan.

G&C Foods 900-5 January 2024


• You are not enrolled in Medicare.
• You cannot be claimed as a dependent on someone else's tax return.

Establishing a Health Savings Account-An eligible team member may set up their H.S.A. account
at any financial institution offering H.S.A. services. Team members must complete an enrollment
form authorizing the payroll deduction and providing direct deposit information. H.S.A. funds must
be payroll deducted and direct deposited into a team member’s account.

Team members must designate a beneficiary upon establishing their account, and for any
subsequent beneficiary changes. The company cannot make changes that are not initiated by the
team member in writing. The company will not be responsible for the result of a team member’s
failure to designate a current beneficiary of failure to comply with current H.S.A. regulations.

Account Management- H.S.A. accounts are governed by the Internal Revenue Service guidelines
and are subject to maximum contribution limits. Team members are responsible for complying with
all IRS regulations governing use of funds in their account for paying qualified medical expenses.
Team members who violate the IRS regulations for medical expense reimbursement are subject to
penalties and fines imposed by the IRS.

Separation from employment- An H.S.A. account is owned by the individual team member and a
team member retains ownership to account funds upon separation from employment. Payroll
deductions cease with the last paycheck a team member receives. However, the team member can
contribute directly to their H.S.A. following separation from employment.

908 Flexible Spending Accounts

Flexible Spending Accounts - A team member may elect to have a pre-determined amount
deducted on a pre-tax basis from the team member's paycheck each pay period to be placed in a
medical flexible spending account (FSA), dependent care FSA, or both. Money a team member sets
aside in a medical FSA may be used to cover certain medical, dental, and vision care expenses that
are not reimbursable through the team member's insurance plan(s). Money set aside in a dependent
care FSA may be used to cover eligible day care and nursery school expenses for covered
dependents.

To receive reimbursement from a team member's FSA account, a claim for reimbursement and proof
that the expense was incurred during the current plan year must be submitted to the Plan
Administrator.

The plan year is May 1st – April 30th. The Company has established a grace period during which a
team member can incur reimbursable expenses. A team member may submit claims for eligible
expenses that were incurred during the current plan year up to 75 days after the plan year ends. Any
refunds remaining in a team member’s account at the end of the plan year are forfeited.

Election Changes - Eligible team members may enroll in or decline coverage in the Flexible
Spending Plan during the annual open enrollment period. Once a pre-tax election is made, it must
remain in effect for the entire plan year unless a qualifying change in employment or family status,
as defined by the IRS and the insurance carrier.

G&C Foods 900-6 January 2024


909 Life Insurance

Eligibility - G&C Foods offers group term life insurance coverage to full-time team members on
the first of the month following 30 calendar days provided all eligibility requirements of the plan are
met. Part-time team members are not eligible to participate in the life insurance plan.

Coverage - The amount of the life insurance coverage is equal to the team member’s annual gross
earnings, up to a maximum of $50,000. Optional group life insurance coverage for a team member’s
spouse (includes same sex spouses) and or dependents is available at the team member’s expense.

Premium Payment - G&C Foods pays 100% of the life insurance premium for eligible team
members. The team member is responsible for 100% of the premium for optional team member life
as well as optional spouse and/or dependent coverage.

910 Retirement Plan

Policy Statement - G&C Foods administers a 401(k) plan that allows eligible team members to save
towards their retirement. More detailed information on the 401(k) plan is available in the applicable
plan document.

Eligibility – Team members who are 18 years of age or older are eligible to participate on the first
of the month following their hire date.

Contributions - A team member may contribute any percentage of the team member’s eligible
compensation to the plan, subject to limitations set by the IRS. A team member’s contributions are
made on a pre-tax basis (401k) or post-tax basis (401k Roth).

Discretionary Company Match - The Company may contribute a percentage of a team member's
compensation to the team member’s plan. The Company’s match contribution is subject to change.
Any change in match contribution level is generally announced in advance.

911 Paid Time Off (PTO)

Eligibility - Full-time non-exempt team members are eligible to begin accruing paid time off for a
period of rest and relaxation in recognition for services performed throughout the year beginning on
their date of hire.

The PTO policy is inclusive of the New York paid sick leave law, which allows team members to use
their PTO for the reasons allowed under that law, as described below:

• the need for diagnosis, care, or treatment of a mental or physical illness, injury, health
condition, or preventative care of the team member or the team member’s family member; and
• certain needs related to the team member or the team member’s family member being the
victim of domestic violence, sexual offenses, stalking, or human trafficking, including obtaining
services from a domestic violence shelter, rape crisis center, or other services program;
participating in safety planning; temporarily or permanently relocating; meeting with an attorney
or participating in legal proceedings; enrolling children in a new school; or taking other actions
to increase the safety of the team member or team member’s family members.

Definition of Family Member - For purposes of this policy, family member includes a team
member’s child (biological, adopted, or foster child, legal ward, or child of a team member standing
in loco parentis), spouse, domestic partner, parent (biological, foster, step, adoptive, legal guardian,
or person who stood in loco parentis when the team member was a minor child), sibling, grandchild,
or grandparent; and the child or parent of a team member’s spouse or domestic partner.
G&C Foods 900-7 January 2024
Allowance - Eligible team members are credited with PTO in accordance with the following
schedule:

COMPLETED, CONTINUOUS
LENGTH OF SERVICE AS OF PTO HOURS
ANNIVERSARY DATE
0 - 6 Years 120 hours-2.31 hours per paycheck
7 - 14 Years 160 hours- 3.08 hours per paycheck
15 + Years 200 hours– 3.85 hours per paycheck

Your PTO hours will be accrued throughout the year. This means that with each paycheck you will
earn a small amount of your PTO time, instead of receiving all of your time at the beginning of the
year.

Team Members can use their accrued time as they earn it. After 12 months of employment, if you
need to use time but have none available, you may borrow up to 40 hours, giving a team member a
negative PTO balance. See Benefit Year for more info. Taking more than 40 hours of PTO at one
time must be approved by Senior Management. PTO must be used if available, taking unpaid time
off is not allowed unless approved by a manager. Excessive unpaid time off will not be allowed.

Exempt Team Members must use PTO in half day (4 hours) or full day (8 hours) increments, unless
on an approved FMLA leave. An exempt team member may borrow PTO within their first year for
pre-approved time off that was scheduled prior to them starting employment. Their PTO will be put
into a negative status until time is accrued to cover the time taken.

New Team Members – A newly hired team member begins accruing PTO immediately after hire
following the schedule above.

Benefit Year - The benefit year is January 1st through December 31st. PTO balances must not be
negative at the end of the plan year.

PTO - A non-exempt team member is compensated at the team member's current base rate of pay
for each day of PTO. An exempt team member receives the team member's regular salary for the
PTO period.

Driver PTO - Mileage Drivers are compensated at an average hourly rate of pay calculated using a
12-week period for each day of PTO.

Scheduling - PTO requests must be submitted in writing to a team member's supervisor as far in
advance of the date(s) as possible. Every effort is made to authorize PTO in accordance with team
member requests. In addition, the Company reserves the right to designate when some or all of a
team member's PTO is taken. The same procedure is followed for time off requests immediately
preceding or following a Company-observed holiday.

Staying Home When Ill - It is critical that team members do not report to work while they are ill
and/or experiencing symptoms associated with a currently prevalent virus or disease. Examples
may include fever, cough, sore throat, runny or stuffy nose, body aches, headache, chills and fatigue.
Team members who report to work ill may be sent home if they exhibit these or other symptoms that
could pose a health hazard to others.

Accumulation - Each calendar year a team member may carry over up to a maximum of 120 hours
of PTO.

G&C Foods 900-8 January 2024


Holiday During Scheduled PTO - If a Company-observed holiday falls on a team member's
normally scheduled workday and the team member is on PTO, the day is counted as a paid holiday
and not a PTO day. No allowance is made for sickness or other paid absence occurring during a
scheduled PTO.

Leave of Absence - PTO leave accrues while a team member is on a paid leave of absence
(including paid FMLA leave) but does not accrue while a team member is on an unpaid leave of
absence. For the purpose of this policy, paid leave is defined as leave during which a team member
is using credited PTO.

Separation from Employment - A team member who resigns, retires, or is laid off is eligible to
receive compensation for credited, unused PTO at the time of separation from the Company. To be
eligible for this payment, the team member must give and complete at least two workweeks written
notice and return all Company property in the team member’s possession. A team member who is
terminated or fails to give appropriate notice and does not complete their resignation period is not
eligible to receive compensation for credited, unused PTO.

Non-Retaliation - It is unlawful for an employer or any other person to deny, interfere with, or fail to
pay for PTO when used for reasons under the New York paid sick leave law. The Company prohibits
retaliation or discrimination with respect to terms and conditions of employment because a team
member inquires, requests, or uses PTO for such reasons.

912 Paid Sick Leave (non-full-time team members)

Eligibility – New York State team members who are not eligible for PTO under the Company’s PTO
policy, are eligible for limited paid sick leave under the New York paid sick leave law. Sick leave may
be used for the following reasons:

• the need for diagnosis, care, or treatment of a mental or physical illness or preventative care
of the team member or the team member’s family member; and
• certain needs related to the team member or the team member’s family member being the
victim of domestic violence, sexual offenses, stalking, or human trafficking, including obtaining
services from a domestic violence shelter, rape crisis center, or other services program;
participating in safety planning; temporarily or permanently relocating; meeting with an attorney
or participating in legal proceedings; enrolling children in a new school; or taking other actions
to increase the safety of the team member or team member’s family members.

Definition of Family Member - For purposes of this leave, a “family member” includes a team
member’s child (including foster child, legal ward, or equivalent legal relationship), spouse,
domestic partner, parent (including a step- or foster parent, legal guardian, or equivalent legal
relationship), sibling, grandchild, grandparent, and the child or parent of a team member’s spouse
or domestic partner.

Benefit Year - The benefit year is the period commencing and ending on a team member's annual
anniversary date.

Allowance and Carryover - All non-full-time team members will accrue paid sick leave at the rate
of .0334 per hour worked, up to 56 hours per benefit (anniversary) year beginning on their date of
hire. A team member who does not use all accrued sick leave in the benefit year may carry it over
to the next year, up to a maximum of 56 hours. The maximum amount of paid sick leave that may
be used in any benefit year is 56 hours.

G&C Foods 900-9 January 2024


Use and Payment of Sick Leave - Team members may not use paid sick leave until it is accrued.
Compensation for paid sick leave is at the team member’s regular (normal) rate of pay.

Notification Procedures - It is understood that sudden illness and certain situations covered by the
New York paid sick leave law may not allow for ample notice to a team member’s supervisor of the
need for absence. However, a team member is asked to provide as much notice as possible when
requesting use of paid sick leave, and will not be required to provide confidential details of the reason
for the absence.

Any team member abusing the use of sick leave or falsifying the reason or documentation of an
absence for any reason, may be subject to disciplinary action, up to and including termination of
employment.

No Pay in Lieu of Use - A team member is not eligible to receive payment in lieu of taking unused
sick leave, nor will unused sick leave be paid out upon separation of employment for any reason.

Non-Retaliation - It is unlawful for an employer or any other person to deny, interfere with, or fail to
pay for sick time and team member has the statutory right to use. The Company prohibits retaliation
or discrimination with respect to terms and conditions of employment because a team member
inquires, requests, or uses paid sick leave.

913 Holidays

Observed Holidays - The Company may close for business to observe the following holidays:

• New Year’s Day • Labor Day


• Memorial Day • Thanksgiving Day
• Independence Day • Christmas Day

Eligibility Full-time team members are eligible for paid holidays upon hire.

Holiday Pay Disqualification – A non-exempt team member may lose holiday pay if they call in the
scheduled day before or the scheduled day after an observed holiday unless verification of the team
members illness is provided from the team members health care provider.

Holiday Pay - A non-exempt team member is eligible for holiday pay at the team member's current
base rate of pay. If a team member is normally scheduled for 8 hours shifts, they will receive 8 hours
of holiday pay. An exempt team member receives the team member's regular salary for each
Company-observed holiday.

Leave of Absence - A team member who is on a paid leave of absence is eligible to receive
compensation for any Company-observed holidays that occur during the leave. For the purpose of
this policy, paid leave is defined as leave during which the team member is using credited, unused
PTO. A team member who is on an unpaid leave of absence is not eligible for any paid holidays that
occur during the leave.

Holiday During Scheduled PTO - If a Company-observed holiday falls on a team member's


normally scheduled workday and the team member is on PTO, the day is counted as a paid holiday
and not a PTO day.

Holiday Observance - If a scheduled holiday falls on a weekend day, the Company will make an
official announcement as to the date the holiday will be observed.

G&C Foods 900-10 January 2024


Assigned to Work on a Holiday – Team members who are required to work on a designated
Company holiday is eligible to receive holiday pay (8 or 10 hours based on regular schedule) plus
regular wages for all time worked.

Floating Holiday - In addition to the designated holidays listed above, full-time team members are
credited with floating holidays if the team member is scheduled to work on a company observed
holiday. A team member must receive authorization to take the floating holiday in accordance with
the Company’s attendance policy (See Policy 701 Attendance).

Holidays Not Designated by the Company - A team member may request time off for Sabbath
observance, to participate in a religious practice, or for a religious holiday that is not included in the
above list of Company-observed holidays. Requests should be submitted in accordance with the
Company’s attendance policy (See Policy 701 Attendance). A team member will not be denied time
off solely because it has been requested for religious reasons. Time off is generally granted so long
as it does not create an undue hardship on the Company. A non-exempt team member may be
allowed to make up the lost work time during the current workweek with prior supervisory approval,
if work is available and if a mutually convenient time can be agreed to by the team member and the
supervisor. A team member also has the option of using credited, unused PTO or taking the time off
without pay (exempt team members are only docked for full day absences).

914 Disability Coverage

New York State Disability


Policy Statement - New York State Disability benefits are available as a temporary benefit to eligible
team members who are unable to work for a period of more than seven days due to a non-work
related injury or illness.

Eligibility - A New York State team member who has worked for the Company for at least four
consecutive weeks or has recently worked for a “covered” employer is generally covered by G&C
Foods disability plan. Minors who are currently attending elementary or high school are normally not
covered.

A team member who is on an unpaid leave of absence for any reason other than the team member’s
own disability will remain eligible for New York State Disability insurance benefits for up to four weeks
after the unpaid leave commences or separation from employment, should a qualifying injury or
illness occur. After four weeks, a team member will no longer be eligible for New York State Disability
benefits.

In the event that a team member collects both New York State statutory disability benefits and
benefits under the New York State Paid Family Leave Benefits Law (“PFL”) at different times during
the same 52-week period, the maximum amount of time that can be taken for both statutory disability
and PFL combined is 26 weeks.

Coverage - Eligibility for benefits is determined by the Company’s disability insurance carrier. An
eligible team member is covered for the period of disability specified by the team member's health
care provider and approved by the insurance carrier, starting with the eighth day of the disability and
continuing up to a maximum of 26 weeks. A team member receives a portion of their wages based
on the previous eight weeks of employment, up to a specified maximum per week. There is no
coverage for medical care related to the disability.

Premium Payment - Team members contribute a small amount towards New York State Disability
insurance. The Company pays the remaining portion.

G&C Foods 900-11 January 2024


Leave of Absence - The Family and Medical Leave Act policy or the Company's Leave of Absence
policy may apply to a team member who is receiving New York State disability benefits. Please refer
to these policies for information regarding leave requests, benefit continuation, job restoration, etc.

Supplemental Short-Term Disability

Eligibility - Full-time team members are eligible to participate in a Company-sponsored short-term


disability plan that provides income at the time of a qualifying injury or illness. Part-time team
members are not eligible for this benefit.

Coverage - Eligibility for short-term disability benefits is determined by the insurance carrier. An
eligible team member generally receives 70% of the team member's average weekly wages
(generally based on your hourly rate x 40 hours), up to a maximum of $1,000 per week. Benefits
begin on the 7th day of disability and continue up to a maximum of 26 weeks. There is no coverage
for medical care.

Premium Payment – The Team Member contributes 100% towards the insurance premium.

Long-Term Disability

Eligibility - Full-time team members are eligible to participate in a Company-sponsored long-term


disability plan that provides income at the time of a qualifying injury or illness. Part-time team
members are not eligible for this benefit.

Coverage - Eligibility for long-term disability benefits is determined by the insurance carrier. An
eligible team member generally receives 60% of the team member's average weekly wages
(generally based on your hourly rate x 40 hours), up to a maximum of $5,000 per month. Long-term
disability benefits may be offset by any other benefits a team member receives. Benefits begin on
the 27th week of disability and continue up to social security eligibility or normal retirement age occurs.

Premium Payment - The team member is responsible for 100% of the insurance premium.

915 Workers' Compensation

Policy Statement - All team members are covered by Workers' Compensation Insurance, which
provides payment for lost wages and medical expenses in the event of a work-related injury or illness.

Coverage - The Workers' Compensation Board determines a team member's eligibility for benefits.
If deemed eligible, a team member is covered for the period of disability specified by the team
member's health care provider and the Workers' Compensation Board.

Benefits - Coverage is provided for all necessary medical care received that is directly related to the
original injury or illness and the recovery from such disability. A team member who is totally or
partially disabled and unable to work for more than seven days is eligible for cash benefits starting
with the eighth day of disability. If the disability extends beyond 14 days, cash benefits are paid
retroactively for the first seven days of the disability. Cash benefits are normally calculated based
on two-thirds of a team member’s average weekly wages during the previous year multiplied by the
percentage of disability, up to a specified maximum.

Voluntary, Off-Duty Conduct - G&C Foods is generally not liable for the payment of workers’
compensation benefits for injuries that occur during a team member’s voluntary participation in any
off-duty recreational, social, or athletic activity sponsored by the Company.

G&C Foods 900-12 January 2024


Leave of Absence - The Family and Medical Leave Act Policy generally applies to a team member
who is receiving workers' compensation benefits. Please refer to this policy for information regarding
leave requests, benefit continuation, job restoration, etc.

Premium Payment - The cost of workers' compensation insurance is paid entirely by the
Company.

916 Unemployment Insurance

Policy Statement - Unemployment insurance benefits provide short-term financial assistance to


individuals who have lost their jobs due to no fault of their own and are ready, willing, and able to
work.

Eligibility - Eligibility for unemployment insurance is determined by the appropriate State


Department of Labor.

Cost - The cost of unemployment insurance coverage is paid entirely by the Company.

917 Social Security and Medicare

Policy Statement - Social Security and Medicare benefits are available for retirement, survivor's
benefits, and medical costs under qualifying conditions as determined by the Federal Social Security
Administration Office.

Cost - The Company matches team member contributions to social security (FICA) and Medicare.

918 Safety Shoe Program

Policy Statement - The safety shoe program is intended to provide team members with safe and
proper footwear.

Required - It is mandatory that team members in the following departments wear safety shoes:
Warehouse, Production, Distribution (CMVO’s), and the Vehicle Repair Shop (Mechanics).

G&C will reimburse an eligible team member up to $100.00 per year towards the purchase price of
safety footwear. Team members must attach a copy of the detailed receipt from their purchase to
receive the reimbursement. If the purchase price of safety footwear is in excess of $100.00, the
team member is responsible for the difference in the purchase price and the Company-provided
reimbursement. (For all new hires, G&C will issue any reimbursement 90 days after hire).

919 Team Member Purchase Policy

Eligibility – All team members are eligible to purchase most products that G&C Foods sells at a
discounted rate after 30 days of employment.

Sales Transactions – Upon completion of the 30-day waiting period your company charge account
can be opened. The order must be placed with a sales representative or supervisor. Team Members
may pick up product on a designated day after noon.

Restrictions - A team member may only purchase items at a discount for the personal use of the
team member. Team member purchases may not be made for commercial use or resale. This
account will have a purchase limit. Purchase must be payroll deducted. No cash or checks are

G&C Foods 900-13 January 2024


accepted. Quantity limits may apply. No special orders on weights or dates are allowed. Exceptions
may be approved by the credit department in certain circumstances.

Policy Violations - Any team member who violates this policy will be subject to disciplinary action,
up to and including termination.

920 Team Member Assistance Program

Policy Statement - The Company makes available a team member Assistance Program (EAP) to
provide free counseling services to team members and eligible family members. The EAP offers
confidential counseling and referral services on a variety of personal issues, such as, but not limited
to, financial concerns, alcohol and drug dependence, and marital and family conflicts. In addition,
the EAP offers assistance for Work/Life problems, Self-Help Resources and more than 8000 e-
learning courses, trainings and videos.

Eligibility -Team members, their spouses (includes same sex spouses), and dependents are eligible
to participate in the EAP as of the team member's first day of employment.

Contact Information - If a team member is experiencing a work-related problem such as poor job
performance or excessive absenteeism, the team member may call 800-252-4555 or visit
www.theEAP.com 24/7.

EAP Referral - If a team member is experiencing a work-related problem such as poor job
performance or excessive absenteeism, the team member’s supervisor may refer the team member
to the EAP. G&C Foods will not retaliate or take negative action against a team member who refuses
EAP services, except where mandated by law.

921 Recognition Awards

Policy Statement - G&C Foods strongly believes that it is important to recognize team members for
their long-term service and dedication to the Company. Service awards are presented to team
members who have worked for the Company for 20 years.

922 Team Member Referral Program

Policy Statement - The Company encourages team members to refer qualified candidates who are
not now and have not ever been employed by the Company to be considered for open positions.

Eligibility- Full time and part-time team members are eligible for this benefit upon hire. Rehired team
members are not eligible for a referral bonus.

G&C Foods 900-14 January 2024


Payment for Team Member Referrals -

Award Amount Type of Position Payment Schedule


$350 Gross Full-time Team Member $50 after 30 days of employment

$100 after 180 days of employment

$200 after 1 year of employment

$2000 Gross Full-time CDL A Driver $600 after 30 days of employment

$600 after 180 days of employment

$800 after 1 year of employment

Team member referral bonuses are processed with the normal payroll. The referring team member
must still be employed with the Company when an award becomes payable. Payments are
processed in the first payroll following 30 days, 180 days and 1 year of completed employment of
the referred applicant. Both the referred applicant and the referring team member must still be
actively employed on the date the payment is credited.

Credit for Referred Applicants - A current team member is eligible for this payment when the
applicant noted the team member’s name on the Employment Application at the time of submission.

Evaluation of Referred Applicants - All referred applicants are subject to the same screening and
hiring process including pre-employment fitness for duty exams and drug screening. When no
openings currently exist, the candidate’s resume or Employment Application will be placed in an
active file in Human Resources for a period of one year. When the candidate is hired, the appropriate
award will be processed in the first available payroll following the new team member's date of hire.

G&C Foods 900-15 January 2024


923 Wellness Center

Policy Statement – G&C Foods strongly encourages the healthy lifestyle of their team members.
G&C maintains a wellness center at its main facility in Syracuse, NY that all active team members
can utilize. Use of the Wellness Center is voluntary, not a condition of employment and during the
participants own personal time. Team Members who choose to use the wellness center agree that
on behalf of themselves, their heirs, and their representatives, they release, discharge, hold
harmless, and agree to indemnify G&C, its parent company, affiliates, successors, and owners, and
their team members, agents, and assigns from any and all claims, liability, damages, expenses,
causes of action, suits, judgments and costs of defense (including reasonable attorneys’ fees and
costs) arising from any injury to themselves, theft of my property, or any other loss or damage
occurring in the Wellness Center or resulting, in any manner, from their use of the Wellness Center.

Team Members must abide by the following rules:

Wellness Center Rules:

• The center is open and available for use only during the hours posted.
• Only proper use of equipment is permitted.
• Team Members Only, no family or friends are permitted.
• No wet footwear is to be used on any equipment.
• No photography or videotaping allowed in the wellness center.
• No food.
• Beverages must be kept in a closed container.
• No swearing.
• No weight dropping.
• Proper and appropriate attire only.
• Be courteous and respectful of others.
• Share the equipment (limit 20-30 min use if someone is waiting).
• Wipe off equipment after use – paper towels and disinfectant provided.
• Always use a spotter when lifting weights.
• Return weights to area when done.
• Report all equipment breakdowns to the Facility Manager and tag the machine with the
problem.
• Please sign the log book each time to use the center.

Policy Violations - Use of the Wellness Center is a privilege and a benefit to G&C Team Members.
Anyone who violates any rules as noted above or posted in the wellness center, will be subject to
disciplinary action up to and including termination.

G&C Foods 900-16 January 2024


1000 PERSONAL CONDUCT

1001 Personal Appearance

Policy Statement – G&C Foods believes that professional personal appearance is critical to
projecting a positive and professional image within our organization and to our customers. We have
adopted the following guidelines for dress. We all must take responsibility to ensure that our personal
appearance is neat, clean, and professional at all times and that the image we project to each other
and to our customers is positive.

ADMINISTRATIVE PROFESSIONALS:
(Sales, Purchasing, Transportation, Accounting, HR, IT, Receiving Office Team members)

Monday through Thursday


Team members are expected to dress neatly in attire appropriate for an office setting. However,
based upon a team member’s position, schedule, and general exposure and interaction with the
public, expectations may be different. Clothing must be free of rips, tears, holes, inappropriate
language or graphics. Management is accountable to communicate their specific expectations to
their team members.

Appropriate Attire Inappropriate Attire


Khakis/Slacks/Jeans Athletic Attire, Sweatshirts, Sweatpants
Skirts/Dresses Shorts, hoodies
Golf, Polo Shirts, Blouses, Sweaters Halter Tops, Spaghetti Straps
Dress Sandals/Casual Footwear/Boots T-Shirts, Hats
Revealing Clothing/Exposed Mid-drifts
Beach Footwear/Sneakers/Flip-Flops

Fridays
Sneakers may be worn on Fridays.

Other Guidelines - In certain instances, when vendors, partners, or investors are on-site,
formal dress requirements may be required. We will strive to provide as much notice as possible.

Closed toe shoes are required on the dock at all times.

OPERATIONS PERSONNEL:
(Any team member who operates Safety Sensitive Equipment on a daily basis)

Warehouse:
Warehouse team members are not required to dress in office attire. However, cleanliness and
personal hygiene is required. Safety shoes and Hi-Visibility vests/clothing are required. Clothing
must be free of rips, tears, holes, inappropriate language or graphics. Use of a single earbud or
headphone is permitted as long as one ear is unobstructed.

Drivers:
Because our drivers work so closely with our customers, it is crucial that they take the utmost care
in regard to their attire and personal hygiene. Drivers are expected to wear black pants or shorts
and are provided with G&C uniform shirts which they are required to wear during their workday.
These uniforms must be kept neat and presentable. Safety shoes and Hi-Visibility vests/clothing are
required outside of the vehicle or when on a dock. Drivers are required to wear closed toed shoes
(no flip flops) while driving.

G&C Foods 1000-1 January 2024


PRODUCTION/REBOX:
(any team member who operates in a production room)

Production team members must abide by all guidelines of Good Manufacturing Practice (cGMPs).
This includes but is not limited to wearing safety shoes, production coats, hair and/or beard nets,
gloves, long pants and ear protection. In addition, no jewelry other than a plain band with no stones
will be allowed in the production area. No fingernail polish, artificial fingernails, artificial eyelashes or
extensions, etc. are allowed in the production areas. See Also 1212 Safe Quality Food (SQF)
Certification.

American Flag - In accordance with New York State labor regulation, the Company will allow a
team member to display an American flag on the team member’s person as long as it does not
substantially or materially interfere with the team member’s job duties.

Reasonable Accommodation - Reasonable accommodation will be made for team members


sincerely held religious beliefs and disabilities whenever possible, consistent with the business
necessity unless it creates a safety concern or imposes an undue hardship on the Company. A team
member should contact the Human Resource Department to request an accommodation.

Grooming Standards - All team members are expected to maintain clean and appropriate oral
and bodily hygiene. A team member’s hair (including facial hair) should be clean, combed, and
well-groomed. Excessive perfume, cologne, or body odor are not permitted. G&C reserves the
right to require team members to conform to its standards of personal presentation and
appearance. Team members shall be allowed to dress and groom themselves in a manner
consistent with their race and religion. This may include, but is not limited to, religious clothing,
coverings, and jewelry, as well as hair texture, protective hairstyles, facial and body hair.

Policy Violations - A team member who reports to work inappropriately dressed or groomed may
be sent home to change. A non-exempt team member is not compensated for any time lost from
work to comply with this policy.

1002 Misrepresentation

Policy Statement - G&C is committed to operating the Company honestly, with integrity, and in
compliance with government regulations. All team members are expected to share this commitment.

Prohibited Conduct - Team members must refrain from any illegal, fraudulent, or dishonest
business activity. Examples of conduct that is prohibited include, but are not limited to, violations of
government or Securities and Exchange Commission (SEC) regulations, preparing fraudulent
accounting records or financial reports, fraudulently claiming an injury and seeking coverage, and
billing customers for services not performed or goods not delivered or over/undercharging them. It
also includes misrepresenting a Company product or service to our customers or intentionally giving
false information.

Reporting Policy Violations - A team member is required to report any conduct that he or she
reasonably believes violates this policy by notifying the Human Resources Department immediately.

G&C Foods 1000-2 January 2024


1003 Substance Free Workplace

Substance Free Workplace – G&C Foods is committed to providing a safe and healthy workplace
free from drug and alcohol abuse. The unlawful or improper presence or use of controlled
substances or alcohol in the workplace presents a danger to everyone. Team members are required
to report to work in appropriate mental and physical condition to perform their jobs in a satisfactory
manner.

Prohibited Behavior - A team member is prohibited from possessing, using, selling, purchasing,
storing, distributing, or manufacturing alcoholic beverages, cannabis, illegal drugs, controlled
substances, or narcotics on Company premises, at work sites, or at any location while representing
the Company. A team member is also prohibited from having cannabis, illegal drugs, controlled
substances, or narcotics that may impair a team member’s ability to safely perform the duties of
his/her job present in the team member’s system when reporting to work, during working time, or at
any time while conducting business-related activities. Consumption of alcoholic beverages on
company property is strictly prohibited unless during an authorized, company sponsored event. Drug
paraphernalia, such as pipes and needles, is prohibited on Company premises, at work sites, and in
vehicles being used for Company business unless the team member is able to provide a prescription
showing medical necessity for health reasons.

The Company prohibits the off-premises abuse of alcohol, cannabis, and controlled substances, as
well as the possession, use, or sale of legal or illegal drugs, when these activities adversely affect
job performance, job safety, and/or the Company’s reputation in the community.

Use of Prescription and Over-the-Counter Drugs - Prescription drugs must be in the possession
of the individual to whom the prescription was written, taken in the dosage prescribed, and
maintained in their original containers. A team member is not allowed to use prescription drugs that
have not been legally obtained or in a manner or for a purpose other than as prescribed. A team
member must inform the team member’s supervisor of any prescription or legal, nonprescription (i.e.,
over the counter) drugs including medical marijuana that are currently being taken if they could in
any way affect or impair the team member's ability to perform the job safely. The legal use of
prescribed and over-the-counter drugs is only permitted on the job if it does not impair a team
member's ability to perform the job safely and it does not affect the safety or wellbeing of other
individuals in the workplace.

A team member should not drive on Company business if the team member’s ability to drive safely
has been impaired by illness, fatigue, injury, prescription medication, illegal drugs, cannabis, or
alcohol.

Reporting of Problems - Any observation or knowledge of a team member who is in a condition


that impairs the team member’s ability to perform job duties, presents a hazard to the safety and
welfare of others, or appears to otherwise be in violation of the Company's substance free workplace
policy should be reported to the Safety Manager immediately.

Screening for Drug or Alcohol Use - In addition to the substance testing policy addressed below
for commercial drivers, a team member may be tested for alcohol, cannabis or illegal drugs where
there is a reasonable suspicion that abuse, impairment, or a violation of this policy exists. Testing
will be conducted in accordance with applicable state or municipal regulations and will generally
follow Department of Transportation (DOT) regulations. A team member who is instructed to take a
drug test must comply with all procedures at the testing facility. Failure to take a test or follow
procedures will result in termination. Drug and alcohol tests are paid for by the Company and are
the property of the Company.

G&C Foods 1000-3 January 2024


A team member who tests positive to a confirmed test for alcohol or controlled substances will be
subject to disciplinary action, up to and including termination of employment. A team member who
violates this policy and is subject to termination may be permitted in lieu of termination, at G&C
Foods's sole discretion, to participate in and successfully complete an appropriate treatment,
counseling or rehabilitation program as recommended by a substance abuse professional, and be
subject to periodic, unannounced drug and/or alcohol testing for a set time period as a condition of
continued employment and in accordance with applicable federal, state, and local laws.

A team member who tests positive, admits to illegal drug use or related misconduct, or who
voluntarily seeks assistance, and is not discharged, will not be allowed to return to work or continue
working until the team member has been evaluated by a health care professional of G&C Foods's
choice to determine if the team member can safely return to work.

Consistent with its EEO policy, G&C Foods maintains a policy of non-discrimination and reasonable
accommodation with respect to recovering addicts and alcoholics, and those having a medical history
reflecting treatment for substance abuse conditions. G&C Foods encourage team members to seek
assistance before their substance or alcohol use renders them unable to perform their essential job
functions or jeopardizes the health and safety of themselves or others. G&C Foods will attempt to
assist its team members through referrals to rehabilitation, appropriate leaves of absence and other
measures consistent with the Company's policies and applicable federal, state or local laws.

A team member’s participation in a treatment program does not prevent G&C Foods from disciplining
the team member for violations of this or other Company policies.

The Company further reserves the right to take any and all appropriate and lawful actions necessary
to enforce this substance abuse policy including, but not limited to, the inspection of desks or other
suspected areas of concealment, as well as a team member's personal property when the Company
has reasonable suspicion to believe that the team member has violated this substance abuse policy.

DOT Drug and Alcohol Testing Policy - The Company has adopted a substance testing policy in
compliance with the Omnibus Transportation Team member Testing Act of 1991. The purpose of
this policy is to reduce accidents resulting from a team member’s use of controlled substances,
cannabis, and alcohol, thus reducing fatalities, injuries, and property damage. Pre-employment
drug testing is required for all new hires to The Company. All covered drivers who operate
commercial motor vehicles requiring a commercial driver's license (CDL) to operate, as well as any
team member performing in a safety sensitive position may be subject to random, post-accident, or
follow-up substance testing. In addition, all team members are subject to reasonable suspicion
substance testing. Any team member that is tested under this policy and receives a positive test
result will be terminated immediately. All covered team members receive a separate copy of this
policy. Team members who operate commercial motor vehicles requiring a commercial driver's
license (CDL) are subject to DOT testing laws and will be expected to adhere to DOT testing
guidelines.

Policy Violations - Violations of this policy may result in disciplinary action, up to and including
termination. The possession, use, sale, purchase, distribution, or manufacture of illegal drugs shall
also be brought to the attention of the appropriate law enforcement agency.

G&C Foods 1000-4 January 2024


1004 Outside Employment

Policy Statement - It is the policy of G&C Foods that a team member may engage in outside work
as long as such outside work does not interfere with the team member’s performance, pose an actual
or potential conflict of interest, or compromise the interests of the Company. Outside employment
that interferes with job performance, constitutes a conflict of interest, or compromises the interests
of the Company is prohibited.

Performance and Work Schedule Requirements - A team member is judged by the same
performance standards, regardless of any existing outside work requirements. A team member must
meet all scheduling requirements of the Company, including business travel and overtime hours, and
shall not receive authorization to report to work late or to leave work early in order to accommodate
a second job.

Use of Paid Leave Benefits - A team member is not allowed to use paid sick or personal leave or
to take time off without pay to work at another employer.

Restrictions - A team member may not work for another employer or be self-employed if such work
is in direct competition with G&C Foods. A team member is not permitted to perform any work for
the Company’s customers during nonworking time if these services are normally available from
and/or performed by G&C Foods. Further, a team member is prohibited from soliciting or performing
any work for another employer, for the team member's own personal business, or for any other
personal gain during working time. No Company-owned equipment, supplies, or confidential
information or techniques may be used for furtherance of a team member's personal business or for
another employer.

Notification of Outside Employment - A team member who is interested in obtaining outside


employment must discuss the matter with the team member's supervisor prior to accepting the job
to ensure that the above guidelines are maintained. Newly hired team members who are employed
by another employer, own their own business, or partake in other work activities must disclose this
information on their Application for Employment Form.

1005 Driving on Company Business

Policy Statement - Team members in certain positions may be required to drive Company, leased,
rental, or personal vehicles to conduct business on behalf of G&C Foods. Team members who drive
on Company business must operate vehicles in a safe and responsible manner, and in compliance
with all applicable motor vehicle and traffic regulations.

Driver’s License - A team member who drives on Company business must possess a valid driver’s
license free from major infractions at the time of hire and throughout employment. A team member
who operates a vehicle that requires a commercial driver's license (CDL) must possess and maintain
this license throughout employment.

The driving records of final applicants and team members who apply for positions that involve driving
as a part of job duties are checked following a conditional offer of employment. Thereafter, the
Company conducts motor vehicle record checks on a regular basis in accordance with state and
federal regulations.

Driving While Impaired - A team member is prohibited from driving on Company business if the
team member’s ability to drive safely has been impaired by illness, fatigue, injury, prescription
medication, illegal drugs, cannabis, or alcohol.

G&C Foods 1000-5 January 2024


Change in Status or Loss of Driver's License - A team member who drives on Company business
must immediately notify the team member's supervisor if a ticket is received while driving a Company
vehicle or if a conviction is received for any traffic violation (except parking) during working or
nonworking time. The team member’s supervisor must also be notified immediately if the team
member’s driver’s license is suspended, revoked, cancelled, or if the team member becomes
disqualified from operating or loses the right to operate a motor vehicle, including a commercial motor
vehicle, for any period. A team member is not allowed to drive on Company business with a
suspended or revoked license.

A team member’s Company driving privileges may be suspended for receiving an excessive number
of traffic citations, regardless of whether the citations were received while driving on Company
business. If a team member’s Company driving privileges are suspended and the team member’s
position requires regular use of a vehicle, the team member may be reassigned to another position,
if available, or terminated for inability to perform the duties of the job.
Traffic Violation - The team member is responsible for paying the cost of any traffic or parking
tickets, moving violations, or fines that result from driving on Company business.

Use of Personal Vehicle for Company Business - A team member who drives a personal vehicle
to conduct Company business must have auto liability insurance (for both bodily injury and property
damage) and proof of a minimum policy for liability coverage of $100,000 per person/$300,000 per
accident. Proof of such insurance is required upon hire and on an annual basis thereafter. If a team
member's liability insurance lapses, the team member's supervisor must be notified immediately.

Company Liability - The Company does not assume any liability for injury to members of the public
caused by the negligence of a team member who is driving a personally owned vehicle in the course
of Company business. In addition, the Company is not responsible for any damage to a team
member’s personal vehicle or loss or damage to personal property contained within the vehicle.

Cell Phones - In accordance with New York State regulation, a team member is not allowed to make
or receive calls on a cell phone and/or wireless device while driving unless a headset or hands-free
device is used. In addition, a team member is prohibited from reading, writing, or sending text
messages and emails, surfing the internet, or playing games while driving. If a team member needs
to engage in any of these activities while driving, they must pull over to a safe location and stop the
vehicle prior to using any device.

This policy covers team members who work outside of New York State, even though there may be
no such regulation against using a cell phone while driving in those states.

Distracted Driving- Distracted driving is any activity that could divert a person's attention away from
the primary task of driving. All distractions endanger driver, passenger, and bystander safety. A team
member is prohibited engaging in any activity that while driving that would distract them from their
primary responsibility of operating a vehicle. This may include but is not limited to operating an
electronic device, handling an object while driving, taking both hands off the wheel at the same time,
taking your eyes off the road, getting up out of the driver’s seat, turning around in your seat, reaching
for an object, etc.

Accident - A team member must notify the Safety Manager immediately in the event of an accident,
theft, or damage involving a vehicle being used for Company business, regardless of the extent of
the damage or lack of injuries. A law enforcement officer should be summoned to the scene of any
accident involving a team member or vehicle being used for Company business and an ambulance
should be summoned if anyone appears injured. A copy of the Accident Report should be obtained
from the police for submittal to the Safety Manager.

Use of Company Vehicles - Company-provided vehicles may be assigned to team members for
the purpose of conducting Company business. Only authorized team members are allowed to drive
G&C Foods 1000-6 January 2024
Company vehicles. Company vehicles should only be used for authorized Company business only.
Company vehicles should not be used to transport unauthorized individuals or materials or to conduct
personal or non-Company related business. Team members are prohibited from smoking in
Company vehicles at all times.

Company Vehicle Maintenance - Team members are responsible for maintaining Company
vehicles in a neat and clean condition at all times. Papers and garbage are to be removed from the
vehicle at the end of each trip. Vehicles should be maintained in a safe and secure condition when
not in use. It is the team member’s responsibility to notify the Safety Manager when a Company
vehicle is in need of maintenance or repair work.

Policy Violations – Violations of this policy will result in disciplinary action up to, and including,
termination.

1006 Personal Conduct

Policy Statement - For the benefit and safety of team members, customers, and the Company, a
team member must comply with G&C Foods standards of behavior and performance. Conduct that
interferes with business operations or is offensive to coworkers, customers, or the public is not
tolerated.

Team Member Responsibilities - Team members are expected to conduct themselves


appropriately and to treat coworkers, customers, vendors, and visitors with courtesy and respect.
Appropriate team member conduct includes, but is not limited to:

• Performing all assigned job duties efficiently, to the best of the team member’s abilities, and in
accordance with established performance standards;

• Being fair, considerate, and honest with supervisors, coworkers, customers, vendors, and
members of the public in connection with the performance of their duties for G&C Foods;

• Reporting any suspicious, unethical, potentially violent, or illegal conduct by coworkers or any
other persons with whom the team member conducts business on behalf of the Company; and

• Cooperating with any G&C Foods investigation.

Prohibited Conduct - A team member may be subject to disciplinary action, up to and including
termination for a violation of a policy, procedure, or rule outlined in this team member handbook or
otherwise established by the team member's supervisor. In addition, a team member may be subject
to disciplinary action up to and including termination for engaging in any of the following:

• Offensive or unprofessional conduct in connection with the performance of their duties for G&C
Foods;
• Improper performance of job duties or repeated failure to perform assigned duties and
responsibilities;
• Unauthorized expenditure of Company funds;
• Being insubordinate, threatening, intimidating, disrespectful or assaulting a supervisor, co-
worker, customer or vendor;
• The use of rude, insulting, aggressive, hostile or abusive language, including racial slurs and
epithets;
• Sabotaging the work of a coworker;

G&C Foods 1000-7 January 2024


• Dishonesty, falsification or misrepresentation on an employment application or other work
records or Company documents, including requests for time off, timekeeping records or other
information requested by or provided to the Company;
• Reporting for work, operating a vehicle, or working under the influence of alcohol, illegal drugs,
controlled substances, cannabis, or non-prescribed prescription drugs while on Company
business;
• Possession, use, sale, distribution, transfer, manufacture, or transportation of illegal drugs,
controlled substances, non-prescribed prescription drugs, cannabis, or alcoholic beverages on
Company premises or while on duty;
• Possession of dangerous or unauthorized materials, such as explosives or firearms in the
workplace;
• Leaving the premises or work location during scheduled work hours without permission;
• Illegal gambling while on duty;
• Sleeping on the job;
• Dishonesty and theft of any kind; and
• Failure to report to work or call the attendance hotline for 2 consecutive workdays.

The above list is illustrative only and is not intended to limit the Company's right to impose discipline
in other situations of inappropriate behavior.

1007 Corrective Discipline

Policy Statement – To ensure smooth and efficient operations, G&C Foods must have certain
policies, procedures, and rules. Any conduct that interferes with operations or that discredits the
Company will not be tolerated. The Company’s disciplinary policy and procedures are intended to
promote team member understanding of acceptable conduct and performance and to encourage
corrective action to meet those standards. The Company strives to impose corrective discipline
fairly, consistently, and in relation to the seriousness of the offense.

Forms of Discipline - Disciplinary action may include a coaching, written warning, and suspension
with or without pay, termination of employment, or other disciplinary measures, depending on the
circumstances. The Company does not guarantee that one type of discipline shall precede another.
Further, the Company reserves the right to suspend a team member with or without pay while an
investigation is conducted.

Payment During Disciplinary Suspensions - In accordance with state and federal employment
regulations, an exempt team member may be suspended without pay in partial or full day increments
for safety rule infractions of major significance or in one or more full day increments for violations of
workplace conduct rules (e.g., violations of the Company’s policies relating to sexual harassment,
discrimination, violence, and substance testing). Unpaid suspensions for exempt team members for
any other reason are generally in full week increments only. Paid suspensions for exempt and non-
exempt team members may be in partial day or partial week increments.

G&C Foods 1000-8 January 2024


1008 Fraternization

Policy Statement - In order to avoid an actual or perceived conflict of interest, the Company
prohibits dating and other similar romantic relationships between a supervisor and a team member
if the team member directly or indirectly reports to that supervisor. G&C believes that such
relationships erode the supervisor’s ability to be fair and impartial when supervising the team
member, or that the supervisor will not be perceived by others to be performing duties in a fair and
impartial manner. Further, complications can develop if or when the relationship ends.

Notification - In the event such a relationship commences, the supervisor must bring it to the
attention of the Human Resources Department immediately so that steps can be considered,
where possible, to adjust the reporting structure of the individuals involved. Failure to report the
relationship may result in termination of employment. This policy is considered when assigning,
transferring, or promoting a team member.

A problem arising as a result of team member fraternization may result in one or both of the team
members being reassigned, transferred to another department, or terminated, at the Company's
discretion.

1009 Ethics

Policy Statement - G&C Foods expects all team members to maintain the highest standards of
professionalism and integrity in the performance of their job duties and while representing the
Company. All work must be performed in an ethical manner and in accordance with government
regulations and Company policy.

Prohibited Conduct - A team member should never use the team member’s position with the
Company or relationship with internal coworkers or external constituents for private gain. A team
member is expected to refrain from any illegal, unethical, and/or dishonest business activity.
Examples of prohibited conduct include, but are not limited to:

• Directly or indirectly soliciting or accepting a bribe, kickback, loan, gift, service, or entertainment
from a current or prospective vendor, supplier, customer, or competitor for the team member's
personal gain in return for being influenced in connection with G&C Foods business;

• Directly or indirectly giving a bribe, kickback, loan, gift, service, or entertainment to a current or
prospective vendor, supplier, customer, or competitor in return for influencing that individual or
organization in connection with G&C Foods business;

• Having a direct or indirect financial interest or a personal business relationship with any business
or person that does business with G&C Foods without disclosure to and approval of the
Company; and

• Investing in the stocks, bonds, or securities of a vendor, supplier, customer, or competitor if such
transactions are based on any “inside information."

Team Member Guidance - Because the Company is unable to list every example of conduct that
may violate this policy, a team member should use good judgment and seek guidance and
assistance from the team member's supervisor, if needed.

International Compliance-If you have any concerns and/or need to report any unethical behaviors
regarding Export Compliance, please email compliancecommittee@gcfoods.com.

G&C Foods 1000-9 January 2024


Gifts - A team member is allowed to accept a nominal gift, money, service, travel, entertainment, or
other consideration of up to $100 in value from a current or prospective vendor, supplier, or customer.
Anything beyond that amount needs to be reviewed and approved by the president of the company.

1010 Conviction Notification

Policy Statement - A team member must, as a condition of continued employment, inform G&C
Foods of all criminal convictions. A team member is responsible for notifying the Human Resource
Department within three days of receiving a misdemeanor or felony conviction. Noncompliance with
this requirement may result in termination of employment.

Notification Prior to Employment - An applicant must indicate any convictions on the Company's
Application for Employment Form and/or indicate such convictions, if asked, during any employment
interviews.

Employment Decisions Based on Conviction - A criminal conviction does not necessarily


disqualify an applicant from employment consideration or result in termination of a current team
member. Employment decisions based on such information take into consideration many factors,
including but not limited to, the extent to which the offense relates to the functions of the particular
job, the seriousness of the offense, rehabilitation, and length of time since the conviction.

G&C Foods 1000-10 January 2024


1100 COMPANY PREMISES AND WORK AREAS

1101 Company Property

Policy Statement - The purpose of G&C Foods property is for the smooth and efficient operations
of the Company.

Team Member Responsibility - A team member is responsible for any items issued by the
Company that are in the team member’s possession and/or control. All equipment must be used
appropriately, handled carefully, and maintained in good condition. In addition, all operating and
maintenance instructions must be followed. Supplies should be used efficiently and not wasted in
order to save money and resources.

Prohibited Uses of Company Property - A team member should not deliberately destroy, deface,
or misuse Company property. The theft or unauthorized removal or possession of Company
property is prohibited.

Damage to Company Property - A team member must stop using and report any damaged,
defective, or malfunctioning Company property to the team member’s supervisor immediately.

Personal Use of Company Property - A team member may not use or borrow any Company
property for personal use without the prior approval of the team member’s supervisor. If authorization
is granted, a team member may use such property for the team member's own benefit only and not
for furtherance of any personal business or monetary gain. Proper use and care must be taken when
using Company property to ensure it is returned in good working order.

Definition of Company Property - For the purpose of this policy, G&C Food's property includes but
is not limited to, equipment, tools, supplies, keys, uniforms, vehicles, and this team member
handbook. This list is not all-inclusive.

Policy Violations – Violations of this policy will result in disciplinary action up to, and including,
termination.

1102 Personal Belongings

Policy Statement - The Company discourages a team member from bringing valuable,
unnecessary, or inappropriate personal property to work, including work sites. Personal property
that is brought onto Company premises must be appropriate for a business environment, should not
be offensive to others, disrupt work, or pose a safety risk to other team members, customers, or
visitors.

Personal Liability - G&C Foods is not liable for the personal belongings of team members and will
not repair, replace, or reimburse a team member for any damage to, or loss of, a team member's
personal property. It is the team member’s responsibility to safeguard their personal possessions.
This includes personal items in Company, leased, rental, or personal vehicles.

Lockers - Lockers are available for team members to place personal belongings. Lockers are
subject to inspection at the Company’s sole discretion. In accordance with SQF Certification
requirements, no food or beverage is allowed in the locker room at any time. See section 306
Separation of Employment for language about locker contents upon termination of employment.

G&C Foods 1100-1 January 2024


Music - Radios, CD players, and similar items are not allowed to be used by team members in safety
sensitive positions. In work areas where they are allowed, the volume must be kept low and the
choice of music not offensive to coworkers or customers.

1103 Work Areas

Policy Statement - G&C Foods is dedicated to providing a safe, clean, and pleasant work
environment for team members, customers, and visitors.

Work Areas - Work areas are to be maintained in a clean and orderly fashion. Equipment and
supplies must be returned to their proper location after use. Coats, boots, and other personal items
should be stored in designated locations.

American Flag – In accordance with New York State labor regulation, the Company allows a
team member to display an American flag in the team member’s work area as long as it does not
substantially or materially interfere with the team member’s job duties.

Food and Beverages - Food and beverages can be consumed in the office areas, but not in the
warehouse or production areas. Warehouse team members are allowed to carry water bottles in a
clear, closed container. However, team members are asked to wipe up any spills or crumbs
immediately and to properly dispose of containers after their use. Team members should also be
careful with beverages when working with, or around, equipment and business materials.

Housekeeping - It is the responsibility of team members to keep the break rooms, conference
rooms, meeting rooms, restrooms as well as the entire premises clean at all times. Please put items
in their proper location after each use, dispose of garbage in the appropriate trash cans, and wash
and put away dishes. Office paper, cardboard, newspapers, and other items that can be recycled
should be placed in the designated containers.

1104 Parking

Designated Parking - Team members should not park in designated handicapped, customer,
reserved, or visitor parking areas. When at work sites, team members must follow the parking
guidelines established by the customer.

Damage to Vehicles - G&C Foods is not responsible for the security of or damage to, team
members' vehicles or their contents while parked on the premises or while on Company business.
The Facilities Manager must be notified immediately of any accident, theft, or damage to a vehicle
that occurs while on Company premises, regardless of the severity, so that the proper authorities
may be notified.

1105 Smoking

Policy Statement - G&C Foods is dedicated to providing a safe and healthy work environment for
team members. In compliance with New York State Clean Indoor Air Act, the Company maintains a
Restricted Smoking Policy.

Smoking Restrictions - The smoking and chewing of tobacco and tobacco-like products, including
electronic devices is prohibited inside all buildings throughout the entire campus, including the office,
warehouse, VMF, meeting rooms, private and non-private offices, hallways, restrooms, locker
rooms, and in Company vehicles. In addition, smoking is prohibited near entryways, common areas
such as the patio or near any flammable objects such as propane tanks. Cigarette butts are to be
disposed of properly into approved disposal units.

G&C Foods 1100-2 January 2024


Smoking Breaks - Team members are allowed to smoke in their personal vehicle or in a
designated smoking area if provided during authorized meal and break periods. A team member is
not allowed additional or special breaks for smoking purposes.

Policy Violations – Violations of this policy will result in disciplinary action up to, and including,
termination.

1106 Charitable Solicitation and Distribution

Policy Statement - The Company is supportive of charitable causes in the community and
recognizes the right of all team members to engage in solicitation and distribution activities during
appropriate times. However, such activities must not interfere with the operation of our business.
Accordingly, G&C Foods has established rules, applicable to all team members, to govern solicitation
and distribution of written material during working time and entry onto the premises and work areas.
All team members are expected to comply with these rules.

1. No team member shall solicit or promote support for any cause or organization during his or her
working time or during the working time of the team member(s) at whom the activity is directed;
and

2. No team member shall distribute or circulate any written or printed material in work areas at any
time, during his or her working time, or during the working time of the team member or team
members at whom the activity is directed.

Working Time - As used in this policy, “working time” includes all time for which a team member is
paid and/or is scheduled to be performing services for the Company; it does not include break
periods, meal periods, or periods in which a team member is not, and is not scheduled to be,
performing services or work for the Company.

Non-Team members - Under no circumstances will non-team members be permitted to solicit G&C
Foods team members or to distribute written material for any purpose on Company property.

Team member Collections – Occasional collections for coworker gifts, activities, or parties that are
not sponsored by the Company are normally allowed with prior approval from a team member’s
supervisor.

Voluntary Participation - All charitable solicitations are completely voluntary; team members are
not required to participate in any charitable solicitation or function asked of them by the Company or
a coworker. Team members should be respectful of coworkers who choose not to participate in a
charitable solicitation.

G&C Foods 1100-3 January 2024


1200 SAFETY AND SECURITY
1201 Safety Program

Policy Statement - G&C Foods is committed to providing a safe and healthy workplace. All
machinery, equipment and devices are placed, operated, guarded, and lighted to provide reasonable
and adequate protection to all persons. The objective of the Company's safety program is to reduce
the number of workplace injuries and illnesses to zero. Accidents can often be prevented through
the use of reasonable precautions and the practice of safe working habits.

Safety Manager – The Human Resource Department can provide the name of the designated
Company Safety Manager.

Safety Program – The Company has developed a written safety program to address the health and
safety of all team members. The Safety Manager maintains the Safety Program. Any team member
may request to see the written program and is encouraged to ask any questions they may have.

Communication and Information - The Company provides workplace safety and health information
to team members on a regular basis via staff meetings, training sessions, bulletin board postings,
memos, company intranet and other written communications.

Team Member Suggestions - Some of the best safety improvement ideas come from team
members. Team members with ideas, concerns, or suggestions for improved safety in the workplace
are encouraged to contact their supervisor or the Safety Manager.

Personal Protective Equipment- Personal protective equipment, commonly referred to as "PPE",


is equipment worn to minimize exposure to hazards that cause serious workplace injuries and
illnesses. Personal protective equipment may include items such as Hi-Visibility Vests, gloves, safety
glasses and shoes, earplugs or muffs, hard hats, bump caps, respirators, or coveralls, vests and full
body suits. The company will provide any PPE that is required for your position. Failure to use/wear
PPE that is required for your position is a violation of this policy. See Also 918 Safety Shoe Program.

Safety Hazards - Any suspected safety hazard should be brought to the attention of a supervisor or
the Safety Manager immediately. Examples of potential safety hazards include, but are not limited
to, damaged or broken machinery or equipment, slippery floors, torn carpet, cords in aisles, and
boxes located in walkways or blocking exit doors. Reports about workplace safety issues may be
made anonymously if a team member chooses. A team member will not be retaliated against for
reporting accidents, injuries, or illnesses, filing a safety-related complaint, or requesting to see injury
and illness logs.

Investigations - The Safety Manager conducts an investigation of all job-related injuries, illnesses,
and near misses to determine the cause and attempt to prevent a recurrence.

Policy Violations - Any team member who violates a safety policy or engages in unsafe work
practices will be subject to disciplinary action, up to and including termination of employment.

1202 Accidents/Injury

Accident/Injury Procedures - In the event of a workplace accident or injury, take the following steps:
1. Stop work;
2. Eliminate or isolate the immediate cause of the accident to prevent further injury;
3. Obtain aid for the injured person and summon assistance. If the injury appears serious, dial 9-
1-1;
G&C Foods 1200-1 January 2024
4. Call a supervisor immediately;
5. Take steps to prevent additional accidents; and
6. Complete an Accident Report with full details of the accident and submit it to the Safety Manager
before the end of the current shift/workday. When an accident occurs, which involves a non-
team member, notify the Safety Manager immediately, no matter how minor the accident or injury
may appear and even if no one was hurt.

First Aid Kits - First aid kits are located in designated locations throughout the building.

Policy Violations – Violations of this policy will result in disciplinary action up to, and including,
termination.

1203 Building Evacuation

Evacuation Procedures - A team member should be familiar with all exits in the building. In the
event of a fire or other emergency that requires the building to be evacuated, the following
procedures must be followed:

1. Leave the building by walking rapidly but calmly to the nearest exit door (do not run or push),
assisting others along the way;
2. Immediately notify a supervisor or other designated person if anyone is having trouble leaving
the building;
3. Do not take time to gather any Company property or personal belongings;
4. Assemble in designated areas immediately after exiting the building; and
5. Do not re-enter the building until a supervisor or other designated person gives authorization to
do so.

Supervisors are responsible for the orderly exit of all team members within their department. Each
supervisor should be the last one out of the department and should make sure that all doors are
closed. Once outside of the building, the supervisor should account for all department team
members.

Fire Extinguishers - Fire extinguishers are located throughout the building. Team members should
be familiar with the location and operation of fire extinguishers. A fire extinguisher should only be
used by an individual who has received training in its use and only if the fire is containable (e.g.,
wastepaper basket, garbage bin). A coworker should be instructed to dial 9-1-1 simultaneously.
Leave the building immediately if the fire does not go out; never attempt to use a second extinguisher
or take other measures to try and contain the fire.

1204 Infectious Disease Control

Policy Statement – G&C will take proactive steps to protect the workplace in the event of an
infectious disease outbreak or declared pandemic. It is the goal of G&C during any such time
period to strive to operate effectively and ensure that all essential services are continuously
provided and that team members are safe within the workplace. See also Addendum on Airborne
Infectious Disease Exposure Prevention Plan.

G&C is committed to providing authoritative information about the nature and spread of infectious
diseases, including symptoms and signs to watch for, as well as required steps to be taken in the
event of an illness or outbreak.

G&C Foods 1200-2 January 2024


Preventing the Spread of Infection in the Workplace – G&C will take all reasonable steps to
provide a clean workplace, including the regular cleaning of objects and areas that are frequently
used, such as bathrooms, breakrooms, conference rooms, copiers, door handles and railings, as
well as shared tools and equipment. A committee will be designated to monitor and coordinate
events around an infectious disease outbreak, as well as to create work rules that could be
implemented to promote safety through infection control.

While we will implement various protocols to ensure your safety, it’s up to you and your co-workers
to execute these protocols daily. We ask all team members to cooperate by taking steps to reduce
the transmission of infectious disease in the workplace. The best strategy remains the most
obvious -- wash hands frequently with warm, soapy water; avoid touching your face; cover your
mouth whenever you sneeze or cough; and discard used tissues in wastebaskets. It’s important
to note that these guidelines are subject to change based on state and local guidance, and the
pandemic itself.

Unless otherwise notified, our normal attendance and leave policies will remain in place and/or
will be modified as required by any federal, state or local ordinance, order or regulation that is
enacted specifically for the infectious disease outbreak. If such policies do not address a team
member’s particular challenges, the team member should take steps to develop necessary
contingency plans. For example, team members might want to arrange for alternative sources of
childcare should schools close and/or speak with supervisors about the potential to work from
home temporarily or on an alternative work schedule.

Personal Protective Equipment: G&C normally maintains adequate supplies of recommended


personal-protective equipment, such as face masks and anti-bacterial hand sanitizers, throughout
the workplace and in common areas.

Limiting Travel - All nonessential travel should be avoided until further notice. Team members
who travel as an essential part of their job should consult with management on appropriate
actions. Business-related travel outside the United States or to identified trouble spots, may need
to be restricted or suspended until further notice. Team members should avoid crowded public
transportation when possible. Contact human resources for more information.

Telecommuting - Telework requests will be handled on a case-by-case basis. While not all
positions will be eligible, all requests for temporary telecommuting should be submitted to the
team member's manager or human resources for consideration.

Staying Home When Ill - During an infectious disease outbreak, it is critical that team members
do not report to work while they are ill and/or experiencing symptoms associated with a currently
prevalent virus or disease. [Examples may include fever, cough, sore throat, runny or stuffy nose,
body aches, headache, chills and fatigue]. The Company will follow the Centers for Disease
Control and Prevention (CDC) guidelines and will communicate these guidelines to all team
members. Team members who report to work ill will be sent home in accordance with these
health guidelines. Team member health screening may also be conducted in accordance with
applicable federal and state regulations.

Requests for Medical Information and/or Documentation - If you are out sick or show
symptoms of being ill, it may become necessary to request information from you and/or your
health care provider. In general, we would request medical information to confirm your need to
be absent; to show whether and how an absence relates to the infection; and to know that it is
appropriate for you to return to work. As always, we expect and appreciate your cooperation if
and when medical information is sought.

Confidentiality of Medical Information - Our policy is to treat any medical information as a


confidential medical record. In furtherance of this policy, any disclosure of medical information is

G&C Foods 1200-3 January 2024


limited to individuals on a need-to-know basis only. Disclosure will be made by Human Resource
staff only with managers, first aid and safety personnel, and government officials as required by
law.

Social Distancing Guidelines for Workplace Infectious Disease Outbreaks - In the event of
an infectious disease outbreak, G&C may implement these social distancing guidelines to
minimize the spread of the disease among the staff. During the workday, team members are
requested to:

1. Avoid meeting people face-to-face. Team members are encouraged to use the telephone,
online conferencing, e-mail or instant messaging to conduct business as much as possible, even
when participants are in the same building.
2. If a face-to-face meeting is unavoidable, minimize the meeting time, choose a large
meeting room and sit at least six feet from each other if possible; avoid person-to-person contact
such as shaking hands.
3. Avoid any unnecessary travel and cancel or postpone nonessential meetings, gatherings,
workshops and training sessions.
4. Do not congregate with multiple persons in offices, conference rooms, kitchens, copier
rooms or other areas where people socialize.
5. Bring lunch and eat at your workstation or away from others (avoid lunchrooms and
crowded restaurants). Properly clean the area when finished.
6. If orders and/or materials must be exchanged, have them ready for fast pick-up or delivery.

Duty to Comply with Guidelines - It is expected that all team members will assist G&C in
upholding and enforcing guidelines established by local and federal government agencies for the
health, and well-being of our team members, our customers, and our communities. Ignoring
and/or acting contrary to these guidelines and expectations could result in disciplinary action up
to and including termination.

Non-Retaliation - The HERO Act makes it unlawful for employers to discriminate, threaten,
retaliate against, or take adverse action against any team member for:

• Exercising their rights under this section or under the applicable airborne infectious disease
exposure prevention plan;
• Reporting violations of the Labor Law, or a plan adopted under this section to any state, local,
or federal government entity, public officer or elected official if they reasonably believe, in
good faith, that a violation has occurred;
• Reporting an airborne infectious disease exposure concern, or seeking assistance or
intervention with respect to airborne infectious disease exposure concerns, to their
employer, state, local, or federal government entity, public officer or elected official; or
• Refusing to work where such team member reasonably believes, in good faith, that such
work exposes him or her, or other workers or the public, to an unreasonable risk of
exposure to an airborne infectious disease due to the existence of working conditions that
are inconsistent with laws, rules, policies, orders of any governmental entity, including but
not limited to, the minimum standards provided by the model airborne infectious disease
exposure prevention standard, provided that the team member, another team member, or
team member representative notified the employer, of the inconsistent working conditions
and the employer failed to cure the conditions or the employer had or should have had
reason to know about the inconsistent working conditions.

Team members who believe they have experienced discrimination and/or retaliation should
immediately contact the Human Resources Department.
G&C Foods 1200-4 January 2024
1205 OSHA

Policy Statement – G&C Foods complies with the safety and health standards that have been
issued by the Occupational Safety and Health Act (OSHA). In order to prevent occupational injuries
and illnesses, the Company makes every effort to provide a workplace which is free from recognized
hazards that could cause physical harm to team members. In order to help the Company maintain
a safe workplace, team members are expected to abide by OSHA’s rules and regulations. The
OSHA standards that pertain to our industry are addressed in the Company's safety program.

Hazard Communication - G&C Foods has implemented a written hazard communication program
to address the safe use of chemicals in the workplace.

OSHA Inspection – The Safety Manager is to be notified immediately if an OSHA inspector arrives
at the office, warehouse or work site.
1206 Building/Campus Security

Safety Precautions - In order to ensure team member safety, prevent theft, and reduce accidents,
a team member who enters or remains in the office, building, warehouse before or after normal
business hours must exercise reasonable care for the team member’s protection must receive prior
authorization from the team member's supervisor.

The office, building, warehouse is equipped with a security system. All team members who are
authorized to be on campus are assigned an ID badge.

Video Recording - Video surveillance equipment is used for safety and security purposes. In
accordance with New York State labor regulation, the Company prohibits video recording in the
bathrooms, locker rooms, or designated changing rooms.

1207 Identification Badge

Policy Statement - Each team member is issued an identification badge that must be worn during
all working hours. A team member is not allowed to work without an identification badge. A non-
exempt team member shall not be paid for the time spent traveling to/from home to obtain the team
member's identification badge. Should your identification badge be misplaced or lost you will be
asked to pay for its replacement. If a pattern develops with continual badge replacement, disciplinary
actions may be taken up to and including termination.

1208 Visitors

Upon Entering the Campus (Normal Business Hours) - Visitors should enter the campus and
stop at the Welcome Center. The Welcome Center attendant will verify that the visitor is in the visitor
log and then direct the visitor to their campus destination. All visitors must be entered into the visitor
log on the intranet prior to their arrival. Visitors should be escorted by their host at all times.

Non-Business Hours - For safety and security reasons, visitors are prohibited from being on
Company premises before or after normal business hours.

Definition of Visitor - For the purpose of this policy, a visitor is defined as a customer, vendor,
supplier, friend or family member of a team member, or any other non-team member.

Personal Visitors – A team member may have personal visitors on Company premises for
occasional, brief visits during normal business hours. Personal visitors are not allowed at work sites.

G&C Foods 1200-5 January 2024


1209 Restricted Areas

Restricted Areas - Due to safety and security reasons, a team member is prohibited from entering
the Compressor room or server room unless assigned to work in this area.

1210 Workplace Violence

Policy Statement - G&C Foods considers the safety of its team members, or any individual on
Company property to be of paramount importance. The Company has zero tolerance for any type
of workplace violence committed by, or against, a team member, including threatening, intimidating,
or inferring violence against any person or property associated with the Company.

Notification of Threatening Behavior - A team member who is a victim of, witness to, or becomes
aware of any potentially dangerous situation, aggressive or hostile behavior, or threats or acts of
violence, must inform their supervisor or another member of management immediately. Any
suspicious individuals or activity must also be reported immediately.

Investigations - G&C Foods treats any threat of violence seriously, and will take immediate
appropriate action, including an investigation of the matter and the involvement of the police
department.

Prohibited Conduct - The following conduct is prohibited at all times while on Company property,
at work sites, or at any location while representing the Company:

• Fighting, provoking a fight, or threatening violence;


• Hostile or aggressive language, behavior or physical contact, including threats, touching,
groping, grabbing, patting, pinching, hitting, pushing, or brushing up against or poking a person's
body or impeding and/or blocking movements;
• Horseplay;
• Hostile behavior that creates a reasonable fear of harm to others or property; and
• Intentionally damaging Company or coworker property.

Firearms and Weapons – A team member is prohibited from possessing firearms or weapons of
any kind while on Company premises; in Company, leased, rental or personal vehicles while
conducting business for G&C Foods; or at work sites, customer locations, or any other location during
working time or while representing the Company, regardless of whether the team member is licensed
to carry the weapon. The only exceptions are law enforcement personnel and security guards.

Policy Violations - Violations of this policy will result in disciplinary action, up to and including
termination and/or legal action.

1211 Security Inspections

Policy Statement - To maintain security and protect against theft, G&C Foods reserves the right to
inspect all Company and personal property brought onto Company premises or work sites at any
time with or without notice, if there is suspicion by management of theft, illegal activity, or similar
behavior that may violate Company policy or government regulation. This includes, but is not limited
to, Company and personal vehicles, packages, briefcases, purses, desks, work areas, computers,
USB drives, files, e-mails, phones, voice mails, lockers, and file cabinets, even if locked. The
inspection will normally be conducted in the presence of the team member. Team members have
no right to privacy with respect to Company property or personal property brought onto Company
premises.
G&C Foods 1200-6 January 2024
Policy Violations - A team member who refuses to allow management to inspect the team
member's Company or personal property may be subject to disciplinary action, up to and including
termination. In addition, a team member who steals from the Company will be subject to disciplinary
action, up to and including termination, as well as prosecution to the fullest extent of the law.

1212 Safe Quality Food (SQF) Certification

Policy Statement - SQF stands for SAFE, QUALITY FOOD. The SQF program is a Global Food
Safety Initiative (GFSI) benchmarked food safety standard based on Hazard Analysis Critical
Control Points (HACCP). The certification, recognized throughout the food industry, is a
measurement by which producers, suppliers, retailers, and consumers can be assured of safe,
quality food products. G&C Foods has maintained its certification since 2017.

It is expected that all G&C Foods team members follow all policies and procedures put forth by the
SQF Certification Program, including but not limited to Good Manufacturing Practices such as;

• Open Toed Shoes are prohibited on the dock and in all food production areas.
• Doors must not be propped at any time.
• No outside food is allowed in the warehouse or production area.
• No beverages other than water in a clear, sealed container is allowed in the warehouse or
production area.
• Steel toe / composite shoes or boots are required. Nonslip soles are strongly recommended.
• No shorts or capris are allowed – legs must be completely covered.
• Clothing displaying jewels, beads or “fuzzy” material is not permitted. Hooded sweatshirts may
be worn if completely covered by company issued production coat (smock).
• Operators must wear a blue smock in the vegetable packing room and a white smock in the
rebox room.
• Smocks shall not be worn into the bathrooms or anywhere in the building except the production
floor. Hooks or hangers are provided for when not in use. All smocks must be placed in the
laundry bin at the end of shift.
• Hairnets are to be worn over the ears to ensure that all hair is contained. If a hat is worn, a
hairnet must cover it.
• Operators with more than 2 days of facial hair growth must also wear a beard net. The beard
net is put on before the hairnet and must capture facial (including mustache) and neck hair.
Masks, gaiters, bandanas, and other coverings are not acceptable substitutions therefore a
beard net must be worn atop.
• Hairnets and beard nets are designed for single use.
• Disposable, latex free, nitrile gloves must be worn if job tasks involve contact with product, food
contact equipment, or primary packaging. The gloves are designed to be single use and
frequently changed. Even when using gloves, personnel shall maintain the hand washing
practices outlined above.
• The “no jewelry” policy includes piercings from the neck up, including tongue and facial
piercings. Plain (finger) bands with no stones, prescribed medical alert bracelets, or jewelry
accepted for religious or cultural reasons may be permitted, provided these items are properly
covered and do not pose a food safety risk.

The complete list of cGMPs can be found with the Quality Assurance Manager

Policy Violations- Violations of this policy will result in disciplinary action, up to and including
termination and/or legal action.
G&C Foods 1200-7 January 2024
1300 COMMUNICATION AND TECHNOLOGY

1301 Team Member Questions and Concerns

Policy Statement - G&C Foods believes that open communication between team members and
management is essential to a productive and successful work environment. It is the Company’s
intent to be responsive to team members’ questions and concerns.

Complaint Procedure - A team member is encouraged to bring any questions or concerns to the
attention of the team member’s supervisor. Normally, team member issues can be resolved through
conversations with the team member’s supervisor. However, in the event that the supervisor does
not resolve the issue to the team member’s satisfaction, or the concern involves the supervisor, the
team member may contact the Human Resource Department. The Human Resource Department
will review the situation and provide a timely response to the team member.

Complaint Procedure for Compliance Policies - If a team member’s complaint involves any of the
Company’s compliance policies relating to harassment, sexual harassment, and/or discrimination,
the team member should follow the complaint procedure outlined in Policy 505 Complaint Procedure
and Investigations.

Retaliation - A team member will not be subject to retaliation or any adverse employment action that
could affect the team member’s job security or potential advancement because of bringing any work-
related questions, concerns, or complaints to management’s attention. A team member who believes
that he or she has been retaliated against for filing a complaint should contact the Human Resource
Department immediately.

1302 Team Member Communications

Policy Statement - Company information is communicated to team members via a variety of


communication channels, including memos, e-mails, voice mail, payroll attachments, staff meetings,
company intranet, and bulletin board postings.

Staff Meetings - Staff meetings are held periodically to report on issues of interest and open
discussion on any concerns or problems you may wish to discuss. Staff meetings are mandatory
unless a team member is excused by their supervisor.

1303 Use of Electronic Communications Systems and Equipment

Policy Statement - G&C’s communication systems and equipment are an integral part of the
Company’s business and are provided to team members to aid them in the performance of their job
duties and to promote efficient operations. A team member’s improper use of company-provided
Internet services can waste time and resources and create legal liability and embarrassment for both
G&C and the team member. In using electronic communication tools, a team member must always
use integrity and professionalism and comply with all laws and corporate policies.

Definition of Communications Systems and Equipment - For the purpose of this Team member
Handbook, the Company's communications systems and equipment include, but are not limited to,
telephones, voice mail, pagers, wireless devices (e.g., cell phones, smart phones, tablets, laptops,
and mobile hotspots), photocopiers, fax machines, incoming/outgoing mail, video and audio taping
devices, and computer systems (e.g., networks, hardware, software, Internet, intranet, e-mail, instant

G&C Foods 1300-1 January 2024


messaging, text messaging, computer files, web sites, and Company social media services and
accounts.

Company Property - All Company communications systems and their contents are the sole property
of G&C. This includes all information created, transmitted by, received from or stored in these
systems.

Computers and the Internet - All computer software must be licensed and registered to the
Company. No unauthorized or unlicensed hardware or software may be used or installed on any
Company-owned computer, laptop, or wireless device. A team member may not reproduce, transfer,
download, modify, or share licensed or non-licensed software with any coworker, business,
customer, or for the team member’s personal use.

Passwords - For security purposes, some of G&C’s communications systems require a password.
If your job duties include the use of computers and various other security systems, you will be issued
the proper access and passwords. A team member may not use a password that has not been
issued to the team member or that is unknown to the Company. Passwords are confidential and
should not be disclosed to anyone other than the team member’s supervisor and the IT Department.
If it is suspected that a password has become known to others, it must be changed immediately, and
the IT Department must be notified. A team member is responsible for all computer transactions
made with the team member’s user ID and password. When leaving a workstation for an extended
period of time, a team member should log off of the computer.

Prohibited Uses - The following uses of G&C's communications systems and equipment are
prohibited. This list is meant to be illustrative and not exhaustive:

• Engaging in any illegal activity that violates copyright or other United States regulations, including
piracy, blackmail, software licensing rules, and the copying or distributing of copyrighted
materials without the express permission of the author;
• Transmitting confidential, proprietary, or trade secret information;
• Using verbal or written obscenities, vulgarities, or threats;
• Transmitting, retrieving or storing of any communications of a defamatory, discriminatory or
harassing nature or materials that are obscene or X-rated.
• Transmitting messages with derogatory or inflammatory remarks about an individual’s race, age,
disability, religion, national origin, physical attributes or sexual preference;
• Distributing chain letters;
• Accessing, or attempting to access, the computer files or e-mail, text, instant, or voicemail
messages of a coworker without appropriate authorization from the coworker or a supervisor;
• Reading, copying, modifying, or deleting a coworker’s computer files or e-mail, text, instant, or
voicemail messages without authorization from the coworker or a supervisor;
• Using or aiding in the unauthorized use of another person’s password, account or identity;
• Soliciting or advocating for commercial ventures, other employers, religious or political causes
during working time;
• Transmitting messages under an assumed name or attempting to obscure the origin of any
message;
• Attempting to remove or modify computer network equipment or software without proper
authorization;

G&C Foods 1300-2 January 2024


• Downloading or using any non-business programs, applications, browser extensions, or any
other files without prior approval.
• Harming or destroying software, data, files, or messages (other than editing or deleting
information in the normal course of job duties);
• Intentionally tampering with, obstructing, or impairing the availability of any computer system,
anti-virus software, network, or security feature, or circumventing any system intended to protect
the privacy or security of another user; and

• Using Company email to sign up for subscriptions or to register on websites, social networks,
blogs, or other online tools utilized for personal use.

Company’s Right to Monitor Communication Systems and Equipment - G&C Foods complies
with the New York State Electronic Monitoring Law as detailed in Section 400 of this Team member
Handbook. There is no guarantee of privacy when using Company-issued wireless devices and
company-owned computers, email, Internet networks, and related systems. To the extent allowed
by regulation, the Company reserves the right to access, search, and monitor the Company’s
communications equipment and files at any time in the normal course of business. This applies to
all information, messages, and files that a team member creates, transmits, downloads, receives,
views, stores, or deletes on such systems, including items that are password protected. The
Company has the ability to monitor sites visited by a team member on the Internet, chat rooms,
newsgroups, all voice mail messages, telephone calls and every e-mail message and file transfer
into and out of the Company’s network as well as any information created or discussed on social
media sites, blogs, or personal web sites. A team member’s use of the Company’s communications
systems and equipment constitutes consent to the Company accessing, intercepting, monitoring,
and disclosing any matter stored in, created, received or sent over those systems and equipment.

Virus Detection - Files obtained from outside sources, including disks brought from home; files
downloaded from the Internet, newsgroups, bulletin boards, or other online services; e-mail
attachments; and files provided by customers or vendors may contain dangerous computer viruses
that may damage the Company’s computer network. A team member may not download files from
the Internet, accept e-mail attachments from outsiders, or use disks from non-Company sources,
without first scanning the material with anti-virus software. Any suspicious e-mail or suspected virus
infection must be reported to the IT Department immediately.

Personal Use - The Company's communications systems and equipment, including but not limited
to, computers, laptops, tablets, cellphones, and the Internet are generally reserved for business
purposes. However, personal use is allowed during non-working time (e.g., authorized meal and
break periods) so long as it does not cause harm, violate any Company policies, disrupt operations,
or interfere with productivity. Personal use during working time is prohibited.

Inappropriate Web Sites and Computer Files - Sending, saving, or viewing inappropriate material
is prohibited. A team member may not log on to any inappropriate or sexually explicit web sites. The
Company reserves the right to delete any inappropriate files or material on Company-owned
computers without notification to the team member.

Use of Audio and Video Recording Devices - Due to confidentiality and personal privacy
concerns, the use of cameras, wireless devices, tape recorders, and other audio and video recording
devices are prohibited in restrooms, restricted access areas, or in any other location where personal
privacy is expected.

G&C Foods 1300-3 January 2024


A team member may not photograph, audiotape, or videotape any Company meeting or activity,
property, coworker, customer, or anyone affiliated with the Company without permission. Advance
authorization from any individual(s) being photographed is required.

1304 Social Media

Social Media –For the purpose of this team member handbook, the term “social media” refers to
any Internet-based media that facilitate activities such as professional or social networking,
posting comments or opinions, and sharing photos, audio, video, or other content. Examples
include, but are not limited to personal websites, blogs, wikis and social networking sites such as
Facebook, LinkedIn, Instagram, Snap Chat, Twitter, Tik Tok, Flickr and YouTube.

Guidelines

• Posting any confidential information as described in Section 401 is prohibited.

• All G&C Foods policies, including its sexual/anti-harassment, equal employment


opportunity (EEO), ethics, and confidentiality policies, apply to the use of social media.

• A team member is prohibited from disclosing any trade secrets, products, processes,
proprietary information, strategic business plans, or any similar or confidential information
about the Company or its customers via social media. Respect copyright, trademark, fair
use and financial disclosure laws.

• A team member may not post any information or engage in any online activity that violates
applicable local, state or federal laws, or professional rules of conduct.

• If a team member indicates on any social media that he or she is a G&C Foods team
member, he or she must clearly state that the views expressed are solely the personal
views of the team member and that they do not represent those of the Company,
customers, or suppliers. This applies to posts, blogs, and videos occurring on any
computer during both working and non-working time.

• Do not use G&C Foods email addresses to register on social networks, blogs or other
online tools utilized for personal use. In addition, a team member may not infringe on the
Company’s logos, brand names, taglines, slogans or other trademarks.

Using Social Media at Work - A team member must receive prior authorization to develop, post
to, or maintain a corporate blog or use social networking sites to conduct G&C Food’s business.
A team member who has received such authorization may post or blog during working time for
business purposes only. Engaging in social networking at work for personal use during working
time is strictly prohibited.

Using Social Media During Non-Working Time - G&C Foods respects a team member’s right
to self-expression, especially when using social media during non-working time. However, team
members are expected to be fair and courteous to G&C’s team members, clients, customers,
independent contractors, suppliers, and people who work on behalf of G&C. Keep in mind that a
team member is more likely to resolve work-related complaints by speaking directly with
management than by posting complaints to a social media outlet. Nevertheless, if a team member
decides to post complaints or criticism, avoid using statements, photographs, video, or audio that
reasonably could be viewed as malicious, obscene, threatening, or intimidating, that disparages

G&C Foods 1300-4 January 2024


clients, customers, independent contractors, team members, associates, or suppliers, or that
might constitute harassment or bullying.

Non-Retaliation - The Company will not retaliate against any team member for reporting a
possible deviation from this policy or for cooperating in an investigation. Any team member who
retaliates against another team member for reporting a possible deviation from this policy or for
cooperating in an investigation will be subject to disciplinary action, up to and including
termination.

Policy Violations - Team members are solely responsible for what they post online. Conduct
that adversely affects job performance, the performance of coworkers, violates Company policies,
or otherwise adversely affects members, customers, suppliers, may result in disciplinary action
up to and including termination.

1305 Telephone/Wireless Device Usage

Policy Statement – Because personal telephone calls can negatively affect productivity and distract
coworkers, team members are asked to limit personal phone calls during working time. This includes
the use of both Company issued phones, wireless devices and team members’ personal cell phones.
Long distance, personal calls may not result in charges to the Company. Emergency calls are
transferred to team members immediately or a message is taken and delivered so that a team
member may return the call as soon as possible.

Personal Wireless Devices - A team member should not make or receive non-business related
calls on the team member’s personal wireless device during working time, except in an emergency.
This includes sending or receiving and viewing text messages. A team member may not photograph,
audiotape, or videotape any Company meeting or activity, property, coworker, customer, or anyone
affiliated with the Company without permission from management. Advance authorization from any
individual(s) being photographed is required.

Excessive Use - If a team member’s personal calls become excessive, affect a team member’s job
performance, and/or distract coworkers, the privilege of making personal phone calls during working
time may be revoked.

USE OF CELL PHONES OR OTHER SIMILAR DEVICES - The use of personal cell phones or other
similar mobile devices will not be allowed in any safety sensitive area of the facility during working
hours. Safety Sensitive Areas are defined as: freezer(s), cooler(s), docks or loading areas,
maintenance areas, rail dock or Production or Rebox room (any warehouse area). Prohibited use
includes but it not limited to receiving or making phone calls, receiving, or sending text messages,
use of the internet, or taking photos or videos. For office team members, this means that your
personal cell phone can be utilized in the office areas, but not in the warehouse. For operation team
members, cell phones can only be used on breaks and lunches in cell phone designated areas such
as the break room, locker room or parking lots.

COMPANY-OWNED AND SUPPLIED DEVICES - The Company provides mobile devices to team
members as appropriate to their duties and responsibilities. Any team member who has been given
a company-owned mobile device for business use is allowed to keep this device on their person, but
we expect that NO phone will ever be utilized while operating a powered industrial vehicle or while
driving. This includes texting, emailing or use of the internet. Mobile devices are for Company and
business use only. Team members in possession of a Company issued mobile device are expected
to protect the equipment from loss, damage or theft. Upon resignation or termination of employment,
or at any time upon request, the team member is to produce the device for return and/or inspection.

G&C Foods 1300-5 January 2024


Mobile device usage will be monitored and misuse may result in disciplinary action, up to and
including termination.

G&C Foods reserves the right to monitor the usage of company-owned/mobile devices.

Policy Violations- Violations of this policy will result in disciplinary action, up to and including
termination.

1306 Mail

Personal Mail - A team member may place personal letters with the Company's outgoing mail for
delivery to the post office as long as the team member’s own postage is used.

Personal mail, including magazines and packages, should not be delivered to the workplace. The
Company reserves the right to review all incoming mail, including mail addressed to individual team
members.

Stationery and Business Cards - Business cards and personalized Company stationery may only
be issued by G&C Foods. Company stationery may not be used for a team member’s personal use
nor should a team member’s personal correspondence appear to be official communication from
G&C Foods.

1307 Team Member Suggestions

Policy Statement - G&C Foods values the suggestions and ideas of team members. A team
member is strongly encouraged to inform the team member's supervisor of any suggestions that
may be valuable to the Company's productivity and success. All suggestions are carefully reviewed
and implemented, if feasible.

1308 Customer and Media Relations

Customer Relations - Customers and the public should be assisted promptly and treated
courteously and professionally at all times. Positive customer service can greatly enhance goodwill,
while a negative experience can easily destroy a valuable customer relationship.

A team member should treat all complaints from customers, vendors, suppliers, or members of the
public seriously and professionally. Take the time to listen carefully and resolve the person’s
concerns, if possible. In the event the complaint cannot be resolved to the person’s satisfaction or if
the person becomes unreasonable or harassing, the team member should immediately notify the
President or Marketing Coordinator.

Media Relations - Events may occur that will draw immediate attention from the news media. It is
imperative that one person speaks for the Company to deliver an appropriate message and to avoid
giving misinformation in any media inquiry. Accordingly, all requests for information from the media
(e.g., television, radio, and newspaper) regarding any aspect of G&C Foods must be referred to the
President or Marketing Coordinator. Likewise, any official press releases or publications released to
the media must be approved by the President or Marketing Coordinator.

Use of Photographs, Video and Digital Recordings of Team Members- Often G&C will
photograph, videotape, or take digital recordings of people and activities that occur here at G&C
Foods for the purpose of promoting G&C Foods. Your name and identity may be revealed therein
or by descriptive text or commentary. The consent releases to G&C Food Distributors, its agents,
and team members all rights to exhibit this work in print and electronic form publicly or privately and
G&C Foods 1300-6 January 2024
to market and sell copies. You will waive any rights, claims, or interest that you may have to control
the use of your identity or likeness in whatever media used. In addition, you should understand that
there will be no financial or other remuneration for recording you, either for initial or subsequent
transmission or playback. G&C Food Distributors is not responsible for any expense or liability
incurred as a result of your participation in these recordings, including medical expenses due to any
sickness or injury incurred as a result. This policy covers external promotional materials only; it does
not pertain to the G&C’s internal facility video system.

If you wish to opt out and not have your photo or video used for promotional purposes, you may do
so by completing an opt out form. This form can be obtained from the Human Resources
Department.

1309 Internet Usage

Purpose -The purpose of this policy is to ensure the proper use of G&C Foods’ (hereinafter
referred to as Company) Internet System (hereinafter referred to as System) and make its team
members and users aware of what the Company deems as acceptable and unacceptable use of
the System. This policy also provides for sanctions in the event of a breach or violation of the
policy terms hereunder.
Applicability-This Policy applies to all users of company technology, including team members,
contractors, vendors, partners, associates, and any other parties accessing or using the
Company’s System through on-site or remote terminals.
Disclaimer of liability for use of Internet- The Company is not responsible for material viewed
or downloaded by users from the Internet. The Internet is a worldwide network of computers that
contains countless amounts of information. Users are cautioned that many of this information
includes offensive, sexually explicit, and inappropriate material. In general, it is difficult to avoid
at least some contact with this material while using the Internet. Even innocuous search requests
may lead to sites with highly offensive content. In addition, having an e-mail address on the
Internet may lead to receipt of unsolicited e-mail containing offensive content. Users accessing
the Internet do so at their own risk.
Duty not to waste computer resources- Team members must not deliberately perform acts that
waste computer resources or unfairly monopolize resources to the exclusion of others. These
acts include, but are not limited to, sending mass mailings or chain letters, spending excessive
amounts of time on the Internet, playing games, engaging in online chat groups, printing multiple
copies of documents, or otherwise creating unnecessary network traffic. Because audio, video
and picture files require significant storage space, files of this or any other sort may not be
downloaded unless they are business-related.
Business Use and Limited Personal Use- The computers and computer accounts given to team
members are the exclusive property of the Company. The System exists to provide team
members with resources to complete their job tasks. The System is to be used primarily for
company-related business activities. However, team members may use the System during
breaks, lunch, or other non-working periods of time to conduct limited personal business. No IT
Department resources will be expended to assist team members or troubleshoot technical
difficulties related to personal use of the System.
Monitoring Use and Expectation of Privacy- The Company reserves the right to monitor,
intercept and/or review all data transmitted, received or downloaded over the System. Any
individual who is given access to the System is hereby given notice that the Company will exercise
G&C Foods 1300-7 January 2024
this right periodically, without prior notice and without the prior consent of the team member. No
individual should have any expectation of privacy in any communication over this System. The
Company’s interests in monitoring and intercepting data include but are not limited to: protection
of company proprietary and classified data; managing the use of the Company’s computer
System; preventing the transmission or receipt of inappropriate materials by team members;
and/or assisting the team member in the management of electronic data during periods of
absence. Additionally, no individual should interpret the use of password protection as creating a
right or expectation of privacy. In order to protect everyone involved, no one can have a right or
expectation of privacy with regards to the receipt, transmission or storage of data on the
Company’s Internet System.
Blocking of Malicious Content and Risky websites- Company may use software to identify
and block websites and web applications that may contain malicious content. Generally, sites that
pose a high cybersecurity risk will be blocked. Malicious content includes malware, ransomware,
spam, or any other content that could cause potential harm to the Company, its people, and its
resources. If you are blocked from accessing a website that has a genuine business need, please
send the website address and an explanation to the IT Department for approval of an exception.
Prohibited Activities- Material that is fraudulent, harassing, embarrassing, sexually explicit,
profane, obscene, intimidating, defamatory, or otherwise unlawful, inappropriate, offensive
(including offensive material concerning sex, race, color, national origin, religion, age, disability,
or other characteristic protected by law), or in violation of Company’s equal employment
opportunity policy and its policies against sexual or other harassment may not be downloaded
from the Internet or displayed or stored in Company’s computers. Team members encountering,
witnessing or receiving this kind of material should immediately report the incident to their
immediate supervisor and to the Business Solutions Group at bsg@gcfoods.com. Company’s
equal employment opportunity policy and its policies against sexual or other harassment apply
fully to the use of the Internet and any violation of those policies is grounds for discipline up to
and including termination.
Games and Entertainment Software- Team members may not use the Company’s Internet
connection to download games or other entertainment software, including wallpaper and screen
savers, or to play games over the Internet.
Illegal Copying- Team members may not illegally copy material protected under copyright law or
make that material available to others for copying. You are responsible for complying with
copyright law and applicable licenses that may apply to software, files, graphics, documents,
messages, and other material you wish to download or copy. You may not agree to a license or
download any material for which a registration fee is charged without first obtaining the express
written permission of your immediate supervisor and Human Resources.
Virus and Malware Detection- Files obtained from sources outside the company, including disks
brought from home; files downloaded from the Internet, newsgroups, bulletin boards, or other
online services; files attached to e-mail; and files provided by customers or vendors may contain
dangerous computer viruses that may damage the company’s computer network. Team members
should never download files from the Internet, accept e-mail attachments from outsiders, or use
disks from non-company sources. If you suspect that a virus has been introduced into the
company’s network, notify the Business Solutions Group immediately.
Amendments and Revisions- This policy may be amended or revised from time to time as the
need arises. Users will be provided with copies of all amendments and revisions.

G&C Foods 1300-8 January 2024


Violations of this Policy- Any team member who abuses the privilege of access to the
Company’s Voicemail, E-mail or the Internet System will be subject to corrective action, up to and
including termination. If necessary, the Company also will advise law enforcement officials of any
illegal conduct.
Use of Internet- Use of the Internet via Company’s computer system constitutes consent by the
user to all the terms and conditions of this policy.
Points of Contact- Questions concerning the use of the Internet System should be directed
bsg@gcfoods.com. Questions concerning the improper use of the System should be directed to
the team member’s immediate supervisor and bsg@gcfoods.com

1310 Email Use

Purpose- The purpose of this policy is to ensure the proper use of G&C Foods’ (hereinafter
referred to as Company) email system and make the users (defined below) aware of what the
Company deems as acceptable and unacceptable use of its email system. This policy also
provides for sanctions in cases of breach of violation of the policy terms.
Applicability- This policy applies to the use of the Company’s email services by team members
at the Company’s offices, as well as remote locations, including, but not limited to, the team
member’s homes, airports, hotels, and client offices. All company team members, full-time or
part-time, independent contractors, interns, consultants, clients, and other third parties who
have been granted the right to use the Company’s email services are defined as users for the
purpose of this policy and are required to read & attest to this agreement confirming their
understanding and acceptance of this policy.
Email Accounts are the Property of the Company- All email accounts maintained on the
Company’s email systems are property of the Company. The Company has the right to read
and keep a record of any emails that users transmit via the Company’s email system.
E-mail exists for Business Purposes only- The Company provides its e-mail system for
business purposes. The use of the Company’s email system for any personal uses is highly
discouraged. Specific usage details are provided below:

• Company email addresses should not be used as the User ID or contact method for
personal online accounts such as Amazon, Facebook, Netflix, or others.
• It is acceptable for the team member to use their Company email address for emergency
contact or notifications from a family member, a children’s school, or similar situations.
• Team members should be aware that all uses of IT assets are subject to monitoring as
described in this policy and as such, the team member has no right to, or expectation of,
privacy with respect to their use of technology.

Unacceptable use of Email- The following acts shall constitute unacceptable use of the email
system of the Company:

• Accessing copyrighted information in a way that violates the copyright.


• Broadcasting unsolicited personal views or chain letters on social, political, religious or other
non-business-related matters.
• Using the Company’s communications systems to run a personal business, conduct an
external job search, or solicit money for personal gain.
• Forwarding confidential Company information in messages to external locations.

G&C Foods 1300-9 January 2024


• Distributing or storing images, text or materials that might be considered indecent,
pornographic, obscene, or illegal.
• Distributing or storing images, text or materials that might be considered discriminatory,
offensive or abusive, in that the context is a personal attack, sexist or racist, or might be
considered harassment.
• Introducing any form of computer virus or malware into the corporate network;
Team members must maintain confidentiality and control of their credentials (passwords,
tokens, certificates). Credentials must not be shared or left where an unauthorized person
might find them. Users must report to IT and their manager if they believe their credential
has been compromised.

Legal Risks Involved- Email is a business communication tool and the users are obliged to use
this tool in a responsible, effective, and lawful manner. Although by its nature email seems to be
less formal than other written communication, similar laws apply. Therefore, it is important that
users are aware of the following legal risks of e-mail. Both the user and the Company can be
held liable for:

• Sending emails with any libelous, defamatory, offensive, racist or obscene remarks.
• Forwarding emails with any libelous, defamatory, offensive, racist or obscene remarks.
• Unlawfully forwarding the confidential information of others.
• Unlawfully forwarding messages that contain copyrighted materials without permission.
• Sending an attachment that contains a virus.
The above list does not enumerate all the legal risks involved. If any user disregards the
rules set out in this Email Policy, Company can take corrective action up to and including
termination of employment.
Best Practices- The Company considers email an important means of communication and
recognizes the importance of appropriate email content and prompt replies in conveying a
professional image and delivering good customer service. Therefore, the Company institutes the
following guidelines for users to adhere to as “Best Practices”:

• All email messages sent on company equipment should be professional and appropriate.
• Write well-structured emails and use short, descriptive subjects.
• The Company’s email style is informal. This means that sentences can be short and to the
point. However, the use of Internet abbreviations and characters such as smileys is not
encouraged.
• Signatures should include your name, job title and company name.
• Do not send unnecessary attachments. Compress larger attachments before sending them.
• Do not write emails in ALL CAPITAL LETTERS.
• If you forward mails, state clearly what action you would like the recipient to take.
• Only send emails of which the content could be displayed on a public notice board. If they
cannot be displayed publicly in their current state, consider rephrasing the email or using
other means of communication.
• Emails that require a reply should normally be answered in 24 hours or less.
• Email passwords should not be given to other people and should be changed periodically.
• To keep resource usage to a minimum, delete any email messages that you do not need.
• E-mail messages are written business records and are subject to the Company’s rules and
policies relating to retaining and deleting business records.

G&C Foods 1300-10 January 2024


• Avoid sending confidential information by email. Unless specifically authorized to do so, the
users are prohibited from using email to transmit confidential information to outside parties.
Users may not access, send, receive, solicit, print, copy, or reply to confidential or
proprietary information about the Company, its team members, clients, and other business
associates. Confidential information includes, but is not limited to client lists, credit
card numbers, Social Security numbers, team member performance reviews, salary
details, trade secrets, corporate confidential information, and any other information
that is not specifically deemed by corporate practice or policy to be appropriate for
the recipients of any email.

System Monitoring- E-mail messages created and transmitted via the Company’s email
system are the property of the Company. The Company reserves the right to monitor all email
transmitted via the Company’s email system. Team members have no reasonable expectation
of privacy when it comes to business and personal use of the Company’s email system.
Email and Phone Call Phishing: Email phishing and phone call phishing (‘vishing’) poses a
significant security threat to our organization, and it is imperative that every employee takes
proactive steps to prevent falling victim to these fraudulent schemes. This policy is designed to
safeguard our confidential information, protect our network infrastructure, and maintain the overall
security and integrity of our organization.

Policy Scope: This policy applies to all employees, contractors, vendors, and any other individuals
who have access to G&C Foods’ email systems and network resources.

Awareness and Training:


• G&C Foods will provide regular training sessions to educate employees about the risks and
signs of email and phone call phishing attacks.
• All employees are required to complete phishing awareness training upon joining the
organization and annually thereafter.
• G&C Foods will tag all email from external senders to aid in employees’ comprehension of
emails that present higher risk and which are more likely to be phishing attempts.

Phishing Detection:
• Employees should exercise caution when opening emails or answering phone calls from
unfamiliar or suspicious sources.
• When reviewing emails, employees must pay close attention to the sender's email address,
subject line, and message content for any inconsistencies or signs of phishing. G&C Foods will
tag all email from external senders with a banner or similar form of warning. No email with this
banner is ever from an internal employee.
• Be cautious when clicking on links or downloading attachments from unknown sources.

Verification of Requests:
• Employees should verify any unusual requests received via email or phone call, especially
those related to financial transactions, account access, or sensitive data.
• Always verify such requests through a separate communication channel, such as an employee-
originating phone call or in-person, with the person or department involved.

Reporting Phishing Attempts:


• If an employee receives an email suspected to be a phishing attempt, they must report it
immediately using the “Report” function in Outlook.
• Do not reply to the suspicious email or forward it to anybody, including the Business Solutions
Group (BSG).
G&C Foods 1300-11 January 2024
Response to Phishing Attempts:
• If an employee mistakenly clicks on a phishing link or discloses sensitive information via any
mechanism (email, voice, etc.), they must report it immediately to the BSG.
• BSG will take appropriate measures to mitigate the impact, which may include resetting
passwords, scanning for malware, or implementing additional security controls.

Password Security:
• Employees are responsible for maintaining strong and unique passwords for their email
accounts.
• Passwords should not be shared, written down, or stored in easily accessible locations.
• Multi-factor authentication must be enabled when available.

Email Security Measures:


• G&C Foods will implement email filtering and anti-phishing solutions to minimize the volume of
phishing emails reaching employees' inboxes.
• Employees should not disable or circumvent email security controls.

Violations and Sanctions- If a team member is found to violate any of this email policy rules,
the Company may take disciplinary action up to and including termination of employment. The
actual penalty applied will depend on factors such as the seriousness of the violation, the team
member’s disciplinary record, and any other factors the Company deems necessary to consider.
If a team member witnesses email policy abuse by, he/she is required to report the incident
immediately to their supervisor.
Amendment of Policy- The Company reserves the right to amend this policy at its discretion.
In case of amendments, users will be informed appropriately.
Points of Contact- If you have any questions or comments about this Email Policy, please
contact the Business Solutions Group at bsg@gcfoods.com. If you do not have any questions,
the Company presumes that you understand and are aware of the rules and guidelines in this
email policy and will adhere to them.

G&C Foods 1300-12 January 2024


G&C FOODS TEAM MEMBER
HANDBOOK ACKNOWLEDGMENT

By signing below, I acknowledge that I have received or have ready-access (or online access) to a copy of
G&C Foods’s Team member Handbook and that I have read it, understand it, and agree to abide by the
policies contained therein. I understand that any violation of the policies in this Handbook could result in
discipline, up to and including termination. I am aware that if I have any questions regarding the contents of
the Team member Handbook I should contact my manager or Human Resources.

I understand that the policies in this team member handbook may supersede, modify, or eliminate benefits,
policies, procedures, or rules previously issued by the Company.

I understand that G&C Foods reserves the right to interpret, add, modify, or revoke any provision in the team
member handbook with or without cause or notice. I also understand that the team member benefits, policies,
procedures, rules, and regulations in this team member handbook will remain in effect until notified otherwise
by the Company. I agree to retain my copy of the team member handbook for future reference and to update
it with any policy additions or revisions that the Company issues.

I am aware that my copy of the team member handbook and any G&C Foods property in my possession
must be returned to the Company upon my separation from employment or when requested by the
Company.

I understand that I may be subject to random as well as reasonable suspicion substance testing as outlined
in the Substance-Free Workplace Policy. I am aware that my refusal to consent to such a test or to test
positive for alcohol or illegal drugs is a policy violation which will result in disciplinary action, up to and
including termination.

Employment at G&C Foods is employment-at-will. Accordingly, this team member handbook is not intended
to be a contract of employment, a warranty of benefits, or a limitation on the Company's ability to terminate
team members.

Failure to sign this team member handbook acknowledgement may result in disciplinary action, up to and
including termination.

Team Member Name (Please Print)

Team Member Signature Date of Signature

G&C Foods January 2024


Addendum A – NY HERO Act

Airborne Infectious Disease Exposure Prevention Plan

The purpose of this plan is to protect team members against exposure and disease during an airborne
infectious disease outbreak. This plan goes into effect when an airborne infectious disease is
designated by the New York State Commissioner of Health as a highly contagious communicable
disease that presents a serious risk of harm to the public health. This plan is subject to any additional or
greater requirements arising from a declaration of a state of emergency due to an airborne infectious
disease, as well as any applicable federal standards.
Team members should report any questions or concerns with the implementation this plan to the
designated contact.
This plan applies to all “team members” as defined by the New York State HERO Act, which means any
person providing labor or services for remuneration for a private entity or business within the state,
without regard to an individual’s immigration status, and shall include part-time workers, independent
contractors, domestic workers, home care and personal care workers, day laborers, farmworkers, and
other temporary and seasonal workers. The term also includes individuals working for digital
applications or platforms, staffing agencies, contractors, or subcontractors on behalf of the employer at
any individual work site, as well as any individual delivering goods or transporting people at, to or from
the work site on behalf of the employer, regardless of whether delivery or transport is conducted by an
individual or entity that would otherwise be deemed an employer under this chapter. The term does not
include team members or independent contractors of the state, any political subdivision of the state, a
public authority, or any other governmental agency or instrumentality.

RESPONSIBILITIES- This plan applies to all team members of G&C Foods, and the following work sites:
3407 Walters Road warehouse and office facility.

This plan requires commitment to ensure compliance with all plan elements aimed at preventing the
spread of infectious disease. The following supervisory team member(s) are designated to enforce
compliance with the plan. Additionally, these supervisory team members will act as the designated
contacts unless otherwise noted in this plan:

Name Title Location Phone


Dave Pangaro Safety Manager 3407 Walters Road 315-415-3252

EXPOSURE CONTROLS DURING A DESIGNATED OUTBREAK

MINIMUM CONTROLS DURING AN OUTBREAK


During an airborne infectious disease outbreak, the following minimum controls will be used in all areas
of the worksite:
1. General Awareness: Individuals may not be aware that they have the infectious disease and can
spread it to others. Team members should remember to:
• Maintain physical distancing.
• Exercise coughing/sneezing etiquette.
• Wear face coverings, gloves, and personal protective equipment (PPE), as appropriate.
• Individuals limit what they touch.
• Stop social etiquette behaviors such as hugging and hand shaking, and
• Wash hands properly and often.
G&C Foods January 2024
2. “Stay at Home Policy”: If a team member develops symptoms of the infectious disease, the team
member should not be in the workplace. The team member should inform the designated contact
and follow New York State Department of Health (NYSDOH)and Centers for Disease Control and
Prevention (CDC) guidance regarding obtaining medical care and isolating.

3. Health Screening: Team members will be screened for symptoms of the infectious disease at the
beginning of their shift. Team members are to self-monitor throughout their shift and report any
new or emerging signs or symptoms of the infectious disease to the designated contact. A team
member showing signs or symptoms of the infectious disease should be removed from the
workplace and should contact a healthcare professional for instructions. The health screening
elements will follow guidance from NYSDOH and CDC guidance, if available.

4. Face Coverings: To protect your coworkers, team members will wear face coverings throughout
the workday to the greatest extent possible. Face coverings and physical distancing should be
used together whenever possible. The face covering must cover the nose and mouth, and fit
snugly, but comfortably, against the face. The face covering itself must not create a hazard, e.g.
have features could get caught in machinery or cause severe fogging of eyewear. The face
coverings must be kept clean and sanitary and changed when soiled, contaminated, or damaged.

Effective February 10, 2022: Team members will wear appropriate face coverings in accordance
with guidance from State Department of Health or the Centers for Disease Control and Prevention,
as applicable. Consistent with the guidance from the State Department of Health, if indoor areas do
not have a mask or vaccine requirement as a condition of entry, appropriate face coverings are
recommended, but not required. It is also recommended that face coverings be worn by
unvaccinated individuals, including those with medical exemptions, in accordance with federal CDC
guidance. Further, the State’s masking requirements continue to be in effect for pre-K to grade 12
schools, public transit, homeless shelters, domestic violence shelters, correctional facilities, nursing
homes, health care, child care, group homes, and other sensitive settings in accordance with CDC
guidelines. New York State and the State Department of Health continue to strongly recommend
face coverings in all public indoor settings as an added layer of protection, even when not required.

5. Physical Distancing: Physical distancing will be followed as much as feasible. Avoid unnecessary
gatherings and maintain a distance of at least six feet (or as recommended by the NYSDOH/CDC
for the infectious agent) from each other. Use a face covering when physical distance cannot be
maintained.

In situations where prolonged close contact with other individuals is likely, use the following
control methods: (Note to employer: Check off the controls you intend to use and add any
additional controls not listed here.)
• restricting or limiting customer or visitor entry;
• limiting occupancy;
• allowing only one person at a time inside small enclosed spaces with poor ventilation;
• reconfiguring workspaces;
• physical barriers;
• signage;
• floor markings;
• telecommuting;
• remote meetings;
• preventing gatherings;
• restricting travel;
• creating new work shifts and/or staggering work hours;
G&C Foods January 2024
• adjusting break times and lunch periods;
• delivering services remotely or through curb-side pickup;

6. Hand Hygiene: To prevent the spread of infection, team members should wash hands with soap
and water for at least 20 seconds or use a hand sanitizer with at least 60% alcohol to clean hands
BEFORE and AFTER:

• Touching your eyes, nose, or mouth;


• Touching your mask;
• Entering and leaving a public place; and
• Touching an item or surface that may be frequently touched by other people, such as door
handles, tables, gas pumps, shopping carts, or electronic cashier registers/screens.

Because hand sanitizers are less effective on soiled hands, wash hands rather than using hand
sanitizer when your hands are soiled.
7. Cleaning and Disinfection: See Section V of this plan.

8. “Respiratory Etiquette”: Because infectious diseases can be spread by droplets expelled from
the mouth and nose, team members should exercise appropriate respiratory etiquette by covering
nose and mouth when sneezing, coughing or yawning.

9. Special Accommodations for Individuals with Added Risk Factors: Some team members, due
to age, underlying health condition, or other factors, may be at increased risk of severe illness if
infected. Please inform your supervisor or the HR department if you fall within this group and need
an accommodation.

ADVANCED CONTROLS DURING AN OUTBREAK

For activities where the Minimum Controls alone will not provide sufficient protection for team
members, additional controls from the following hierarchy may be necessary. Employers should
determine if the following are necessary:
Elimination: Employers should consider the temporary suspension or elimination of risky activities
where adequate controls could not provide sufficient protection for team members.

Engineering Controls: Employers should consider appropriate controls to contain and/or remove
the infectious agent, prevent the agent from being spread, or isolate the worker from the infectious
agent. Examples of engineering controls include:

i. Mechanical Ventilation:
a. Local Exhaust Ventilation, for example:
• Ventilated booths (lab hoods);
• Kitchen Vents; and
• Vented biosafety cabinets.

b. General Ventilation, for example:


• Dedicated ventilation systems for cooking areas, malls, atriums, surgical suites, manufacturing,
welding, indoor painting, laboratories, negative pressure isolation rooms;
• Increasing the percentage of fresh air introduced into air handling systems;
• Avoiding air recirculation;
• Using higher-efficiency air filters in the air handling system;
G&C Foods January 2024
• If fans are used in the facility, arrange them so that air does not blow directly from one worker
to another; and

ii. Natural Ventilation, for example:


• Opening outside windows and doors to create natural ventilation; and
• Opening windows on one side of the room to let fresh air in and installing window exhaust fans
on the opposite side of the room so that they exhaust air outdoors. (Note: This method is
appropriate only if air will not blow from one person to another.)

iii. Install automatic disinfection systems (e.g., ultraviolet light disinfection systems).
iv. Install cleanable barriers such as partitions and/or clear plastic sneeze/cough guards.
v. Change layout to avoid points or areas where team members may congregate (e.g., install
additional timeclocks).

Subject to changes based on operations and circumstances surrounding the infectious disease,
engineering controls that are anticipated to be used are listed in the following table:
Engineering Controls Utilized/Location(s):
• UV Light Filtration in administrative Office areas.
• Increasing air change over in all applicable areas.
• Using MERV #8 & 13 pleated filters in the HVAC.

“Administrative Controls” are policies and work rules used to prevent exposure. Examples include:

• Increasing the space between workers;


• Slowing production speed to accommodate fewer workers at a time;
• Disinfecting procedures for specific operations;
• Not shaking out soiled laundry;
• Team member training;
• Identify and prioritize job functions that are essential for continuous operations;
• Cross-train team members to ensure critical operations can continue during worker absence;
• Limit the use of shared workstations;
• Post signs reminding team members of respiratory etiquette, masks, handwashing;
• Rearrange traffic flow to allow for one-way walking paths;
• Provide clearly designated entrance and exits;
• Provide additional short breaks for handwashing and cleaning;
• Establishing pods or cohorts working on same shift;

Subject to changes based on operations and circumstances surrounding the infectious disease, the
following specific administrative controls are anticipated to be used:

Administrative Controls Utilized/Location(s):

Personal Protective Equipment (PPE) are devices like eye protection, face shields, respirators, and gloves
that protect the wearer from infection. PPE will be provided, used and maintained in a sanitary and reliable
condition at no cost to the team member. The PPE provided to a team member will be based on a hazard
assessment for the workplace.

G&C Foods January 2024


PPE Required- Activity Involved/Location:
• Face Masks Inside

EXPOSURE CONTROL READINESS, MAINTENANCE AND STORAGE:


The controls we have selected will be obtained, properly stored, and maintained so that they are ready
for immediate use in the event of an infectious disease outbreak and any applicable expiration dates
will be properly considered.
HOUSEKEEPING DURING A DESIGNATED OUTBREAK

A. Disinfection Methods and Schedules

Objects that are touched repeatedly by multiple individuals, such as door handles, light switches,
control buttons/levers, dials, levers, water faucet handles, computers, phones, or handrails must be
cleaned frequently with an appropriate disinfectant. Surfaces that are handled less often, or by fewer
individuals, may require less frequent disinfection. The disinfection methods and schedules selected
are based on specific workplace conditions.
The New York State Department of Environmental Conservation (NYSDEC)and the Environmental
Protection Agency (EPA) have compiled lists of approved disinfectants that are effective against
many infectious agents (see dec.ny.gov and epa.gov/pesticide-registration/selected-epa-
registered-disinfectants). Select disinfectants based on NYSDOH and CDC guidance and follow
manufacturer guidance for methods, dilution, use, and contact time.
B. Adjustments to Normal Housekeeping Procedures
Normal housekeeping duties and schedules should continue to be followed during an infectious
disease outbreak, to the extent practicable and appropriate consistent with NYSDOH and/or CDC
guidance in effect at the time. However, routine procedures may need to be adjusted and additional
cleaning and disinfecting may be required.
Housekeeping staff may be at increased risk because they may be cleaning many potentially
contaminated surfaces. Some housekeeping activities, like dry sweeping, vacuuming, and dusting,
can resuspend into the air particles that are contaminated with the infectious agent. For that reason,
alternative methods and/or increased levels of protection may be needed.
Rather than dusting, for example, the CDC recommends cleaning surfaces with soap and water
before disinfecting them. Conducting housekeeping during “off” hours may also reduce other
workers’ exposures to the infectious agent. Best practice dictates that housekeepers should wear
respiratory protection. See cdc.gov for more guidance.
C. If a team member develops symptoms of the infectious disease at work, it is ideal to isolate the area in
accordance with guidance issued by NYSDOH or the CDC, before cleaning and disinfecting the sick team
member’s work area. This delay will allow contaminated droplets to settle out of the air and the space to be
ventilated.
D. As feasible, liners should be used in trash containers. Empty the containers often enough to prevent
overfilling. Do not forcefully squeeze the air out of the trash bags before tying them closed. Trash
containers may contain soiled tissue or face coverings.

G&C Foods January 2024


INFECTION RESPONSE DURING A DESIGNATED OUTBREAK

If an actual, or suspected, infectious disease case occurs at work, take the following actions:
• Instruct the sick individual to wear a face covering and leave the worksite and follow
NYSDOH/CDC guidance.
• Follow local and state authority guidance to inform impacted individuals.

TRAINING AND INFORMATION DURING A DESIGNATED OUTBREAK

A. G&C Foods will verbally inform all team members of the existence and location of this Plan, the
circumstances it can be activated, the infectious disease standard, employer policies, and team member
rights under the HERO Act. (Note: training need not be provided to the following individuals: any
individuals working for staffing agencies, contractors or subcontractors on behalf of the employer at any
individual work site, as well as any individual delivering goods or transporting people at, to or from the work
site on behalf of the employer, where delivery or transport is conducted by an individual or entity that would
otherwise be deemed an employer under this chapter)

B. When this plan is activated, all personnel will receive training which will cover all elements of this plan
and the following topics:

1. The infectious agent and the disease(s) it can cause.


2. The signs and symptoms of the disease;
3. How the disease can be spread;
4. An explanation of this Exposure Prevention Plan;
5. The activities and locations at our worksite that may involve exposure to the infectious agent;
6. The use and limitations of exposure controls
7. A review of the standard, including team member rights provided under Labor Law, Section 218-B.

C. The training will be:


1. Provided at no cost to team members and take place during working hours. If training during
normal work hours is not possible, team members will be compensated for the training time (with
pay or time off);
2. Appropriate in content and vocabulary to your educational level, literacy, and preferred language;
and
3. Verbally provided in person or through telephonic, electronic, or other means.

PLAN EVALUATIONS DURING A DESIGNATED OUTBREAK


The employer will review and revise the plan periodically, upon activation of the plan, and as often as
needed to keep up-to-date with current requirements. Document the plan revisions below:
Plan Revision History:
Date Participation Major Changes Approved By
2/10/22 All team members Face Coverings NYS Hero Act update

G&C Foods January 2024


RETALIATION PROTECTIONS AND REPORTING OF ANY VIOLATIONS

No employer, or his or her agent, or person, , acting as or on behalf of a hiring entity, or the officer or agent
of any entity, business, corporation, partnership, or limited liability company, shall discriminate, threaten,
retaliate against, or take adverse action against any team member for exercising their rights under this
plan, including reporting conduct the team member reasonably believes in good faith violates the plan or
airborne infectious disease concerns to their employer, government agencies or officials or for refusing to
work where a team member reasonably believes in good faith that such work exposes him or her, other
workers, or the public to an unreasonable risk of exposure, provided the team member, another team
member, or representative has notified the employer verbally or in writing, including electronic
communication, of the inconsistent working conditions and the employer’s failure to cure or if the employer
knew or should have known of the consistent working conditions.
Notification of a violation by a team member may be made verbally or in writing, and without limitation to
format including electronic communications. To the extent that communications between the employer and
team member regarding a potential risk of exposure are in writing, they shall be maintained by the
employer for two years after the conclusion of the designation of a high-risk disease from the
Commissioner of Health, or two years after the conclusion of the Governor’s emergency declaration of a
high risk disease. Employer should include contact information to report violations of this plan and
retaliation during regular business hours and for weekends/other non-regular business hours when team
members may be working.

G&C Foods January 2024

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