El Monte City Council
March 1, 2022

Proposer represents that the following person is authorized to negotiate on its behalf with the City in Connection with this RFP:

Jason Snow, Vice President/COO (626) 258-1310
Name Title Phone
The undersigned certifies that it has examined and is fully familiar with all of the provisions of the RFP Documents and is satisfied that they are accurate; that it has carefully checked all the words and figures and all statements made in the Proposal Requirements; that it has satisfied itself with respect to other matters pertaining to the proposal which in any way affect the work or the cost thereof.

The undersigned hereby agrees that the City will not be responsible for any errors or omissions in these RFP Documents.

By·
Timmy Mardirossian
Type or Print Name
3650 Rockwell Avenue
Business Address
El Monte, CA 91731
City, State, Zip Code
(626) 258-1310
Telephone Number
( 626) 258-1329
FAX Number

Proposal Check Sheet
Explain in detail any NO answers. Attach additional pages to the form if necessary.

General Requirements
Have you completed and enclosed the Cost Proposal (Form 1)? CKJ D Yes No
Have you completed and enclosed the Proposal Letter (Form 2)? [i] D Yes No
Have you completed and enclosed the Proposal Check Sheet (Form 3)? CiJ D Yes No
Have you enclosed all required Attachments, Forms, etc.? w D Yes No
Have you enclosed at least three current client references? [i] D Yes No
Have you enclosed at least one previous client reference? ~ D Yes No
Have you included your Certification Regarding Lobbying? [i] D Yes No
Have you included your False Claims Act Certification? D Yes No
Have you included your Civil Litigation Certification? [i] D Yes No
Have you included your DBE Certifications, if applicable? [i] D Yes No
Does your company currently possess a business license for the City of El Monte? [i] Yes
D
No
Does your company currently provide transportation service to El Monte Residents? GJ Yes
D
No
Does your company have previous experience in providing transportation service to El Monte resident?
Operations Facility
Is your operations facility located in the El Monte service area? Have you provided the address and complete description of your proposed operations facility?
Have you provided a list of all other operations provided from the proposed operations facility?
Recruiting & Training
Do all of your drivers receive 80 hours of classroom instruction and operation training?
Does your company employ a full-time training staff?
Does your company employ a full-time driver recruiter?
CKJ D
Yes No
CiJ D
Yes No
CKJ D
Yes No
~ D Yes No
[[] D Yes No
~ D
Yes No
[[] D
Yes No
FORM3
Does your company participate in the California DMV Employer Testing Program?
Do all of your drivers receive at least 12 hours of annual refresher training? Does your company currently employ El Monte resident?
Safety
Have you included a copy of your company's safety plan? Does your company employ trained accident investigators? Insurance
Does your company provide at least $5,000,000 Automobile Liability coverage? Does your company provide at least $10,000,000 General Liability coverage? Does your company provided $1,000,000 Workers Compensations coverage to all employees?
Billing & Reporting
Does your company use auditing procedures to ensure the accuracy of fare collection and billing?
Are audit procedures fully described in your proposal?
Project Staffing
Have you identified the Project Manager in your proposal and provided a complete description of his/her experience and qualifications? Have you identified and described the experience and qualifications of all backup personnel and other supervisors that will provide service to the City? Have you included a detailed organization chart which shows the number of all staff (including drivers, dispatchers and receptionist) providing service to the city? Have you identified your maintenance manager and/or road supervisor and clearly described his/her experience and qualifications? Have you included wage and benefit information for vehicle maintenance staff and/or road supervisors?
Have you identified the number and experience of vehicle mechanics? Have you provided a Manpower Analysis?
Does the Manpower Analysis clearly identify the other commitments/projects that staff members are required to complete?

~ Q
[i] D
Yes No
[i] D
Yes No
[K] D
Yes No
[i] D
Yes No
[i] D
Yes No
w D
Yes No
[iJ D
Yes No
W, Q
[i] D
Yes No
[i] D Yes No
w. Q
[K] Q Yes
[i] D Yes No
[KJ D
Yes No
[Kl D
Yes No
[i] D
Yes No
%i Q
Other
Does your company survey its customers for satisfaction/needs ratings? Have you provided copies of survey results and sample surveys in your proposal? Have you included copies of your safety policy, Drug and Alcohol testing policy, accident reporting forms, management reports and all other relevant documents?

[Kl D
Yes No
~ D
Yes No
C:HUE3E3 .
09 December 2021
Westchester Fire Insurance Company
436 Walnut Street
Philadelphia, PA 19106
USA
Re: Southland Transit / Prequalification Letter
To Whom It May Concern:
0 215-64 0-4198
F 215-640-1134
Southland Transit has been prequalified by Westchest er Fire Insuranc e Company who will provide consideration for the City of El Monte Transit I Dial­ Ride Operations project up to $150 ,000. Consideration for higher limits will be underwritten on a case by case basis. Westchest er Fire Insurance Company is an A++ rated surety through AM Best and is listed in the Federal Register.

AB you are well aware, formal approval of any and all bonds would also be conditioned upon applicable underwriting considerations such as acceptable contract terms , review of bond forms and a favorable review and compliance with current underwriting information and requirements at the time of the requests for bonds .

This letter of recommendation is not a bid or performance bond nor assumption of liability. Future bonds will be considered subject to favorable underwriting conditions including mutually acceptable contract terms. Should further information be needed, please feel free to contact me.

Yours very truly,

TCHESTER FIRE INSURANCE COMPANY
ce F. McMahon, Attorney-In-Fact

PRIVACY NOTICE
This message is intended only for the use of the individual or entity to which this is addressed and may contain information that is privileged , confidenlial, or exempt from disclosure under applic able Federal or State Law. If the render of this message is not the intended recipient or the employee or agent responsib le for delivering the message to the intended recipient, you are hereby notified that any dfasemination, distribution, or reproduction of this communication is prohibit ed.

ACKNOWLEDGMENT
A notary public or other officer completing this
certificate verifies only the identity of the individual who signed the document to which this certificate is
attached , and not the truthfulness , accuracy, or
validity of that document.

State of California
County of San Diego
on December 9, 2021 before me, Minna Huovila, Notary Public (insert name and title of the officer)
personally appeared Lawrence F. McMahon
who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies) , and that by his/her/their signature(s) on the instrument the person(s) , or the entity upon behalf of which the person(s) acted , executed the instrument.

I certify under PENAL TY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

WITNESS my hand and official seal.

Signature(~)
..• . , I
(Seal)
ra-·· ~~~~. ~~~~~ 0 U NOTARY PUBLIC·CALIFORNIA Cl>
en .. SAN DIEGO COUNl'< !:z o , . My c ommission Expires I I DECEMBER .s. 2023 • ·- CH LI E3 s ·
Power of Attorn ey
Federal Insuranc e Company I Vigilant Insurance Company I Pacific Indemnity Company Westchester Fire Insurance Company I ACE American Insurance Company Know All by Thes e Presents, d1at FEDERAL INSURANCE COMPANY. an Indiana corpo ration, VIGILANT INSURANCE COMPANY, a New York corporatio n. PACIFIC INDEMNITY COMPANY, a Wisconsin corporatio n, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY corporatio ns of the Commonwealth of Pennsylva nia, do each hereby constitute and ap point Teresa Sc h o lle o f Sacramen to, Ca lifo rni a ; Ta ra Bacon, Dale Ha rs h a w , Minn a Hu ovila, La wre nce F. McMa ho n, John R. Qua lin and Geoff rey Sh e lton of San Diego , Californ ia--- ------- --------------- -------- --- each as th eir tr ue and lawful Attorney-in-Pact to execute under such designation In their names and to affix the ir corporate sea ls to and delive r for and on their behalf as surety thereon or otherw1se, bonds and undertak iogs and o ther writi ngs obligatory In the natu re thereof (other than ball bonds) given or executed In the course of business, and any Instruments amend ing or altering the same, and consents to the modification or alte ration of any Instru ment referred to in said bonds or obligations.

In Witn ess Wh ereof, said FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMNITY COMPANY, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY have each executed and attesced these presents and affixed th eir corpora te seals on this 9lh day of November 2020.

D~1v:n \l. Ch Ion,,;. ,\:;;.-;Js1an1 Stuc1~11)'

STATE OF NEW JERSEY
County of Hunter don SS.

Step hm \J ll ~llK)'. \"il:c Pn.':'ldl'lll
On th is 9th day of Nove mber , 2020 before me, a Notary Public of New jersey, perso nally came Dawn M. Chloros and Stephen M. Haney, to me known to be Assistant Secreta ry and Vice President, respectively, ofF EDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMNITY COMPANY, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY, the compau lesw hlch executed the foregoing Power of Atto rney. and the said Dawn M. Chloros and Stephen M. Haney, being by me duly sworn, severally and each for herself and himself did depose and say tl1at they are Assistant Secretary and Vice Preside nt. respect ively, of PEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMNITY COMPANY. WESTCHESTER PIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY and know the corporate seals thereof, that the seals affixed to Lhe foregoing Power of Atto rney are s uch corpor ate sea ls and we re th ereto affixed by authority of sa id Companies; and that their signatu res as such officers were duly affLXed and s ubscribed by like autho rity.

Notarial Seal KATHE RINE .J. ADE LAAR
NOTARY PUBLIC OF N EW .JE RSEY
NO. 2 3 16665
Commission Expires .July 16, 2024

CERT IFICAT ION
Resolutions adopted by the Boards of Directors of FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, and PACIPIC INDEMNITY COMPANY on August 30, 2016; WESTCHESTl':R FIRE INSURANCE COMPANY on December 11, 2006; and ACE AMERICAN INSURANCE COMPANY on March 20, 2009:
•RESOLVED, that the rollowlng authorizations relate lO the cxccutlon. for and on behalr of the Company, of bonds, undertakings, recog nlzances, contracts and other wMtten commitments of the Company entered into in the ordinary course of business (each a 'Written Commitment"'):
(1) Each of the Chairman, the President and the Vice Presidents of the Company Is h•reby authorized to executo any Written Commitment for and on behalf of the Company, under the seal of the Company or otherwise.
(2) Each duly appointed attorney-in-fact of the Company is hereby authorized to execute any Written C:ommllment for and on behalf of the Company. under tho seal of the Company or otherwise, to the extent that such actton ls authorized by the grant of powers provided for1n such person's written appointment as such attorney-in-facL (3) Each of the Chairman, tbe President and the Vice Presidents of the Company ls hereby authorized, for and on behalf of the Company. to appoint In writing any person the attorney-in­ fact of the Company with full power and authority to execute, for and on behalfof the Company, under the seal of [he Company or otherwise, such Wriuen Commi tmen L~ of the Company as may be specified In such written appointment, which specification may be by general type or class of Written Commitments or by speciOcatlon of one or more partJcular Written Commitments.
( 4) Each of the Cholrman, the President and the Vice Presidents of the Company Is hereby authorized, for and on behalf of the Company, lo delegate in writing to any other officer of the Company the authority to execull!, for and on behalf of the Company, under the Company's seal or oth•rwlse, such Written Commitments of the Company as arespec!Oed In such written delegation, which speciflcaUon may be by general type or class of Written Commitments or by specification of one or more ~rtlcu l ar Written Commitments. (S) The slgnaLure of any officer or other person executing any Written Commitment or appointment or delegation pursuant to this Resolution. and the <eol of tho Company, may be affixed by facstmlle on suc.h Written Commtnnent or w ritten a ppointtnent or delegation. l' URTHER RESOLVED, that the foregoing Resolution shall not be deemed to be an exclusive statement of the powers and authority of officers, employees and other persons to act for and on behalf of the Company. and such Resolution shall not limit or otherwise affect lhc exercise of any such power or authority otherwtse validly granted or vested." 1, Daw n M. Chloros, Assls tan c sec reta ry of FEDERAL INSURANCE COMPANY, VIGILANT INSURANCE COMPANY, PACIFIC INDEMNITY COMPANY, WESTCHESTER FIRE INSURANCE COMPANY and ACE AMERICAN INSURANCE COMPANY (the "Companies'1 do hereby certify that (i) the foregoing Resolutions adopted by the Board of Directors of the Companies are true, cor rect and in full force and effect. (II) the foregoing Power of Attorney is true, correct and In full force and effect Given unde r my hand and seals of sa id Companies at Whitehouse Statio n. NJ. this December 9, 2021.

IN THE EVENT YOU WISH TO VERIFY TlfE AUTHENTICITY OF THIS BONO OR NOT tFY us OF ANY on rnn MA'ITEI\, Pl.EASE CONTACT us AT:

Tele hone 908 903· 3493 Fax 908 903 -3656 e-mo!I: sure @lchubb.com Comb111ed: FEO-VIG-Pl-Vlo'FlC-AAIC (rev. 11-19)
CHUBB .

SURETY BOND DIGITAL SIGNATURE AND CORPORATE SEAL

NOTICE AND ADDENDUM
WESTCHESTER FIRE INSURANCE COMP ANY ("WESTCHESTER FIRE") has authorized its respective Attorneys-in-Fact to affix WESTCHESTER FIRE'S corporate seal to any surety bond executed on behalf of WESTCHESTER FIRE by any such Attorney-in-Fact by attaching this Notice and Addendum to said bond.

To the extent this Notice and Addendum is attached to a surety bond that is executed on behalf of WESTCHESTER FIRE by its Attorney-in-Fact, WESTCHESTER FIRE hereby agrees that the corporate seal below for WESTCHESTER FIRE shall be deemed affixed to said bond to ,the same extent as if its raised corporate seal was physically affixed to the face of the bond. WESTCHESTER FIRE hereby further agrees that the execution of said bond on behalf of WESTCHESTER FIRE by its Attorney-in-Fact with said Attorney-in-Fact's digital signature shall be considered acceptable to the same extent as if the Attorney-in-Fact executed the bond with their original, wet ink signature.

Dated this 25th day of August, 2020.

WESTCHESTER FIRE INSURANCE COMPANY
A__.J_.. Iv\. d
By:_1° __ J\4---___ ---=-ttr-v-=---------
Stephen M. Haney, Vice President

CITY OF EL MONTE
Request for Proposals
APPENDIX A, 49 CFR PART 20-CERTIFICATION REGARDING LOBBYING Certification for Contracts, Grants, Loans, and Cooperative Agreements FORMS
The undersigned [Contractor] certifies, to the best of his or her knowledge and belief, that:
(1) No Federal appropriated funds have been paid or will be paid, by or on behalf of the undersigned, to any person for influencing or attempting to influence an officer or employee of an agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement. (2) If any funds other than Federal appropriated funds have been paid or will be paid to any person for making lobbying contracts to an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with this Federal contract, grant, loan, or cooperative agreement, the undersigned shall complete and submit Standard Form-LLL, "Disclosure Form to Report Lobbying," in accordance with its instructions [as amended by "Government wide Guidance for New Restrictions on Lobbying," 61 Fed. Reg. 1413 91/19/96). Note: Language in paragraph (2) herein has been modified in accordance with Section 10 of the Lobbying Disclosure Act of 1995 (P.L. 104-65, to be codified at 2 U.S.C. 1601, et seq.)]
(3) The undersigned shall require that the language of this certification be included in the award documents for all subawards at all tiers (including subcontracts, subgrants, and contracts under grants, loans, and cooperative agreements) and that all subrecipients shall certify and disclose accordingly.

This is certification is a material representation of fact upon which reliance was placed when this transaction was made or entered into. Submission of this certification is a prerequisite for making or entering into this transaction imposed by 31, U.S.C. §1352 (as amended by the Lobbying Disclosure Act of 1995). Any person who fails to file that required certification shall be subject to a civil penalty of not less than $100,000 for each such failure. [Note: Pursuant to 31 U.S.C. §1352(c)(l)-(2)(A), any person who makes a prohibited expenditure or fails to file or amend a required certification or disclosure form shall be subject to a civil penalty of not less than $10,000 or not more than $100,000 for each such expenditure or failure.]
1of2
FORMS
Southland Transit, Inc.

The Contractor, certifies or affirms the truthfulness and accuracy of each statement of its certification and disclosure, if any. In addition, the Contractor understands and agrees that the provisions of 31 U.S.C. A 3801, et seq., apply to this certification and disclosure, if any.
12/10/21
2 of 2

CITY OF EL MONTE

CITY HALL
11333 VALLEY BOULEVARD
EL MONTE, CALIFORNIA 90201

FALSE CLAIMS/

FALSE CLAIMS ACT CERTIFICATION
(TRANSIT & PARATRANSIT OPERATIONS RFP)
FORM6
Proposer shall provide either the certification requested below or the information requested on the next page. Failure to certify or provide the requested information may result in a determination that the Proposer is non-responsive and City may reject the proposal on this basis. Failure to fully and accurately provide the requested certification or information may result in a determination that the Proposer is not responsible and City may reject the proposal on this basis as well. "False Claims Act", as used herein, is defined as either or both the Federal False Claims Act, 31 U.S.C. Sections 3729 et seq., and the California False Claims Act, Government Code Sections 12650 et seq.

FALSE CLAIMS ACT CERTIFICATION
If the Proposer has no False Claims Act violations as described above, complete the following:

I, Timmy Mardirossian amthe ___ P_r_e_si_d_en_t ______________ _ (Print name of person responsible for submitting proposal) (Title with proposing entity) 0 ~ ___ s_ou_t_h_la_n_d __ T_r_an_s_it_,_I_n_c. ________________________ ~(hereinafteG "Proposer"). (Print name of Proposing Entity)
In submitting a proposal to the City of El Monte, I, hereby certify that neither Proposer nor any person who is an officer of, in a managing position with, or has an ownership interest in Proposer has been determined by a court or tribunal of competent jurisdiction to have violated the False Claims Act as defined above.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this 10th day of Dec, 2021 at ___ E_l_M_o_n_te_,_C_A _______ _ (city and state)
half of Proposer)
City of El Monte
False Claims/False Claims Act Certification

FALSE CLAIMS ACT VIOLATIONS INFORMATION
(1) Date of Determination of Violation:
(2) Identity of tribunal or court and case name or number, if any:
(3) Government Contract or project involved:
(4) Government agency involved:
(5) Amount of fine imposed:
(6) Exculpatory Information:

DECLARATION
I, the ______________ ~
(Print name of person responsible for submitting proposal) (Title with proposing entity) of, (hereinafter, "Proposer")
(Print name of Proposing Entity)
declare under penalty of perjury that the above information is true and correct.

Executed this ___ day of _____ at-----------------
(month and year) (city and state)
(Signature of Person Responsible for Submitting Proposal on behalf of Proposer)

END OF DOCUMENT

CITY OF EL MONTE

CITY HALL
11333 VALLEY BOULEVARD
EL MONTE, CALIFORNIA 91731

CIVIL LITIGATION HISTORY/

CIVIL LITIGATION CERTIFICATION
(TRANSIT and PARATRANSIT OPERATIONS SERVICES RFP)
FORM7
Proposer shall provide either the certification requested below or information requested on the next page. Failure to provide such certification or information may result in a determination that the Proposer is nonresponsive. Failure to fully and accurately provide the requested certification or information may result in a determination that the Proposer is not responsible. For the five (5) years preceding the date of submittal of this Proposal, identify any civil litigation arising out of the performance of a procurement contract within the State of California in which any of the following was a named plaintiff or defendant in a lawsuit brought by or against the entity soliciting Proposals: the Proposer submitting the instant Proposal, including any person who is an officer of, or in a managing position with, or has an ownership interest in the entity submitting the Proposal. Do not include litigation which is limited solely to enforcement of mechanics' liens or stop notices. Provide on the following page labeled "Civil Litigation History Information:" (i) the name and court case identification number of each case, (ii) the jurisdiction in which it was filed, and (iii) the outcome of the litigation, e.g., whether the case is pending, a judgment was entered, a settlement was reached, or the case was dismissed.

CIVIL LITIGATION CERTIFICATION
If the Proposer has no civil litigation history to report as described above, complete the following:
(Print name of person responsible for submitting proposal) (Title with proposing entity) of,-------------------- (hereinafter, "Proposer")
(Print name of Proposing Entity)
In submitting a Proposal to the City of El Monte for Transit and Paratransit Operations Services, I, hereby certify that neither Proposer nor any person who is an officer of, in a managing position with, or has an ownership interest in Proposer has been involved in civil litigation as described, above.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this ___ day of _____ at _______________ _
(month and year) (city and state)
by ______________________________ _
(Signature of Person Responsible for Submitting Proposal on behalf of Proposer)

CIVIL LITIGATION HISTORY INFORMATION
Proposer is uncertain of what is meant to be included in "civil litigation arising out of the performance of a procurement contract" and interprets this as asking if the Proposer has ever been involved in a civil action arising from the non-performance, inadequate performance, default or breach of a procurement contract. Proposer has not been involved in any litigation of this type in the last five years.

As Proposer is a transportation provider, Proposer has been a party in numerous civil litigation personal injury cases over the last five years arising from motor vehicle accidents which have been handled by Proposer's insurance carriers. Proposer assumes these type civil litigation cases are not what is being inquired about and need not be listed in this civil litigation history as they would be voluminous.

If the City of El Monte wishes an itemization of these cases please advise and it will be provided.

Proposer is also occasionally named as a party in employment related lawsuits brought by an employee who may be assigned to a procurement contract. Proposer again assumes these type civil litigation cases are not what is being inquired about and need not be listed in this civil litigation history. If the City of El Monte wishes an itemization of these cases please advise and it will be provided .

DECLARATION
I, Timmy Mardirossian the President
-------------------(Print name of person responsible for submitting Proposal) (Title with Proposing Entity) of,_S_o_u_th_l_a_n_d_T_ra_n_s_i t_, _In_c. ____________ ( herei natter, "Proposer") (Print name of Proposing Entity)
declare under penalty of perjury that the above information is true and correct.

Executed this 10th day of Dec, 2021 at ____ E_l _M_o_n_t_e_, C_A _______ _ (month and year) (city and state)
ubmitting Proposal on behalf of Proposer)

END OF DOCUMENT
City of El Monte
Transit and Paratransit Operations
RFP

Form 8

STATE OF CALIFORNIA DRUG FREE WORKPLACE CERTIFICATION
Company/Organization Name: __ S_o_u_th_la_n_d_T_ra_n_s_i_t,_I_n_c_. ___________ ("Proposer") The Proposer named above hereby certifies compliance with U.S. DOT regulations 49 CFR Part 29, Subpart F and Government Code Section 8355 in matters relating to providing a drug-free workplace. The above named Proposer or grant recipient will:

1. Publish a statement notifying employees that unlawful manufacture, distribution, dispensation, possession, or use of a controlled substance is prohibited and specifying actions to be taken against employees for violations of the prohibition.

2. Establish an on-going Drug-Free Awareness Program as required to inform employees about all the following:
(a) The dangers of drug abuse in the workplace,
(b) The person's or organization's policy of maintaining a drug-free workplace, (c) Any available drug counseling, rehabilitation, and employee assistance Programs,
( d) Penalties that may be imposed upon employees for drug abuse violations occurring in the workplace.

3. Every employee who works on the proposed contract or grant will receive a copy of the company's drug-free policy statement.

4. Notify each employee that as a condition of employment financed with Federal assistance provided in the proposed contract, the employee will be required to:
(a) Abide by the terms of the company's policy statement, and (b) Notify the employer (Proposer) in writing of any conviction for a violation of a criminal drug statute occurring in the workplace no later than five (5) calendar days after that conviction.

5. Notify FTA in writing, within in ten (10) calendar days after receiving notice required by paragraph 4 (b) from an employee or otherwise receiving actual notice of that conviction. The Proposer, as employer of any convicted employee, must provide notice, including position title, to every project officer or other designee on whose project activity the convicted employee was working. Notice shall include the identification number(s) of each affected vehicle and related equipment and accessories.

6. Taking one of the following actions within thirty (30) calendar days of receiving notice under paragraph 4 (b) with respect to any employee who is convicted:
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(a) Taking appropriate personnel action against that employee, up to an including termination, consistent with the requirements of the Rehabilitation Act of 1973, as amended, or (b) Requiring the employee to participate satisfactorily in a drug abuse assistance or rehabilitation program approved for such purposes by a Federal, State, or local health, law enforcement, or other appropriate agency; and
(c) Making a good faith effort to continue to maintain a drug-free workplace through implementation of Paragraph 1,2,3,4,5, and 6 of this certification. The Proposer agrees to maintain a list identifying its headquarters location and each workplace it maintains in which activities provided by this contract are conducted and make that list readily accessible to the State Department of Transportation.

CERTIFICATION
I, the official named below, hereby swear that I am duly authorized legally to bind the Proposer or grant recipient to the above-described certification. I am fully aware that this certification executed on the date and in the city below, is made under penalty of perjury under the laws of the State of California.

Executed on 12/10/21 at El Monte ------------ , California Date City
Print Name: Timmy Mardirossian
Title: __ P_r_e_si_d_e_n_t _________ _
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FORM9

CERTIFICATION OF PRIMARY PARTICIPANT REGARDING

DEBARMENT, SUSPENSION, AND OTHER RESPONSIBILITY MATTERS The Primary Participant (applicant for an FTA grant or cooperative agreement, or potential contractor for a third party contract), Southland Transit, Inc. certifies to the best of its knowledge and belief that it and its principles:

1. Are not presently debarred, suspended, proposed for debarment, declared ineligible or voluntarily excluded from covered transactions by an Federal debarment or agency.

2. Have not within a three year period preceding this proposal been convicted of or had a civil judgment rendered against them for commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or performing a public (Federal, State or Local) transaction or contract under a public transaction; violation of Federal or State antitrust statues or commission of embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, or receiving stolen property;

3. Are not presently indicated for or otherwise criminally or civilly charged by a governmental entity (Federal, State or Local) with commission of any of the offenses enumerated in paragraph (2) of this certification; and

4. Have not within a three-year period preceding this application/proposal had one or more public transactions (Federal, State or Local) terminated for default. (If the primary participant (applicant for and FT A grant, or cooperative agreement, or potential third party contractor) is unable to certify to any of the statements in this certification, the participant shall attach an explanation to this certification.)

THE PRIMARY PARTICIPANT (APPLICANT FOR AN FTA GRANT OR

COOPERATIVE AGREEMENT, OR POTENTIAL CONTRACTOR FOR A MAJOR THIRD PARTY CONTRACT), Southland Transit, Inc. , CERTIFIES OR

AFFIRMS THE TRUTHFULNESS AND ACCURACY OF THE CONTENTS OR THE

STATEMENTS SUBMITTED ON OR WITH THIS CERTIFICATION AND
UNDERSTANDS THAT THE PROVISIONS OF 31 U.S.C. SECTION 3801 ET SEQ. ARE APPLICABLE THERETO.

Title of Authorized Official Timmy Mardirossian, President 38 FORM 10

CITY OF EL MONTE

CITY HALL
11333 VALLEY BOULEVARD
EL MONTE, CALIFORNIA 91731

COMMUNICATIONS WITH CITY COUNCIL, ADVISORY COMMITTEE AND CITY STAFF

DISCLOSURE OF CONTACTS WITH COUNCILMEMBERS
(TRANSIT AND PARATRANSIT OPERATIONS RFP)

1. Fallowing the deadline for submission of proposals and continuing until the City Council awards the last contract, if any: (i) El Monte City Council members, members of the City's executive management team and staff members will not hold any discussions or any meetings, conferences or other like gatherings with any Proposer, except as this RFP allows or otherwise contemplates; and (ii) a Proposer must not communicate, in any manner, with the individuals identified in romanette, above, except as contemplated under the terms of the RFP. Proposers may write to the City Council as a whole after staff recommendations are made public by staff in anticipation of a public meeting.

2. From the date the RFP is issued to the date on which the City awards the last contract, if any, a Proposer must not directly or indirectly give, furnish, donate, or promise any money, compensation, gift, gratuity, or anything of value to the individuals listed under romanette (i) of paragraph 1, above, for the purpose of, or which has the effect of
• Securing or establishing an advantage over other Proposers; • Securing or recommending the selection of the Proposer's Proposal; or • Securing or recommending the Contract's award to the Proposer. • Violations of Paragraphs 1 or Paragraph 2 or both, will constitute grounds for rejection.

3. Proposer shall provide either the certification requested below or information requested on the next page. Failure to provide such certification or information may result in a determination that the Proposer is nonresponsive. Failure to fully and accurately provide the requested certification or information may result in a determination that the Proposer is not responsible and City may reject the proposal on this basis as well. During the one-year period immediately preceding the date of the deadline for submitting proposals, list the date of all meetings or other communications the following persons have had with any one or more members of the El Monte City Council or any City employee regarding the provision of transit and paratransit operations the City of El Monte: the Proposer submitting the instant Proposal, including any person who is an officer of, or in a managing position with, or has an ownership interest in the entity submitting the Proposal. Please also identify the name(s) of the City Council members or City employees with whom such persons have met with or communicated with regarding the provision of transit and paratransit operations services to the City of El Monte.

City of El Monte
Transit and Paratransit Operations RFP

HISTORY OF MEETINGS OR COMMUNICATIONS WITH EL MONTE CITY COUNCIL MEMBERS AND/OR

CITY EMPLOYEES REGARDING THE PROVISION OF TRANSIT AND PARATRANSIT OPERATIONS

SERVICES TO THE CITY OF EL MONTE DURING THE ONE-YEAR PERIOD IMMEDIATELY PRECEDING

THE SUBMISSION OF THIS PROPOSAL
List the date of all such meetings or communications, the City Council member or City employee with whom you met with (attach extra pages if necessary)

DECLARATION
I, ,the _____________________ ~
(Print name of person responsible for submitting Proposal) (Title with Proposing Entity) of (hereinafter, "Proposer")
(Print Name of Proposing Entity)
declare under penalty of perjury that the above information is true and correct.

Executed this ____ day of ______ at ______________________ _ (month and year) (city and state)
by _______________________________________ ~
(Signature of Person Responsible for Submitting Proposal on behalfof Proposer)

END OF DOCUMENT
City of El Monte
Transit and Paratransit Operations RFP

CERTIFICATION REGARDING MEETINGS OR COMMUNICATIONS WITH CITY OFFICIALS OR

EMPLOYEES
If the Proposer has had not had any meetings or other communications with the persons mentioned above regarding the provision of transit and para transit operations to the City of El Monte with the one-year period immediately preceding the submission of this Proposal, complete the following:

I, _T_im_m_y'---M_ar_d_i_r_o_ss_i_a_n ________ , am the President (Print name of person responsible for submitting Proposal) of Southland Transit, Inc.
(Print Name of Proposing Entity)
(Title with Proposing Entity)
(here in after, "Proposer").

In submitting a Proposal to the City of El Monte for Transit and Paratransit Operations Services, I, hereby certify that neither Proposer nor any person who is an officer of, in a managing position with, or has an ownership interest in Proposer has met with or communicated with any member of the El Monte City Council or any City employee regarding the provision of the transit and paratransit operations for the City of El Monte during the one-year period immediately preceding the submission of this Proposal to the City of El Monte.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this 10th day of December 202 lat __ E_l_M_o_n_te_, _C_A ___________ _ (month and year) (city and state)
oposal on behalf of Proposer)
City of El Monte
Transit and Paratransit Operations RFP

FORMB

LOCAL AGENCY PROPOSER RC-DBE COMMITMENT
This form must be submitted with the proposal.

Local Agency City of El Monte Location _E_l_M_o_n_t_e ____ _ Project Description _F=ix;..;.e;;...;d;,.;.._;;;,,R::-"o;_;;uc;...;t;...;;;.e_;;a=n.;;_;d;;.;......;;;;.P....;;.a=r=a=tr;;._;:;a=n=s;..;;;.i t.;;....::;_S.;:;..;erv;;...;;;._;:;i;..;;;.c..;;;;..es;;;......;;;C;;...;o;;._;:;n""'t=r=a..;;;;..ct..;;...._-..:::2;..:;0..:::2=2'------- Proposal Date _D_e_c_e_m_b_er_l_4..:...., _2_0_2_1 ___________________ _ Proposer's Name _.::;;S-=o-=u~t=h=la=n=d~T=-.,r~a~n=s=i:...:;.t'--'I=n=c=.'-------------------- Contract RC-DBE Goal(%) ___ 9._0_%_· ---=2=-•:::....:0::;....0-'-Y."""'o _____________________ _ Work Item
Number
Description or Services
to be Subcont racted
(or contracted if the
Proposer is a RC-DBE)
I
DBE
Certificate
Number and
Expiration Date
I Name of Each RC-DBE I
(must be certified prior to submissi on-
! .. .

I of ~::':~~~~E
I
Percent
include
RC-DBE address
and ohone number)
______ .l___ i Vehicle Cleaning_ _________ L_ 39250 I Trans-Global Services 3.51 % ______ 2 ___ 1!l.BJfQ!!!!_~gQ£!y__ ____ l_ _ _ill1L _ .. I ICM ~.Assoc~l~§. _________ l_ .12. ~ __ .. ______ _j____________________ i ......... --.. --·--·-----·----L-----.. ·------·--------·--- -L __________ _ l
------·-----;--------------- -+-·-·-- ---- .. --+----------------- ~------- -·----------+--------·-·-· -----------.--------·---+--------- -------·- - ---- -.------- -ii --·-----.. ·----- ----~---.. ----·--·--·--·---·----·-·--·-.. -·-· ·---t ............ ----·-·---·----·-·---J ..... ..... _ .. _ .. _____ ... _ .. _______ .. ____ .. _____ L-·-· ··-- ---·-·

FOR AGENCY TO COMPLETE
Agency Proposal Number ______________ _
Federal-Aid Project Number --------------­
Federal Share --------------­
Proposal Date ---------------
Agency certifies that the DBE certifications have been verified and all information is complete and accurate/unless noted otherwise .

Total Claimed RC-DBE Commitment: 3.6 %
Signature of Proposer -------=::::::: ~
12/14/21 (626 )258 -1310
Signature of Agency Representative Date Date Phone Number Jason Snow, VP/COO
Agency Representative (please print or type) Person to Contact (please print or type) ( )
Phone Number
Distribution : (1) Original - Agenc y files Local Agencv Proposer RC-DB E Commitm ent (Consultant Contracts) - Rev 06211 3 14 DBE AFFIRMATION
TO BE COMPLETED BY PRIME AND ALL SUBCONTRACTORS THAT WILL SUBCONTRACT TO A DBE BUSINESS.

Prime and subcontractor(s) at any tier level that will subcontract work to a DBE business are required to complete this form to affirm that it will utilize the DBE businesses listed on Form 1 or Form 4. This form must be signed by the DBE business acknowledging that it has submitted a written quote to the respective Prime or Subcontractor, and has been listed to perform work on this contract.

1. IFB/RFP/RFIQ Number: City of El Monte
~--~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

2. Project Name: Transit and Paratransit/Dial-A-Ride Operations - 2022

3. Prime Name: Southland Transit, Inc.

4. Prime Business Address : 3650 Rockwell Ave El Monte CA 91731 ~~~~~~~~~ ~~~~~~
(Street) (City) (State) (Zip)

5. NameofProposedDBEBu~ness:_T_r_a_n_s_-_G_l_o_b_a_l_S_e_N~ic_e_s~, _ln_c_·~~~~~~~~~~~~~~~~~

6. DBE Business Address: 709 N. Hidalgo Avenue Alhambra CA 91801 (Street) (City) (State) (Zip)

7. Financial Description -Total$ Amount listed for this DBE business is:$ 389,768.24(base) + $263,059.32(options) (Amount should match$ Amount listed for this business on Form 1 or Form 4)

8. Technical Description - Identify the scope of work that will be performed by this DBE business. Please provide applicable Northern America Industry Classification System (NAICS) code(s) only.

Description of Work, Service, or Material Supplied DBE NAICS (6 digits) Clean, Disinfect, Fumigate, Detail and Wax 561720, 561740, 562998, 811192 Affirmation:

Signatures of the authorized representatives of this Contractor and of the DBE business below represent the commitment by both parties to enter into a formal subcontract agreement for the work and any terms or conditions described above and in the accompanying attachments , conditioned on the Bidder/Proposer being awarded this Contract.

Southland Transit, Inc.
(Prime ~~
(Aut~.-ne_s_s-)1-~-
(Date) I I
Jason Snow
(Typed or Printed Name of Signee)
VP/COO
(Title of Signee)
[email protected]
(Email)
(626) 258-1310
(Telephone)
Trans-Global SeNices, In
(DBE
(Date) 1
Luisa J Sun
(Typed or Printed Name of Signee)
President
(Title of Signee)
[email protected]
(Email)
(626) 423-4871
(Telephone)

Certifie d Directory
California Unified Certification Program Certified Directory TRANS-GLOBAL SERVICES, INC.

LUISA SUN [email protected] 626-423-4871 626-427-1348 www.trans-globalservices.com 709 N. HILDALGO AVENUE
ALHAMBRA, CA 91801
709 N. HILDALGO AVENUE
ALHAMBRA , CA 91801
Asian-Pacific American Female Caltrans DBE
561720 - Venetian blind cleaning services; 561740 - Carpet and Upholstery Cleaning Services; 562998 - All Other Miscellaneous Waste Management Services ; 811192 - Car washes; C9999 - BROKER (FOR FEE ONLY); 17341 - JANITORIAL SERVICES; 17380 -

MISC BUSINESS SERVICES
39250
TRANS-GLOBAL SERVICES, INC.

LUISA SUN [email protected] 626-423-4871 626-427-1348 www.trans-globalservices.com 709 N. HIDALGO AVENUE
ALHAMBRA , CA 91801
709 N. HIDALGO AVENUE
ALHAMBRA , CA 91801
Maintenance and Upholstery
Asian-Pacific American Female Caltrans DBE
561720 - Janitoria l services ; 561720 - Venetian blind cleaning services; 561740 - Carpet and Upholstery Cleaning Services; 562998 - All Other Miscellaneous Waste Management Services; 811192 - Car washes; C9999 - BROKER (FOR FEE ONLY); 17341 - JANITORIAL SERVICES ; 17380 - MISC BUSINESS SERVICES
Los Angeles 39250

DBE AFFIRMATION
TO BE COMPLETED BY PRIME AND ALL SUBCONTRACTORS THAT WILL SUBCONTRACT TO A DBE BUSINESS.

Prime and subcontractor(s) at any tier level that will subcontract work to a DBE business are required to complete this form to affirm that it will utilize the DBE businesses listed on Form 1 or Form 4. This form must be signed by the DBE business acknowledging that it has submitted a written quote to the respective Prime or Subcontractor , and has been listed to perform work on this contract.

1. IFB/RFP/RFIQ Number : City of El Monte
~--~~~~~~~~~~~~~

2. Project Name : Transit and Paratransit/Dial-A-Ride Oper_a_tio_n_s_-_2_0_2_2 __________ _

3. Prime Name: Southland Transit, Inc.

4. Prime Business Address: 3650 Rockwell Ave El Monte CA 91731 ~~~~~~~- -~~~~--
(Street ) (City ) (State) (Zip)

5. Name of Proposed DBE Business: JCM & Associates, Inc.

6. DBE Business Address: 5443 E. Washington Blvd. Commerce CA 90040 (Street) (City) (State) (Zip)

7. Financial Description - Total$ Amount listed for this DBE business is:$ 12,751.40 (base) + $8,557 . 72 (options) (Amount should match S Amount listed for this business on Form 1 or Form 4)

8. Technical Description - Identify the scope of work that will be performed by this DBE business. Please provide applicable Northern America Industry Classification System (NAICS) code(s) only.

Description of Work, Service, or Material Supplied DBE NAICS (6 digits} 1-----------------------------------------r--~
Su I uniforms 448190 and 315990
...__._,_,.'--------~-------------------------+--~
Affirmation:

Signatures of the authorized representatives of this Contractor and of the DBE business below represent the commitment by both parties to enter into a formal subcontract agreement for the work and any terms or conditions described above and in the accompanying attachments, conditioned on the Bidder/Proposer being awarded this Contract.

Southland Transit, Inc.
(Prim~~-------------
(A~ure of Business) 1 -
{Date) I I ·
Jason Snow
(Typed or Printed Name of Signee)
VP/COO
(Title of Signee)
[email protected]
(Email)
(626) 258-1310
(Telephone)
JCM & Associates, Inc.
(®E. _EBusi~s~~) __ .
\K \ ~'-ye--- -
(Authorized Signature of B~ss)
iZ-\9\;l\
(Date)
Richard Crady
(Typed or Printed Name of Signee)
VP
------~----------------~~---------(Ti tie of Signee)
richard@bluegooseuniforms .com
(Email)
800-543-3732
(Telephone)

Los Angeles County One G2tev1ay Plaza
Metropolitan Transportation Authority Los CA 90012-2952 metro.net u
March 25 t 201 g REISSUED 51112020 NA/CS ADDED: 315990 NAfCS REMOVED: 812331 Jose Cornejo
JCM & Associates, Inc. dba Blue Goose Uniforms
5443 E. Washington Blvd.

Commerce, CA 90040-2105
RE: Disadvantaged Business Enterprise Certification
Dear Mr. Cornejo:

CUCP#32118
Metro File # 70
We are pleased to advise you that after careful review of your application and supporting documentation, the Los Angeles County Metropolitan Transportation Authority (Metro) has determined that your firm meets the eligibility standards to be certified as a Disadvantaged Business Enterprise (DBE) as required under the U.S. Department of Transportation (U.S. DOT) Regulation 49 CFR Part 26, as amended. This certification will be recognized by all of the U.S. DOT recipients in California. Your firm will be listed in the California Unified Certification Program (CUCP) database of certified DBEs under the following specific areas of expertise that you have identified on the NAICS codes form of the application package:

NAICS Description
448190 Other Clothing Stores
315990 Apparel Accessories and Other Apparel Manufacturing Your DBE certification applies only for the above codes. You mayreview your firm's information in the CUCP DBE database which can be accessed at the CUCP's website at www.calfforniaucp.org. Any additions and revisions must be submitted to Metro for review and approval.

In order to ensure your continued DBE status, you are required to submit an annual No Change Declaration Form (which will be sent to you) along with supporting documentation. If no changes are noted, then your DBE status remains current. If there are changes, Metro will review to determine continued DBE eligibility. Please note, your DBE status remains in effect unless Metro notifies you otherwise.

Should any changes occur that could affect your certification status prior to receipt of the No Change Declaration Form, such as changes in your firm's name, business/mailing address, ownership, management or control, or failure to meet the applicable business size standards or personal net worth standard, please notify Metro immediately. Failure to submit forms and/or change of information will be deemed a failure to cooperate under Section 26.109 of the Regulations.

Metro reserves the right to withdraw this certification if at any time it is determined that it was knowingly obtained by false, misleading, or incorrect information. Your DBE certification is subject to review at any time. The firm thereby consents to the examination of its books, records and documents by Metro.

Congratulations, and thank you for your interest in the DBE program. Should you have any questions, please contact us at213-922-2600 Option 1. For information on Metro contracting opportunities, please visit our website at www.metro.net.

Sincerely,
~~·_...,s;-­
Shirley Wong
Principal Certification Officer
Diversity & Economic Opportunity Department
Small Business Certification Unit
One Gateway Plaza, Mail Stop 99·8-4, Los Angeles, CA 90012-2952 Ph: 213-922·26-00 Option 2
From:

Sent:

To:

Subject:

Hinojosa, Megan <[email protected]>
Tuesday, January 5, 2021 10:03 AM
[email protected]
Annual No Change Declaration #70
We have received your Annual No Change Declaration. Your DBE and/or SBE file has been updated and remains active. You will not receive any new certification letters. We will do this again next year.

Best Regards,
Megan Hinojosa
LA Metro
Certification Officer
Diversity & Economic Opportunity Department
213.922.2209
metro.net I facebook.com/losangelesmetro I @metrolosangeles Metro provides excellence in service and support.
1 PROPOSAL FOR THE CITY OF EL MONTE FIXED ROUTE
TRANSIT AND PARATRANSIT OPERATIONS - 2022
SOUTHLAND TRANSIT, INC.

XI. FIRM EXHIBITS
Exhibit 1 – STI Employee Handbook
Exhibit 2 – STI Drug and Alcohol Policy
Exhibit 3 – STI Safety & Training Manual
Exhibit 4 – STI Customer Service Manual
Exhibit 5 – STI Accident/Incident Investigation Procedure Exhibit 6 – STI Safety, Security and Emergency Preparedness Plan (SSEPP) Exhibit 7 – STI Injury, Illness and Preparedness Plan (IIPP) Exhibit 8 – Financial Statement
Exhibit 9 – Sample Rider Survey
Employee Handbook – Rev. May 1, 2015
Southland Transit, Inc.

EMPLOYEE HANDBOOK

- 1 - Employee Handbook – Rev. May 1, 2015
Table of Contents

Section I Introductory Policies Page 2
Section II Starti ng the Employment Relationship Page 4 Section III Discrimination and Harassment Page 6
Section IV Reasonable Accommodation Page 10
Section V Communication & Problem Solving Page 11
Section VI Confidentiality & Conflict of Interest Page 13 Section VII Payroll Practices Page 15
Section VIII Hours of Operation & Work Schedules Page 19 Section IX Personnel Records Page 22
Section X Job Duties and Performance Page 24
Section XI Employee Conduct & Work Rules Page 25
Section XII Safety & Security Page 33
Section XIII Benefits Page 38
Section XIV Leaves of Absence Page 45
Section XV Separation From Employment Page 55
Receipt and Acknowledgement Page 57

- 2 - Employee Handbook – Rev. May 1, 2015

Section I Introductory Policies
A. Welcome Statement
WELCOME! It is our pleasure to welcome you to Southland Transit, Inc. (“STI” or the "Company"). STI is not just a company; it is a team of dedicated individuals all focused on providing the best community transit services. Many different skills and disciplines are required to achieve success, and the Company is committed to providing a safe and enjoyable working environment for its employees. People working together must have common goals and a spirit of cooperation. O ur principal goal is to be the best at what we do.

We want to help make your employment with the Company as enjoyable and rewarding as possible. In any organization, it is necessary to know what the Company does for you. You will find that this Employee Handbook explains what you may expect from the Company, as well as what will be expected from you. Therefore, it is important that you become familiar with the contents of the Employee Handbook.

With that said, again, welcome to the Company!
B. Introduction
This Employee Handbook contains information about STI’s employment policies and practices. We expect each employee to read this Employee Handbook carefully as it is a valuable reference for understanding your job and the Company. During your initial orientation, you will be given an opportunity to sit down and carefully review the Employee Handbook. This Employee Handbook supersedes all previously issued Employee Handbooks and inconsistent verbal or written policy statements.

Except for the policy of at-will employment, which can only be changed by the President in writing, and such other policies as may be required by law, the Company reserves the right to revise, delete, and add to the provisions or policies described in this Employee Handbook at any time, as it deems necessary or appropriate in its discretion. All such revisions, deletions, or additions must be in writing and signed by the President. No oral statements or representations can change the provisions of this Employee Handbook.

The benefits described herein are provided at the sole discretion of the Company and this Employee Handbook is not and should not be interpreted to be an assurance, promise or guarantee of an obligation to continue to provide such benefits. Furthermore, this Employee Handbook is not a substitute for the terms of any benefit plan. If there is at any time a conflict between this Handbook and the terms of such a benefit plan (which you are expected to read carefully), the terms of the benefit plan and not this Handbook will control.

None of the Company's personnel documents or benefit plans constitute, or are intended to constitute, an express or implied contract guaranteeing employment or continued employment for any employee. IN ADDITION, THIS HANDBOOK IS

NOT INTENDED

TO AND DOES NOT CONSTITUTE AN EMPLOYMENT CONTRACT FOR A SPECIFIED PERIOD OF TIME OR FOR TERMINATION ONLY FOR CAUSE.

- 3 - Employee Handbook – Rev. May 1, 2015

No supervisor has any authority to enter into a contract of employment --express or implied--that changes or alters the at -will employment relationship. No part of this Employee Handbook may be reproduced in any form or by any electronic or mechanical means without written permission.

Not all of the Company’s policies and procedures are set forth in this Employee Handbook. We have summarized only some of them. If you have any questions or concerns about this Employee Handbook or any other policy or procedure, please ask your manager. If you lose your handbook or if it becomes damaged in any way, please notify Human Resources as soon as possible to obtain a replacement copy.

C. At-Will Employment
Employment at the Company may be terminated for any reason or no reason, with or without cause or notice, at any time by the employee or the Company. Nothing in this Employee Handbook or in any oral or written statement shall limit the right to terminate employment at will. No supervisor or employee of the Company shall have any authority to enter into an employment agreement --express or implied-- with any employee providing for employment other than at-will.

This policy of at -will employment is the sole and entire agreement between you and the Company as to the duration of employment and the circumstances under which employment may be terminated.

With the exception of employment at will, all other terms and conditions of employment with the Company may be modified at the sole discretion of the Company with or without cause or notice at any time. No implied contract concerning any employment -related decision or term or condition of employment can be established by any other statement, conduct, policy, or practice. Examples of the types of terms and conditions of employment that are within the sole discretion of the Company include, but are not limited to, the following: promotion; demotion; t ransfers; hiring decisions; compensation; benefits; qualifications; discipline; layoff or recall; termination; rules; hours and schedules; work assignments; job duties and responsibilities; production standards; subcontracting; reduction, cessation, or expansion of operations; sale, relocation, merger, or consolidation of operations; determinations concerning the use of equipment, methods, or facilities; or any other terms and conditions that the Company may determine to be necessary for the safe, efficient, and economic operation of its business.

These provisions supersede all existing policies and practices and may not be amended or added to without the express written approval of the President.

- 4 - Employee Handbook – Rev. May 1, 2015
Starting the
Section II Employment Relationship
A. Employment Applications
The Company relies on the accuracy of information contained in the employment application, which must be completed by all prospective employees, as well as the accuracy of other data and information presented and gathered during the employment process. Any misrepresentation, falsification or material omission may result in the Company's exclusion of the applicant from further consideration for employment, or, if the person has been hired, termination of employment.

B. Background Checks
The Company recognizes the importance of maintaining a safe workplace with employees who are honest, trustworthy, qualified, reliable, and nonviolent, and do not present a risk of serious harm to their coworkers or others. Therefore, the Company reserves the right to investigate an individual's prior employment history, personal references, and educational background, as well as other relevant information that is reasonably available to the Company.

C. Immigration Law Compliance
The Company is committed to full compliance with federal immigration laws. Therefore, as a condition of employment, the Company is required to verify the identity and legal authority to work of all persons working for the Company. Each new employee must complete the Employment Eligibility Verification Form I -9 and present documentation establishing identity and employment eligibility. Support documentation submitted as proof of eligibility of employment in the United States must be presented within the first three (3) days of employment. We are an E-Verify employer and follow all the rules and guidelines established by the Department of Homeland Security when verifying eligibility for employment.

If an employee has provided right to work documentation that has an expiration date, updated documentation must be given to the Company before this expiration date. Per E-Verify guidelines, the company does not accept expired documentation at time of hire.

All offers of hire and continued employment are conditioned on furnishing satisfactory evidence of identity and legal authority to work in the United States.

D. Physical Examinations
An applicant for employment may be required to take a job -related, pre- employment physical examination after receiving an offer of employment and before beginning his or her first day of work. The pre- employment physical examination includes a drug and alcohol screening. Every offer of employment is contingent on the applicant's successful completion of the physical examination.

The pre-employment physical is provided by the Company at no cost to the applicant.

- 5 - Employee Handbook – Rev. May 1, 2015
E. Reference Checks
To ensure that individuals joining the Company are well qualified and have the potential to be productive and successful, the Company reserves the right to check the employment references of applicants. Offers of employment are contingent on the appropriate completion of a reference check.

No references will be given concerning any present or past employee of the Company unless the Company has received a written request and a written release for such a reference. Only Human Resources may respond to a request for a reference.

Generally, such response will only confirm the dates of employment and position held.

All calls regarding current or former employees must be forwarded to Human Resources.

No one other than Human Resources is authorized to disclose any information about current or former employees, including but not limited to compensation rate and other aspects of employment.

- 6 - Employee Handbook – Rev. May 1, 2015
Discrimination
Section III And Harassment
A. Equal Employment Opportunity
The Company is an equal employment opportunity employer and strives to comply with all applicable laws prohibiting discrimination based on race, color, religion, sex, age, national origin, ancestry, citizenship status, physical or mental disability, veteran or military status, marital sta tus, medical condition, pregnancy, gender (including gender identity and gender expression) , sexual orientation, genetic characteristics or genetic information, as well as any other category protected by federal, state, or local laws. All such discrimination is unlawful and all persons involved in the operations of the Company are prohibited from engaging in this type of conduct. Equal employment opportunity will be extended to all persons in all aspects of the employer -employee relationship, including recruitment, hiring, upgrading, training, promotion, transfer, compensation, benefits, leaves of absence, discipline, layoff, recall, termination and other terms and conditions of employment.

In accordance with applicable federal and state law protecting qualified individuals with known disabilities, t he Company will attempt to reasonably accommodate those individuals unless doing so would create an undue hardship on the Company. Any qualified applicant or employee with a disability who requires an accommodation in order to apply for a job at the Company or perform the essential functions of the job should contact Human Resources and request an accommodation. The Company will engage in an interactive dialogue with the employee in an effort to determine whether reasonable accommodations can be made that will not result in undue hardship to the Company.

You should report every instance of unlawful discrimination or harassment to your supervisor and/or Human Resources, regardless of whether you or someone else is the subject of the discrimination. Detailed reports--including names, descriptions, and actual events or statements made--will greatly enhance the Company's ability to investigate.

Any documents supporting the allegations should also be submitted. Based on your report, the Company will conduct an investigation. Employees can raise concerns and make reports without fear of reprisal. The Company prohibits any and all retaliation for submitting a report of unlawful discrimination and for cooperating in any investigation.

Any supervisor or employee who retaliates against the accuser or those involved in the investigation will be disciplined, up to and including discharge from employment.

If the investigation determines that prohibited discrimination or other conduct violative of Company policy has occurred, the Company will take disciplinary action, up to and including termination of employment, against those who engaged in the misconduct.

The Company will also evaluate whether other employment practices should be added or modified in order to deter and prevent that conduct in the future. The involved parties will be informed of the action(s) the Company takes to resolve and remedy the situation.

B. Non-Harassment Policy
The Company has a zero tolerance harassment policy and is committed to providing a work environment free from unlawful harassment. In accordance with applicable law, the Company prohibits unlawful harassment of any kind, whether verbal, physical or

- 7 - Employee Handbook – Rev. May 1, 2015
visual, that is based on race, color, r eligion, sex, age, national origin, ancestry, citizenship status, physical or mental disability, veteran or military status, marital status, medical condition, pregnancy, gender identity or expression, sexual orientation, genetic characteristics or genetic information, as well as any other category protected by federal, state, or local laws. All such harassment is unlawful and will not be tolerated.

The Company’s policy against harassment applies to all employees and independent contractors of the Company, including supervisors and manager s. The Company will not tolerate harassment of employees or independent contractors by managers, supervisors, co-workers, clients, vendors, suppliers, independent contractors and others doing business with the Company.

Violation of this policy will subject an employee to disciplinary action, up to and including termination. Additionally, under California law, employees may be held personally liable for harassing conduct that violates the California Fair Employment and Housing Act.

1. Sexual Harassment Defined
Applicable state and federal law defines sexual harassment as unwanted sexual advances, requests for sexual favors, or visual, verbal, or physical conduct of a sexual nature when: (1) submission to the conduct is made a term or condition of employment; or (2) submission to or rejection of the conduct is used as a basis for employment decisions affecting the individual; or (3) the conduct has the purpose or effect of unreasonably interfering with the employee's work performance or creating an intimidating, hostile, or offensive working environment. This definition includes many forms of offensive behavior. The following is a partial list:
a. Unwanted sexual advances;
b. Offering employment benefits in exchange for sexual favors or threatening an employment detriment for an employee’s failure to engage in sexual activity; c. Making or threatening reprisals after a negative response to sexual advances;
d. Visual conduct such as leering, making sexual gestures, or displaying sexually suggestive objects, pictures, cartoons, or posters; e. Verbal conduct such as making or using derogatory comments, epithets, slurs, sexually explicit jokes, or comments about any employee's body or dress;
f. Verbal sexual advances, propositions, requests or comments; g. Verbal abuse of a sexual nature, graphic verbal commentary about an individual's body, sexually degrading words to describe an individual, or suggestive or obscene letters, notes, or invitations;
h. Physical conduct such as touching, assault, or impeding or blocking movements;
i. Retaliation for reporting harassment or threatening to report harassment; and

- 8 - Employee Handbook – Rev. May 1, 2015
j. Widespread sexual favoritism
It is unlawful for males to sexually harass females or other males, and for females to sexually harass males or other females. Sexual harassment on the job is unlawful whether it involves coworker harassment, harassment by a supervisor, or harassment by persons doing business with or for the Company.

2. Other Types Of Harassment
Prohibited harassment on the basis of race, color, religion, age, national origin, ancestry, citizenship status, physical or mental disability, veteran or military status, marital status, medical condition, pregnancy, gender identity or expression, sexual orientation, genetic characteristics or genet ic information, or any other protected basis, includes behavior similar to sexual harassment, such as:
a. Verbal conduct such as threats, epithets, derogatory comments, offensive remarks, or slurs;
b. Visual conduct such as derogatory posters, photographs, cartoons, drawings, or gestures;
c. Physical conduct such as assault, unwanted touching, blocking normal movement, threats, intimidation or other menacing behavior; and d. Retaliation for reporting harassment or threatening to report harassment.

3. Company’s Complaint Procedure
The Company’s complaint procedure provides for an immediate, thorough, and objective investigation of any claim of unlawful or prohibited harassment, appropriate disciplinary action against one found to have engaged in prohibited harassment, and appropriate remedies for any victim of harassment. A claim of harassment may exist even if the employee has not lost a job or some economic benefit.

All employees are responsible for helping to assure a workplace free from prohibited discrimination or harassment. If an employee or independent contractor feels he/she has been subjected to any form of harassment or discrimination, the employee should firmly and clearly tell the person engaging in the harassing and/or discriminating conduct that it is unwelcome, offensive, and should stop at once. The employee should also provide a written or verbal complaint to his/her supervisor and/or Human Resources, or any member of senior management, including the President of the Company, as soon as possible. These are the individuals who are authorized by this policy to receive and act upon reports or complaints of harassment or discrimination on behalf of the Company. This policy does not require reporting harassment to any supervisor or manager who may be creating the harassment.

The complaint should be as detailed as possible, including the names of individuals involved, the names of any witnesses, direct quotations when language is relevant, and any documentary evidence (notes, pictures, cartoons, et cetera). All complaints of unlawful harassment will be treated with as much confidentiality as possible, consistent with the need to conduct an adequate investigation.

- 9 - Employee Handbook – Rev. May 1, 2015
Applicable law also prohibits retaliation against any employee for using this complaint procedure or for filing, testifying, assisting, or participating in any manner in any investigation, proceeding, or hearing conducted by a governmental enforcement agency. Additionally, the Company will not knowingly permit any retaliation against any employee who complains of prohibited harassment or who participates in an investigation.

All incidents of prohibited harassment that are reported will be investigated. The Company will immediately undertake or direct an effective, thorough, and objective investigation of the harassment allegations. The investigation will be completed and a determination regarding the reported harassment will be made and communicated to the employee who complained and to the accused harasser(s).

If it is determined prohibited harassment has occurred, the Company will take effective remedial action commensurate with the circumstances. Appropriate action will also be taken to deter any future harassment. If a complaint of prohibited harassment is substantiated, appropriate disciplinary action, up to and including discharge, will be taken. Whatever action is taken against the harasser will be communicated to the employee who complained. Employees should refer to the California Department of Fair Employment & Housing’s information sheet (DFEH #185) on sexual harassment that describes employee rights and remedies under state law. Copies of this pamphlet have been given to all employees.

4. Liability For Harassment
Any employee of the Company, whether a coworker or supervisor, who is found to have engaged in prohibited harassment is subject to disciplinary action, up to and including discharge from employment. The contract of any independent contractor is subject to termination for violation of this policy. Further, any supervisor or manager who knew about harassment and took no action to stop it or failed to report the harassment to Human Resources may also be subject to discipline, up to and including discharge. The Company does not consider conduct in violation of this policy to be within the course and scope of employment or the direct consequence of the discharge of one's duties.

C. Manager Training
As part of t he Company’s commitment to provide a harassment free workplace, the Company provides and requires training for all managers and supervisors on sexual and all other forms of prohibited harassment, and abusive conduct in the workplace, at least once every two years. While it is nearly impossible to prevent all employee conflict in any business, we believe that training our management staff on how to recognize and prevent harassment goes a long way to eliminating it in the workplace altogether.

- 10 - Employee Handbook – Rev. May 1, 2015
Reasonable Accommodation for
Section IV Disabilities, Pregnancy, & Lactation
A. Disability Accommodation
The Company will make reasonable accommodations for the known physical or mental disabilities of an otherwise qualified applicant for employment or employee, unless undue hardship to the Company would result. Any applicant or employee who requires accommodation in order to perform the essential functions of a job should contact their supervisor and/or Human Resources.

The applicant or employee should advise the Company what accommodations he or she believes are needed in order to perform the job. Together with the applicant or employee, the Company will engage in an interactive process to determine effective, reasonable accommodations, if any. If such an accommodation is possible and will not impose undue hardship on the Company, the Company will make the accommodation.

The Company also reserves the right to require an employee to undergo a fitness -for- duty medical examination, at the Company's expense, if the Company believes or suspects that the employee may not be able to perform the essential duties of the job or may not be able to perform the essential duties of the job without risk of harm to him/herself or others. In such an instance, the Company will so advise the employee, in writing, of the need for the examination. Depending on the situation, the Company reserves the right to suspend employment pending the results of the examination.

B. Pregnancy Accommodation
A pregnant employee may request a reasonable accommodation of her condition on presentation of a doctor's written certification attesting that the accommodation request is on the doctor's advice. Such an accommodation may include, but is not limited to, a transfer to a less strenuous or hazardous position. If such a transfer can be reasonably accommodated and does not impose an undue hardship on the Company, a pregnant employee will be transferred for the duration of her pregnancy. However, the Company need not undertake to create additional employment that the Company would not otherwise have created to meet its own business needs, nor will the Company be required to discharge any employee, transfer any employee with more seniority than the pregnant employee, or to promote any employee who is not qualified to perform the job.

On transfer, an employee will receive the salary and benefits which are regularly provided to employees in the position to which the employee has transferred. The Company need not make an accommodation that is an undue hardship on the Company.

C. Lactation Accommodation
Employees who wish to express breast milk at work may request a reasonable accommodation to do so. The Company will provide a reasonable amount of break time to accommodate an employee to express breast milk for the employee’s infant child. If possible, such break time will run concurrently with the break time already provided.

Any other break time will be unpaid. If the employee requiring a lactation break does not normally work in an area that can be made private, the Company will make reasonable efforts to provide the use of a room or other nearby location to express milk in private.

- 11 - Employee Handbook – Rev. May 1, 2015
Communication and
Section V Problem Solving
A. Non-Fraternization
The Company does not prohibit relatives, spouses, and domestic partners from applying for job openings. However, such relatives, spouses, and domestic partners will not be given priority or preference over other applicants. Should a relative, spouse or domestic partner of an employee be hired, he or she may not supervise or be supervised by his or her relative, spouse or domestic partner, or be placed in a position that may cause difficulties for supervision, safety, security, or morale, or create a potential conflict of interest.

B. No Solicitation Policy
To avoid interruption of employee work and protect employees from unnecessary annoyance, it is necessary to prohibit solicitations and distribution of literature on working time and in work areas.

Therefore, no employee shall solicit or promote support for any cause or organization during his or her working time or during the working time of the employee or employees at whom the activity is directed. No employee 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 employee or employees at whom the activity is directed. Further, under no circumstances will non- employees be permitted to solicit or distribute written materials for any purpose on Company property. Distribution of literature in working areas is prohibited at all times.

Employees are advised to refrain from soliciting for a children’s fund raising event such as, but not limited to, a child’s school, boys and girls clubs, etc. on work time or in work areas. In addition, employees are advised to refrain from selling any food or other goods on work time or in work areas. The Company will not be held responsible for any lost, stolen or damaged goods, and Company disclaims any and all liability for any damages or claims arising from such solicitation or sale of food or goods. Employees are not obligated to purchase from these or any other organizations.

Working time does not include rest breaks and meal periods, off duty hours, or other periods during the work day when employees are properly not engaged in performing their work tasks.

C. Open-Door Policy
The Company recognizes that employees will have suggestions for improving the workplace, as well as complaints about the workplace. The most satisfactory solution to a job- related problem or concern is usually reached through prompt discussion.

Employees are encouraged to see their supervisor or manager with questions or problems relating to their job. Employees also can talk over matters of concern directly with Human Resources.

If an employee does not feel comfortable contacting his/her manager or Human Resources, he/she may write out his/her suggestion and/or complaint and submit them

- 12 - Employee Handbook – Rev. May 1, 2015
either anonymously or not in one of the suggestion boxes located throughout the facility.

However, suggestions and/or complaints received anonymously will not allow management to provide you with feedback.

While the Company provides you with this opportunity to communicate your views, please understand that not every complaint can be resolved to your satisfaction. Even so, the Company believes that open communication is essential to a successful work environment and all employees should feel free to raise issues of concern without fear of reprisal.

- 13 - Employee Handbook – Rev. May 1, 2015
Confidentiality and
Section VI Conflict of Interest
A. Confidentiality And Non-Disclosure
The Company has a vital interest in protecting its employees, their property and the property of the Company. Proper security depends on the cooperation of the entire workforce. Accordingly, all employees are asked to comply with the Company’s confidentiality and non-disclosure policies. Any breach of these policies should be reported promptly to your manager.

Information about the Company, its contracts and its employees, passengers, suppliers and vendors is to be kept confidential and divulged only to individuals within the Company with both a need to receive and authorization to receive the information. This does not pertain to employees disclosing or discussing their own wages or salaries as well as working conditions with others. If in doubt as to whether information should be divulged, err in favor of not divulging information and discuss the situation with your manager.

The protection of the Company’s property is vital to the interests and success of the Company. Company property includes not only tangible property, such as equipment, but also intangible property, such as information. Of particular importance is proprietary and confidential information obtained by the Company employees during the course of their work. Confidential information is any information not known generally to the public or the industry.

Confidential information obtained during or through employment with the Company may not be used by any employee for the purpose of furthering current or future outside employment or activities or for obtaining personal gain or profit. The Company reserves the right to avail itself of all legal or equitable remedies to prevent impermissible use of confidential information or to recover damages incurred as a result of the impermissible use of confidential information.

B. Conflicts Of Interest
Employees are required to avoid any conflict of interest during his or her employment by the Company. Any involvement that conflicts with an employee's duties or responsibilities or affects the employee's judgment in making a decision affecting the Company will be considered a conflict of interest. This includes any direct or indirect business, management or financial interest or activity, whether or not for compensation, in any business or entity that is a competitor, client, supplier or vendor of the Company.

Employees may engage in or have outside businesses, personal interests or activities that do not constitute a conflict of interest with their employment at the Company. The Company requires that these activities or interests do not adversely affect an employee's capacity to perform his or her job duties or result in conflicting loyalties.

C. Outside Jobs
The Company has no objection to you holding another job as long as you can effectively meet the perform ance standards for your position with the Company and disclose the

- 14 - Employee Handbook – Rev. May 1, 2015
second job to the Company. The Company asks that you think seriously about the effects that such extra work may have on the limits of your endurance, your overall personal health, and your effectiveness with the Company. The Company will hold all employees to the same standards of performance and scheduling demands and cannot make exceptions for employees who also hold outside jobs.

If the Company determines an employee's outside job interferes with his or her performance or ability to meet the Company's requirements, the employee may be required to elect between terminating their outside employment or terminating their employment with the Company.

An employee may not, during employment with the Company, work for a competitor of the Company without written approval.

- 15 - Employee Handbook – Rev. May 1, 2015
Section VII Payroll Practices
A. Employee Status

1. Training Employees
Training employees are those who are training for their position with the Company and have not yet been scheduled regular hours. Training employees are not eligible for employer-sponsored benefits, except those required by law.

2. Regular Full-Time Employees
For purposes of eligibility for health benefits, regular full -time employees are those who work at least 30 hours per week and who have completed (1) a 30- day orientation period after the date of hire, and (2) a 30- day waiting period immediately thereafter. Such employees are eligible for health benefits as of the first of the month following the 30-day waiting period.

3. Regular Part-Time Employees
Regular part-time employees are those who work less than 30 (thirty) hours per week. Part-time employees may be assigned a work schedule in advance or may work on an as-needed basis.

4. Non-Exempt Employees
Non-exempt employees are those who are subject to the provisions of federal and state law requiring the payment of overtime. The Company will pay non- exempt employees overtime pay in accordance with state and federal law.

You will be advised of your employee status at the time of hire, promotion or transfer. Since all employees are hired for an unspecified duration, assignment to any of these classifications does not guarantee employment for any specific length of time. Regardless of classification, your employment with the Company is at will. Accordingly, either you or the Company can terminate the employment relationship at will, at any time, without cause or notice.

5. Salaried, Exempt Employees
Exempt employees are those whose job assignment meets the federal and state requirements for overtime exemption. Exempt employees include salaried professional, executive, and administrative employees.

Exempt employees’ salary will not be reduced for partial weeks of work due to service in the military or for lack of work.

Salaried, exempt employees are expected to demonstrate the level of commitment appropriate to their job classification. The Company will consider any failure to display such commitment when evaluating an employee's performance and when considering matters such as pay increases and opportunities for advancement.

- 16 - Employee Handbook – Rev. May 1, 2015
B. Orientation Period
The first thirty (30) days of continuous employment will be a learning experience. You will learn your job duties and responsibilities, get acquainted with your supervisor and fellow employees, and familiarize yourself with the Company in general. We refer to this initial period of employment as your “ orientation period.” However, certain positions within the Company may require a period of training that exceeds the initial orientation period.

While we understand that you will be learning a lot about your new job, you are still expected to perform satisfactorily and your performance will be reviewed closely. Also, please understand that completion of the orientation period does not guarantee continued employment and does not change the at -will nature of the employment relationship.

On satisfactory completion of the orientation period, the employee’s performance will be reviewed. Please note that completion of the orientation period does not guarantee continued or long term employment. All employees remain at will both during and after the orientation period and the Company may terminate employment at any time, with or without cause.

C. Anniversary Date
An employee’s anniversary date shall be the employee’s date of hire. The Company will use employee’s anniversary date to calculate PTO accrual.

D. Reporting Pay
The Company will pay you for one half (½) of your regularly scheduled workday, not to exceed four (4) hours pay, or two (2) hours at your straight time pay rate, whichever is greater, if you report to work and are not put to work or are given less than half the usual or scheduled day’s work. The Company will not pay you for reporting to work under the following circumstances:

1. The interruption of work is due to the failure of any public utility;

2. The interruption of work is due to an act of God or other cause not within the Company's power to control;

3. Operations cannot begin due to threats to the Company or the Company’s property, or when recommended by civil authority;

4. To employees on a paid standby status, called to work at times other than their usual shift; and

5. If you show up to work unfit to perform your regular work duties.

E. Payroll Deductions
State and federal laws require the Company to make the proper deductions on your behalf. Amounts withheld vary according to how much you earn, your marital status, and the number of your exemptions. Required deductions include: (1) Social Security (FICA); (2) Medicare; (3) federal income tax; (4) state income tax; (5) State Disability

- 17 - Employee Handbook – Rev. May 1, 2015
Insurance (SDI); and (6) Paid Family Leave (PFL). Voluntary deductions for the employee portion of health insurance premiums, or other voluntary benefits, will be made on an employee's written authorization.

F. Payment of Wages
Wages will be paid every other Friday for the work performed between the previous two designated workweeks. In the event a regularly scheduled payday falls on a holiday, employees will be paid the prior workday.

If there is an error in your check, please report it immediately to your supervisor. Failure to do so may result in disciplinary action, including but not limited to termination. No one other than the employee to whom the paycheck is written will be allowed to pick up a paycheck unless written authorization has been given for another person to do so.

G. Requests For Payroll Records
The Company will provide an employee or former employee with copies of his or her payroll records within twenty-one (21) days of his or her submission of a written request to their manager or Human Resources.

H. Reimbursement of Business Expenses
The Company will reimburse employees for reasonable, pre- approved business expenses incurred in connection with the performance of the employee’s duties.

Employees should promptly submit expense reports detailing the business -related expenses and must obtain prior consent before incurring any business-related expense.

I. Wage Overpayment/Underpayment
The Company takes all reasonable steps to ensure employees receive the correct amount of pay in each paycheck and are paid promptly in full on the scheduled paydays.

In the unlikely event there is an error in the amount of your pay, you should promptly bring the discrepancy to the attention of your supervisor so corrections can be made as quickly as possible. Failure to immediately report any discrepancy in your paycheck may result in disciplinary action, including but not limited to termination of employment.

If the Company determines you have been underpaid, the Company will pay you the difference. If the Company determines you have been paid in excess of what you earned, you can either repay the Company or consider the overpayment an advance of future wages payable. The Company will ask you to sign an authorization to deduct the excess (in whole or in part) from the next available paycheck(s) until the overpaid amount has been fully repaid.

No employee is entitled to retain any pay in excess of the amount he or she has earned according to the agreed- on rate of pay. Failure to report any discrepancy in your paycheck may result in disciplinary action, including but not limited to termination of employment. No deduction will cause any employee to earn less than the current minimum wage. Deductions will not be made from final paychecks.

- 18 - Employee Handbook – Rev. May 1, 2015
J. Wage Garnishments
The Company will adhere to legally imposed wage assignments and garnishments and will not modify the terms of those legal arrangements unless ordered to by a court.

K. Advances
The Company does not provide payroll advances , extend credit or offer loans to employees.

- 19 - Employee Handbook – Rev. May 1, 2015
Hours of Operation
Section VIII and Work Schedules

A. Business Hours and Schedule
The Company’s designated workweek begins at 12:01 a.m. on Saturday and ends at midnight the following Friday.

You will be assigned a work schedule and you will be expected to begin and end work according to the schedule. To accommodate the needs of our business, it may be necessary to change individual work schedules on either a short-term or long-term basis.

All employees are responsible for knowing their schedule and working the hours assigned. Employees must check the schedule regularly for any changes.

Exchanging work schedules with other employees is discouraged. However, if it is necessary to exchange schedules, both employees’ supervisors must be notified and must approve the change. Schedules will not be exchanged if the exchange will result in disruption or interference with the Company’s normal operations, or will result in overtime.

B. Meal And Rest Periods
Non-exempt employees are entitled to a 30-minute unpaid duty -free meal period for every work period of more than five (5) hours, to be taken before or at the end of the five hour period. However, if six (6) hours of work will complete the day’s work, the employee may voluntarily choose not to take the meal break with the consent of his or her supervisor. A second meal break is available for employees working more than ten (10) hours in a workday. An employee may waive the second meal break if (i) the total hours worked on that workday is not more than twelve ( 12); (ii) there is mutual consent of the employer and the employee; and (iii) the first meal break of the workday was not waived.

Non-exempt employees are also authorized and permitted to take a paid ten (10) minute break for every four (4) hours of work (or majority thereof). Rest breaks should occur as near as possible to the middle of the work period. Rest breaks cannot be combined with your meal period. Nor can employees use rest breaks to come in late or leave early.

If a non -exempt employee feels they are not being provided an opportunity to take a meal or rest break in accordance with this policy, they should inform their supervisor immediately.

Your supervisor will schedule your break and meal periods. An employee who refuses to take their meal period may be subject to discipline, up to and including termination of employment.

By signing each time record, all non-exempt employees certify that they were advised of their right to rest and meal breaks and that they took all rest and meal break s to the extent required by law.

- 20 - Employee Handbook – Rev. May 1, 2015
C. Time Records
Time records are the Company’s way of making sure employees are paid correctly. All employees, exempt and non-exempt, are required to submit a signed time card, or in the case of employees who are drivers, a trip sheet, for each pay period.

Non-exempt employees must record the time work begins and ends, as well as the beginning and ending time of each meal period. Non- exempt employees must also record any departure from work for any non- work-related reason. Non -exempt employees should not report to work prior to their scheduled starting time nor stay after their scheduled stop time, or work any overtime without authorization from their supervisor.

Exempt employees are required to record their time worked and must report absences from work for reasons such as vacation or personal business.

All employees must make sure that personal days off, leaves , and holidays are correctly recorded on their time card.

It is your responsibility to sign your time record or trip sheet, as the case may be. When you do so, you will be certifying the accuracy of all time recorded and non- exempt employees will also be certifying they took all required meal and break periods to the extent required by law.

Any errors in your timecard or trip sheet should be reported immediately to your supervisor. The Company will attempt to correct legitimate errors.

Altering, falsifying, and tampering with time records, trip sheets, or recording time on another employee's time record , is prohibited and subject to disciplinary action, up to and including termination of employment.

D. Accuracy Of Time
It is the Company's goal to ensure that all employees are properly paid for all of their work. Therefore, it is every employee's responsibility to examine their paycheck and paycheck stub to ensure they are being properly paid for all work time and that the paycheck and pay stub are accurate. If an employee believes they are not being properly paid for all their work, the employee must immediately inform their supervisor.

Additionally, employees may not work "off the clock." If anyone asks you to work "off the clock," you must immediately bring this issue to your supervisor, Human Resources, or management. No employees are permitted to work "off the clock" at any time. For the purposes of this policy, "off the clock" work is where an employee works for the Company but does not accurately record their time in the Company's approved time record.

Only an employee’s manager is authorized to change an employee's time record to accurately reflect the employee's actual work hours. Employees should initial all such changes to confirm the revised time accurately reflects the hours worked.

It will be presumed the Company is accurately compensating an employee, unless the employee brings a complaint pursuant to this policy in a manner that is timely . “Timely” is defined as 72 hours from receipt of your payroll check.

- 21 - Employee Handbook – Rev. May 1, 2015
E. Overtime
The Company may request employees to work beyond their normal shift from time to time. Although employees will be given advance notice where feasible, this is not always possible. Employees must have prior approval from their supervisor or manager before any overtime can be worked. Non-approved overtime will be paid, but may result in discipline, up to and including termination.

The Company will pay overtime as required by applicable federal and state law as follows:

Non-exempt employees who regularly work an eight (8) hour daily shift will be paid at the rate of one and one half (1½) times their regular rate of pay for hours worked over forty (40) hours in a work week or eight (8) in a workday. In addition, the Company will pay one and one half (1½) times the employee’s regular rate of pay for the first eight (8) hours worked by the employee on his or her seventh consecutive day of work in a work week. Work performed in excess of twelve ( 12) hours per day and after eight (8) hours on the seventh consecutive day worked will be paid double the employee’s regular rate of pay.

Non-exempt employees who regularly work a ten (10) hour daily shift pursuant to an authorized alternative work week scheduled will be paid 1½ times their regular rate of pay for hours worked over forty (40) hours in a work week or ten ( 10) hours in a workday. Work performed in excess of twelve (12) hours per day will be paid double the employee’s regular rate of pay.

Drivers of commercial vehicles requiring a commercial driver license are not eligible for daily overtime, but are eligible for overtime for hours worked over forty (40) in a work week. Please see your supervisor if you have any questions regarding overtime.

Holidays and Personal Time Off which is paid, but not worked, is not included in calculating overtime. The Company does not permit employees to take time off in lieu of receiving overtime pay.

Exempt employees may have to work hours beyond their normal schedule, but will not be paid overtime.

- 22 - Employee Handbook – Rev. May 1, 2015
Section IX Personnel Records
A. Health Insurance Portability And Accountability Act (HIPAA) The Health Insurance Portability and Accountability Act (HIPAA), a federal law, is designed to protect the privacy of an individual's medical information. The Company complies with HIPAA to the extent it is applicable. The Company follows the HIPAA standards for non-covered entities which sponsor group health plans.

You will receive a HIPAA Notice of Privacy Rights. If at any time, you have any questions about HIPAA, please contact the individual designated in the Notice of Privacy Rights.

B. Personnel Records
The Company keeps a personnel file on each employee. The personnel file contains such information as the employee's job application, records of training, performance appraisals, and records of salary increases.

The contents of an employee's file, except for pre-employment materials and certain other limited kinds of information, are open for his or her inspection, within 30 days of a written request. An employee may make copies of anything in his or her file that has been signed by them, provided the employee/former employee pays the actual cost of copying. Employees/former employees must complete the Personnel File Inspection / Copy Form and provide it to Human Resources if they wish to review or copy their personnel file. Personnel files may only be reviewed in the presence of a designated Company representative.

Personnel files are the property of the Company and access to the information they contain is restricted. Generally this information is only available to those in management who have a legitimate need for the information.

The Company will keep employee personnel records confidential. Any request for information from a personnel file must be directed to Human Resources. Only Human Resources is authorized to release information about current or former employees.

There are certain times when information may be given to persons outside of the Company. These include:

1. Responses to subpoenas, court orders, or orders of administrative agencies;

2. In a lawsuit in which an employee and/or the Company are parties;

3. To administer employee benefit plans; and

4. To a health care provider.

- 23 - Employee Handbook – Rev. May 1, 2015
C. Personnel Data Changes
It is the responsibility of each employee to promptly notify the Company of any changes in his or her personnel data. An employee's personal mailing address, telephone number, number and names of dependents, and emergency contact, should be kept accurate and current. Moreover, to ensure the Company can notify you when necessary, you must provide an address where the Company can reach you (not a Post Office or P.O. Box). If any personnel data has changed, employees must notify either their manager or Human Resources immediately.

- 24 - Employee Handbook – Rev. May 1, 2015
Job Duties
Section X and Performance
A. Work Assignments
From time to time, an employee may be asked to work on special projects or to assist with other work necessary or important to the operation of his or her department or the Company. Cooperation and assistance in performing such additional work is expected.

The Company reserves the right, at any time, with or without notice, to alter or amend an employee's job description, to reassign or transfer job duties, or to assign additional job responsibilities.

B. Job Duties
As part of your initial orientation, you will learn the various duties and responsibilities of your job. The Company maintains certain expectations and standards applicable to your job position. Your manager will review these with you.

It is expected that employees will perform additional duties and assume additional responsibilities as needed for the efficient operation of the Company.

In order to adjust to changes in our business, it may become necessary to add to or remove certain duties and responsibilities, or to reassign you to an alternate job position.

Employees are expected to cooperate in this regard.

C. Performance Evaluations
Employees are strongly encouraged to discuss job performance and goals on an informal, ongoing basis.

Evaluations will usually be conducted by your manager. The frequency of performance evaluations may vary depending on length of service, job position, past performance, changes in job duties or recurring performance problems.

The purpose of any evaluation is to let the employee and the Company review the employee's job tasks, encourage and recognize employee strengths, identify and correct weaknesses, and to set future performance goals and methods for meeting these goals.

The evaluation may include a review of factors such as the quality and quantity of work, job knowledge, initiative, work attitude, and attitude towards others.

Evaluations will be reviewed in a private meeting between the employee and their manager. The employee will be allowed to see and comment on the evaluation, sign the form to show that it has been read and discussed, and receive a copy. The employee is encouraged to ask questions and comment on the evaluation.

Performance evaluations will not necessarily result in a salary increase or promotion.

The timing and amount of such increases and promotions will be determined by the Company and will be based on individual merit.

- 25 - Employee Handbook – Rev. May 1, 2015
Employee Conduct
Section XI and Work Rules
A. Employee Conduct
Whenever people are required to work together for any purpose, they need certain guidelines to govern their personal conduct and relations. The Company considers work rules to be an important responsibility. They are a necessary part of managing the business so employees can be treated fairly and work safely and effectively. These rules apply to all employees. You may receive disciplinary action in the form of verbal warnings, written warnings, or suspension, or you may be immediately discharged from your employment as the Company is an at-will employer.

Examples of impermissible conduct which may lead to disciplinary action are identified below to promote understanding of what is considered unacceptable conduct and to encourage consistent action by the Company in the event of violations. However, it is impossible to provide an exhaustive list of types of conduct that may result in disciplinary action. The following list, therefore, contains only some examples of conduct that may lead to the imposition of discipline, up to and including termination.

1. Falsification of employment records, employment information, or other records.

2. Recording the work time of another employee, allowing any other employee to record your work time, or allowing falsification of any time card, whether your own or another employee's.

3. Theft or damage of any Company property or the property of any employee or client.

4. Removing or borrowing Company property without prior authorization.

5. Unauthorized use of Company equipment, time, materials, or facilities.

6. Working with alcohol or illegal substances in your system or any violation of the Company’s policy on drugs and alcohol.

7. Possessing, distributing, selling, transferring, using, or having alcohol or illegal drugs in your system while in the workplace or in Company vehicles.

8. Provoking or participating in a fight or fighting during working hours or on premises owned or occupied by the Company.

9. Provoking or participating in horseplay or practical jokes on the Company's time or on premises owned or occupied by the Company.

10. Possession of firearms or any other dangerous weapons, at any time, on premises owned or occupied by the Company or in company vehicles.

11. Engaging in illegal conduct which is detrimental to the reputation of the Company, whether or not related to job performance.

- 26 - Employee Handbook – Rev. May 1, 2015

12. Insubordination, including, but not limited to, failure or refusal to obey the orders or instructions of any supervisor or member of management, the use of threatening language toward any supervisor or member of mana gement, or refusal to fully disclose information in the course of Company investigations.

13. Using profane, hostile, or abusive language towards an employee or customer at any time during working hours or while on premises owned or occupied by the Company.

14. Failing to personally notify the Company when unable to report to work.

15. Failure to report to work and notify management of the absence for two (2) consecutive scheduled workdays.

16. Failing to obtain permission to leave work for any reason during normal working hours, with the exception of unpaid meal periods.

17. Failing to observe working schedules, including meal periods.

18. Failing to provide a physician's certificate when requested or required to do so.

19. Sleeping or malingering on the job.

20. Working overtime without authorization or refusing to work assigned overtime.

21. Violating any safety, health, or security policy, rule, or procedure of the Company.

22. Failing to maintain the confidentiality of proprietary information or Company trade secrets or engaging in direct competition with the Company.

23. Engaging in unlawful harassment or discrimination.

24. Failing to comply with the Company’s policies, including the policies in this Employee Handbook.

The Company does not have a formal progressive discipline policy requiring a set number of warnings or counseling sessions. Instead, each case is considered based on its own facts. Any misconduct or violation of the Company's policies may result in discipline, up to and including termination.

This statement of prohibited conduct does not alter or limit the Company's policy of employment at will. Either you or the Company may terminate the employment relationship at any time for any reason, with or without cause or without notice.

B. Cell Phone Safety While Driving
In the interest of the safety of our employees and others, employees are prohibited from using cell phones, text messaging , and/or emailing while driving on Company business and/or Company time. Under no circumstances shall employees make phone calls, text message, or email while driving on Company business and/or Company time.

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If an emergency arises and the employee must use their cell phone while in a Company vehicle, the employee must pull over and park the vehicle before doing so. Employees who violate this policy are subject to disciplinary action, up to and including termination.

This policy does not apply in the event an employee needs to use a cell phone in the case of an emergency or to contact a law enforcement agency.

C. Telephones and Personal Cell Phones
It is important to keep the Company’s telephone lines free for client and passenger calls.

Occasional use of the Company’s telephones for a personal emergency may be necessary, but routine personal calls should be kept to a minimum.

In order to ensure that telephone calls are handled in a professional and businesslike manner and to promote employee efficiency, the Company may monitor employee telephone calls. Therefore, employees should have no anticipation of privacy for either incoming or outgoing calls made on Company-provided telephone equipment.

Use of personal cell phones at work interferes with the efficient operations of the Company and is distracting to others. Absent a true emergency, employees may not use personal cell phones during the employee’s work hours. Employees are also prohibited from using the text messaging and photography features of cell phones during these times. Personal cell phones must be kept in the “ silent” position (vibrate position is not allowed) and should be kept in employees’ desk drawer, purse or pocket, and used only during rest breaks and meal periods.

Employees may not use their personal cell phone to conduct Company business unless specifically authorized.

D. Drug And Alcohol Policy
The Company maintains ZERO TOLERANCE for drug and alcohol abuse by its employees. Illicit drug use and indiscriminate alcohol consumption puts everyone at risk and cannot be tolerated. In keeping with our efforts to promote health and safety and protect the interests of our employees, clients, passengers, and the Company, the Company strictly prohibits the use, possess ion, s ale, manufacture, or purchase of alcohol, illegal drugs, intoxicants, or controlled substances at any time on Company premises, in Company vehicles, or while on Company business. Furthermore, employees are prohibited from being under the influence of, or having in their system, alcohol, illegal drugs, intoxicants or controlled substances during working time or while operating company vehicles.

1. Prohibited Acts
The follow ing rules and standards of conduct apply to all employees. The following acts are strictly prohibited by the Company and will be grounds for immediate termination:
a. Possession, use, or having alcohol or an illegal drug intoxicant, or controlled substance in your system while on the job or on Company-owned or occupied premises, or in Company vehicles;

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b. Driving a Company vehicle, or driving any vehicle on Company business , while having alcohol or an illegal drug, intoxicant, or controlled substance in your system;
c. Distributing, selling, manufacturing, or purchasing--or attempting to distribute, sell, manufacture, or purchase-- an illegal drug, intoxicant, or controlled substance during working hours or while on Company -owned or occupied premises or in Company vehicles;
d. Testing positive on a required or requested drug or alcohol test or screen; e. Refusing either to take or to release information regarding a required or requested drug or alcohol test or screen; and
f. Violating any Company rule or policy regarding alcohol and drug use.

2. Testing Program
The Company may require drug and/or alcohol testing:
a. After an offer of employment, but before the applicant commences employment;
b. When a reasonable suspicion exists that any employee has alcohol or any illegal drug, intoxicant, or controlled substance in his or her system while on the job, or is otherwise in violation of this policy. Reasonable suspicion means suspicion based on information regarding, among other things, the appearance, behavior, speech, attitude, mood, and/or breath odor of any employee;
c. When any employee is found in possession of alcohol or any illegal drug, intoxicant, or controlled substance in violation of Company policy, or when any of those items are found in an area controlled or used by the employee; d. When an accident, near -miss, or incident occurs in which safety precautions are violated or careless acts are performed, and a reasonable suspicion exists that the employee involved has alcohol or any illegal drug, intoxicant, or controlled substance in his or her system;
e. When a work injury is reported;
f. After any employee has participated in a rehabilitation program; and g. When required by a state or federal law or regulation.

Employees suspected of possessing alcohol, illegal drugs, intoxicants, o r controlled substances are subject to inspection and search, with or without notice. Employees' personal belongings, including any bags, purses, briefcases, and clothing, and all Company property, are also subject to inspection and search, with or without notice. Employees who violate the Company's drug and alcohol policy will be removed from the workplace immediately. The Company may also bring the matter to the attention of appropriate law enforcement authorities. Any conviction for criminal conduct involving illegal drugs,

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intoxicants, or controlled substances, whether on or off duty, or any violation of the Company's drug and alcohol policy, including having a positive drug test result or refusing to take the test will be grounds for immediate termination.

Any employee's conviction on a charge of sale, distribution, manufacturing --or attempted sale, distribution, or manufacturing --or possession of any controlled substance while off Company property will not be tolerated because that conduct, even though off duty, reflects adversely on the Company. In addition to reflecting adversely on the Company, the Company must keep people who are involved with illegal drugs, intoxicants, and controlled substances off premises owned or occupied by the Company in order to keep those substances off the premises.

Employees found to be involved as such will be subject to immediate termination.

Any employee who is using prescription or over -the-counter drugs that may impair his or her ability to safely perform the job or may affect the safety or well - being of others must submit a physician's statement that the prescription drug use will not affect job safety. The employee is not required to identify the medication or the underlying illness. Various federal, state, and local laws protect the rights of individuals with disabilities and others with regard to the confidentiality of medical information, medical treatment, and the use of prescription drugs and substances taken under medical supervision. Nothing contained in this policy is intended to violate or interfere with individual rights under these laws. Employees who violate over -the-counter or prescription notification are subject to disciplinary action, up to and including termination.

It is essential employees comply fully with this policy and the Company’s other guidelines regarding substance abuse.

The Company’s Drug and Alcohol Policy is further set forth in a separate document and is distributed to and reviewed with employees during training.

Please refer to that separate document for further information and contact your supervisor or manager if you have any questions.

E. Smoking
As part the Company’s efforts to provide a safe and healthy workplace, smoking cigarettes and/or electronic cigarettes is allowed in designated areas only. Smoking within the facility is strictly prohibited. Smoking is prohibited in ALL Company vehicles.

Employees who smoke may do so only on their meal and rest breaks and only outside of the Company’s offices.

Employees smoking in any non-smoking area may be subject to disciplinary action, up to and including termination. Please contact your supervisor if you have any questions regarding this policy.

F. Dress And Grooming
Dress, grooming and personal cleanliness standards contribute to the morale of all employees and a ffect the business image that the Company presents to others.

Employees are expected to report to work well -groomed, clean and dressed appropriately in designated uniform (uniform shirts are provided for all departments,

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excluding Office Administration). Your attire should be appropriate for your position, roles and responsibilities.

Clothing should be professional, neat, clean, tasteful and in good repair. Wrinkled, torn, dirty, worn out or overly revealing clothing is unacceptable. All seams must be finished.

Any clothing that has words, terms or pictures that may be offensive is unacceptable.

Hair should be clean, combed and neatly trimmed or arranged. All employees will maintain good hygiene and grooming standards. Excessive jewelry, make -up, hairstyles, and body piercings are not permitted while on duty.

Employees may dress casually, but may not wear undershirts, sweat pants, pajama- like pants, swim wear, or flip-flops. Pants must be worn at the waist and fit appropriately. If pants are loose at the waist, a belt must be worn. Men’s shirts must have a collar.

The following is not permissible:
• Shorts shorter than 4” above the knee
• Hats, stocking caps, caps with logos
• T ank tops and/or spaghetti straps or tube tops
• Bare backs or midriffs
• Distracting or revealing clothing
• Skirts / dresses revealing more than 4” above the knee • Low cut or revealing outfits
• See through clothing
• S weat pants
• Flashy or “loud” clothing
• Clothes that are too transparent or too tight
• T- shirts without a collar
• Excessively long fingernails
• Overly strong perfume or lotion
Employees should consult with their supervisor or manager if they have any questions as to what constitutes appropriate attire.

Employees who are not dressed in proper attire may be sent home to change, and they will not be compensated for the time away from work. Violations of this policy may result in disciplinary action, up to and including termination.

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The Company will consider reasonable accommodations for employees who would be non-compliant with the Dress & Grooming Policy as part of their religious practices (e.g., religious head coverings).

G. Attendance
To maintain a safe and productive work environment, the Company expects you to report to work on a reliable and punctual basis. Excessive unexcused absenteeism, early departures from work, and late arrivals burden your fellow employees and the Company. If you cannot avoid being late to work or are unable to work as scheduled, you must notify your supervisor or manager a minimum of 2 hours prior to the start of your shift. If you are unable to reach your supervisor, you must contact dispatch or the person designated by your contract and inform them of your status.

Every time you are absent or late, or leave early, you must provide an honest reason or explanation. You must also inform the Company of the expected duration of any absence. If the expected duration of your absence is unknown, you must call in each day. The Company will comply with applicable laws relating to time off from work, but it is your responsibility to provide sufficient information to enable the Company to make a determination. You must notify the Company of any change in your status as soon as possible.

Except for absences that are legally authorized, excessive unexcused absenteeism and/or tardiness may lead to disciplinary action, up to and including termination of employment.

If you fail t o report to work and notify management of the absence for two (2) consecutive scheduled workdays, or are tardy three (3) times within a thirty (30) day period , you will be considered excessively absent or tardy and will be subject to discipline , up to and including termination. Three or more days of absence may require certification from your health care provider. In addition, the Company will take corrective action up to and including termination in any case where your overall attendance or tardiness record is less than satisfactory.

Employees not present at their workstation ready to start work by their designated start time may be considered tardy.

Certification by your health care provider is required for absences of five (5 ) or more consecutive work days.

If you fail to report for work without notification for two (2) consecutive workday s, you may be considered to have abandoned your employment.

Different rules may apply to individuals on a protected leave of absence, which may require an employee to be absent on a regular or intermittent basis. Also, individuals with disabilities may be granted reasonable accommodation in complying with these policies if undue hardship does not result to the Company’s operations. However, regular attendance and promptness are generally considered part of each employee’s essential job functions.

H. Contact With the Company
It is essential that drivers are at the appointed job sites at the designated times. The Company’s clients and passengers rely on this. Thus, employees must inform the

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Company in advance if they anticipate they will not be in a scheduled place at a scheduled time.

I. Customer and Public Relations
The Company’s reputation is built on excellent service and quality, and reliable work.

The active participation of every employee is required to maintain this reputation.

The opinion a customer has about the Company may be based on the actions of a single employee. It is sometimes easy to take customers for granted, but when we do, we run the risk of losing not only that customer, but his or her associates, friends or family who may also be customers or prospective customers.

Each employee must be sensitive to the importance of providing courteous treatment in all working relationships, including to coworkers.

J. Confidentiality of Customer Matters
The Company requires employees to maintain the highest degree of confidentiality when handling customer matters. Employees should not disclose customer information to anyone outside the Company, including other customers and third parties. Questions about customer confidentiality should be directed to your supervisor.

K. Gratuities
Employees are not permitted to accept gratuities of any kind from clients, passengers or vendors.

L. Natural Disasters
When natural disasters, such as earthquakes, mud slides, floods and fires occur, the public and our clients rely on us more than ever to provide our services. It is imperative that employees work with the Company during these times and to keep the Company informed of their whereabouts and ability to report to work.

Unless the Company is notified and approves the absence, employees are expected to report to work as scheduled. If extreme conditions require the Company to close its operations, the Company will attempt to notify employees.

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Section XII Safety and Security
The Company has a vital interest in maintaining safe, healthful and efficient working conditions for its employees, clients, and visitors. Accordingly, it is the right, obligation and intent of the Company to protect its employees, clients, passengers, and visitors, and to safeguard Company property, equipment and operations by establishing and maintaining the following policies.

A. Policy Against Workplace Violence

1. Statement of Policy
The safety and security of Company employees is paramount. Acts or threats of physical violence, including intimidation, harassment, and/or coercion, that involve or affect the Company or that occur on Company property or in the conduct of Company business off Company property, will not be tolerated. This prohibition against threats and acts of violence applies to all persons involved in Company operations, including, but not limited to, Company personnel, contract workers and anyone else on Company property or conducting Company business off Company property. Violations of this policy will lead to disciplinary and/or legal action as appropriate.

This policy is intended to confirm that the Company is in compliance with existing legal provisions requiring employers to provide a safe workplace. I t is not intended to create obligations beyond those required by existing law.

2. Definitions
Workplace violence is any intentional conduct that is sufficiently severe, offensive, or intimidating to cause an individual to reasonably fear for his or her personal safety or the safety of his or her family, friends, and/or property such that employment conditions are altered or a hostile, abusive, or intimidating work environment is created. Workplace violence may involve any threats or acts of violence occurring on Company premises, regardless of the relationship between the Company and the parties involved. It also includes threats or acts of violence that affect the business interests of the Company or that may lead to an incident of violence on Company premises. Threats or acts of violence occurring of f Company premises that involve employees, agents, or individuals acting as a representative of the Company, whether as victims of or active participants in the conduct, may also constitute workplace violence. Specific examples include, but are not limited to, the following:
a. Threats or acts of physical or aggressive contact directed toward another individual;
b. Threats or acts of physical harm directed toward an individual or their family, friends, associates, or property;
c. The intentional destruction or threat of destruction of Company property or another employee's property;
d. Harassing or threatening phone calls, texts, or emails;

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e. Surveillance;
f. Stalking;
g. Veiled threats of physical harm or similar intimidation; and h. Any conduct resulting in the conviction under any criminal law relating to violence or threats of violence that adversely affects the Company's legitimate business interests.

Workplace violence does not refer to occasional comments of a socially acceptable nature. These comments may include references to legitimate sporting activities, popular entertainment, or current events . Rather, it refers to behavior that is personally offensive, threatening, or intimidating.

3. Enforcement
Anyone who engages in a threat or violent action on Company property may be removed from the premises as quickly as safety permits and may be required, at the Company's discretion, to remain off premises pending the outcome of an investigation of the incident.

When threats are made or acts of violence are committed by employee(s), a judgment will be made by the Company as to what actions are appropriate, including possible disciplinary action.

Once a threat has been substantiated, it is the Company's policy to put the threat maker on notice that they will be held accountable for their actions and then implement a decisive and appropriate response.

Under this policy, decisions may be needed to prevent a threat from being carried out, a violent act from occurring, or a life -threatening situation from developing. No existing policy or procedure of the Company should be interpreted in a manner that prevents the making of these necessary decisions.

The Company may undertake a case-by-case analysis to ascertain whether there is a reasonable basis to believe that workplace violence has occurred.

Employees who violate this policy, who engage in or contribute to violent behavior, or who threaten others with violence may be subject to disciplinary action, up to and including termination. No provision of this policy shall alter the at-will nature of employment at the Company.

B. Policy Regarding Violent Crime
You should make a conscious effort to observe your surroundings and report any suspicious persons or activities to the police. In the unfortunate event of a holdup or robbery, you should consider obeying the orders issued by the perpetrator. Failure to follow the perpetrator's orders may jeopardize your safety as well as the safety of passengers and other employees. Therefore, try to stay calm, move slowly, and cooperate with the perpetrator. Do not argue, fight, display a weapon, or offer other form of resistance. To the extent possible, employees should attempt to concentrate on the

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perpetrator's physical features, dress, voice, automobile, et cetera in hope of later identification.

Once the incident is over, you should remain where you are--do not attempt to follow or catch the perpetrator. Once you are certain that the perpetrator has left the immediate area, quickly secure the area and call the police. While waiting for the police to arrive, avoid touching anything or disturbing the area. If possible, write down everything you can remember about the incident and the perpetrator. Employees are expected to cooperate fully with the enforcement authorities after the occurrence of an incident.

C. Health and Safety
The Company strives to attain the highest possible level of safety in all activities and operations. The Company also makes efforts to comply with all health and safety laws applicable to our business.

To this end, the C ompany must rely on employees to ensure that work areas are kept safe and free of hazardous conditions. Employees should be conscientious about workplace safety, including proper operating methods and known dangerous conditions or hazards. You should report any unsafe conditions or potential hazards to your supervisor or the Safety Manager immediately, even if you believe you have corrected the problem. If you suspect a concealed danger is present on the Company's premises, or in a piece of equipment, process, or business practice for which the Company is responsible, bring it to the attention of your supervisor immediately. The Company will arrange for the correction of any unsafe condition or concealed danger immediately.

Periodically, the Company may issue rules and guidelines governing workplace safety and health. All employees should familiarize themselves with these rules and guidelines as strict compliance will be expected. Contact your supervisor for copies of current rules and guidelines for your department. Failure to comply strictly with rules and guidelines regarding health and safety or negligent work performance that endangers health and safety will not be tolerated.

Any workplace injury, accident, or illness must be reported to your supervisor and/or the Risk Manager as soon as possible, regardless of the severity of the injury or accident. If medical attention is required immediately, the Company will assist employees in obtaining medical care, after which the details of the injury or accident must be reported.

Employees must understand that compliance with safety requirements is a condition of employment and will be evaluated, together with other aspects of an employee’s performance. It is essential that all employees comply fully with the standards and practices of the Company that are designed to promote a safe and healthful working environment. As part of our policy, the Company has established programs to help employees avoid dangerous and unhealthful conditions and to remedy problems or hazards before they cause accidents or injuries.

D. Voice Mail, E-Mail, Text Messages and Computer Files Company-provided e-mail, text messaging systems and computers are to be used for business purposes only and may not be used for personal business. These systems are maintained by the Company in order to facilitate Company business. Therefore, all messages sent, received, composed and/or stored on these systems are the sole

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property of the Company , and employees should have no anticipation of privacy when using company equipment.

E. Right To Monitor Employees
In our ongoing effort to achieve the highest level of business efficiency and customer service, the Company reserves the right to observe employees throughout the Company's premises, either by way of direct observation or through the use of electronic devices. The Company may install video cameras to monitor Company premises and/or other generally open areas where employees may be seen by others. Therefore, employees should have no anticipation of privacy in the workplace, with the exception of restrooms.

F. Use Of Equipment
Company-owned equipment is expensive and may be difficult to replace. When using equipment, employees are expected to exercise care, perform required maintenance, and follow all operating instructions, safety standards and guidelines. At no time is Company-owned equipment to be used for personal purposes. No Company -owned equipment may be removed from the premises without written authorization from the Company.

Questions about the responsibility to maintain and care for equipment should be directed to your supervisor or manager.

Employees should immediately notify their supervisor or manager if any equipment, machine, or tool appears to be damaged, defective or in need of repair. Prompt reporting of damage, defects and wear can prevent deterioration of equipment and avoid possible injury to the employee and others.

The negligent, careless or unsafe use of Company equipment may result in discipline, up to and including termination.

G. Safe Operation Of Vehicles
Drivers of Company vehicles are responsible for the safe operation and cleanliness of the vehicle. Accidents and incidents involving a Company vehicle must be immediately reported to a supervisor or manager. Failure to immediately report an accident or incident will result in disciplinary action, up to and including termination. Seat belts must be worn by all drivers at all times driving Company vehicles.

Employees must exercise good judgment and safe driving practices at all times, including avoiding any activity which may distract their attention from the road or violate any law. Such activity includes speeding or other reckless driving, ingesting alcoholic beverages or drugs, and use of a cell phone while operating a vehicle.

Employees driving their own personal vehicles while conducting Company business should promptly submit an expense report detailing the number of miles driven on Company business. The Company will pay mileage. In the course of such operation, a valid driver’s license and proof of current insurance must be in your possession.

Employees are expected to observe all Company policies while on Company business,

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even if driving their own personal vehicles. Employees are prohibited from using Company vehicles for personal use.

Employees who violate this policy are subject to disciplinary action, up to and including termination.

H. Employee Property
Employees should not bring valuables to work. The Company assumes no responsibility for the loss, theft, or damage of employees' personal property.

I. Employee Parking
The Company provides parking for staff on the premises but employees are cautioned to park at their own risk. The Company shall assume no responsibility for any loss, theft, or damage to an employee’s vehicle. Please be courteous to the vehicles already parked and please be mindful of the speed limit (5mph) in the parking lot.

J. Visitors in the Workplace
To provide for the safety and security of employees and the Company facility, employees may not have visitors in the workplace. Restricting visitors helps maintain safety standards, protects against theft, ensures security of equipment, protects confidential information, safeguards employee welfare and avoids potential distractions and disturbances.

Non-staff personnel and children of staff members are not allowed to be on the premises with an employee while employee is working.

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Section XIII Benefits
A. Holidays
The Company observes the following holidays: New Year's Day, Memorial Day, Fourth of July, Labor Day, Thanksgiving Day, and Christmas Day.

If one of the above holidays falls on a day an employee’s contract system is normally closed and the client observes the holiday by closing a different day, the day the client is closed will be considered the employee’s holiday. If the client’s system does not close for the holiday, the employee must work their regularly scheduled shift and will be paid one and a half (1½) times their normal hourly rate. If the client’s system observes holidays other than or in addition to those listed above, the employee will not be paid for the additional days off, but may use any accrued, unused Personal Time Off during this time.

Non-exempt employees in the orientation period are not eligible for holiday pay. Eligible employees will only receive holiday pay if the holiday falls on their regularly scheduled workday.

Eligible, exempt employees receive their regular salary on any recognized holidays .

Eligible, full- time non- exempt employees will receive their regular straight time hourly wage rate for the number of hours that they are regularly scheduled to work on the day a holiday is observed by the Company and management offices are closed. Part -time and temporary employees, and employees on a leave of absence, are not eligible for holiday pay. To be eligible for holiday pay, you must work the last scheduled day immediately preceding and the first scheduled day following the holiday, unless a written request for time off is submitted and approved by the Company prior to the holiday. In the event of illness and with written approval from the Company, this rule will be suspended contingent on the employee’s submission of a certificate from a health care provider.

Employees on leave of absence are ineligible for holiday benefits for holidays observed during the period they are on leave of absence.

B. Personal Time Off

1. Non-Exempt Employees
Personal Time Off ( “PTO”) for non -exempt employees will accrue on a weekly basis at the rate of 0.8 hours per week for those employees who get paid for at least 35 hours in a given week. For example, if an employee works 28 hours in a week and uses at least 7 hours of accrued PTO and/or sick leave hours to reach the thirty five (35) hour threshold, 0.8 hours of PTO will be added to the employee’s PTO bank. However, if an employee has exhausted their accrued PTO and/or sick leave hours and works less than 35 hours in a week, P TO will not accrue for that week.

Employees are eligible to accrue PTO after completing 9 0 days of continuous employment from their date of hire.

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Earned PTO accrues to a maximum of one and one- half (1½) times the annual accrual rate. Once the maximum accrual amount has been reached, no additional PTO will be earned until previously accrued PTO is used. You will not be given retroactive credit for any period of time in which you did not accrue PTO because you were at the maximum. At y ear-end, unused PTO at or below the maximum accrual amount will carry over to the subsequent year.

2. Exempt Employees
PTO for exempt employees will accrue on a weekly basis at the rate of 1.55 hours per week for those employees who have worked for the Company three (3) consecutive years or less, and at the rate of 2.04 hours per week for those employees who have worked for the Company for more than three (3) years.

Employees are eligible to accrue PTO after completing 90 days of continuous employment from their date of hire.

Earned PTO accrues to a maximum of one and one- half (1½) times the annual accrual rate. Once the maximum accrual amount has been reached, no additional PTO will be earned until previously accrued PTO is used. You will not be given retroactive credit for any period of time in which you did not accrue PTO because you were at the maximum. At year -end, unused PTO at or below the maximum accrual amount will carry over to the subsequent year.

3. Use of PTO

PTO may be used for any purpose, including illness or injury, medical or dental appointments, vacation, care for a family member, or other reasons. Employees are not eligible to take PTO until it is earned and they have completed 90 days of employment from their anniversary date. Employees are encouraged to take their accrued PTO each year. Employees will be paid for all accrued unused PTO on termination of employment. Employees who have worked for the company for 2 consecutive years may receive one- half of their yearly PTO accrual in pay at the time they take PTO time off of not less than three days.

Employees should submit written requests for PTO to their supervisor at least two (2) weeks in advance. In the event of illness or an emergency, employees must contact their supervisor as soon as possible and in no event less than two (2) hours prior to their start time. The Company encourages employees to request PTO in increments of at least one (1) regularly scheduled workday. PTO will be scheduled so as to provide adequate coverage of job and staff requirements. The Company will make the final determination in this regard.

Therefore, the Company may elect to deny PTO in its discretion.

PTO does not accrue during unpaid leaves of absence or other periods of inactive service, except where required by law.

Exempt employees must use PTO for otherwise unexcused absences from work for a day or more. Exempt employees must also use PTO for absences of four (4) or more hours in a work day when taking personal time off. Exempt employees are prohibited from doing
any work while taking PTO, including but
not limited to checking voicemail, checking email and text messaging.

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If you are eligible for a partial wage replacement by the state under the state's Paid Family Leave program (PFL), the Company may require that y ou take accrued but unused PTO leave prior to your initial receipt of these benefits.

C. Paid Sick Leave
Employees who meet the eligibility service requirements as specified by applicable law are eligible for paid sick leave benefits during each year of employment. New employees who have worked for 30 or more work days within a year from the beginning of their employment are eligible to receive paid sick leave benefits.

1. Non-Exempt Employees
Beginning with their date of hire, eligible employees will accrue 1 hour of sick leave per work week until a total of 30 hours of sick leave have been accrued for use after they have completed the eligibility service requirements. Thereafter, during each year of employment, beginning on the employee’s anniversary date, eligible employees will accrue 1 hour of sick leave per week until a total of 30 hours of sick leave have been accrued per anniversary year. Employees who do not meet the eligibility service requirements are not eligible for sick leave benefits.

For non-exempt employees, paid sick leave accrual will cap at sixty (60) hours, with a usage cap of thirty (30) hours per anniversary year.

2. Exempt Employees
Beginning with their date of hire, eligible exempt employees will accrue 1 hour of sick leave per work week until a total of 3 days (24) hours of sick leave have been accrued, for use during their first year of employment after they have completed the eligibility service requirements. Thereafter, during each year of employment, beginning on the employee’s anniversary date, eligible employees will accrue 1 hour of sick leave per work week until a total of 3 days (24 hours) of sick leave have been accrued.

For exempt employees, paid sick leave accrual will cap at forty-eight (48) hours, with a usage cap of twenty-four (24) hours per anniversary year.

3. Use of Paid Sick Leave
Non-exempt employees may only use thirty (30) hours of paid sick leave per year, and exempt employees may only use twenty-four (24) hours of sick leave per year. Newly hired eligible employees may start using their earned sick leave benefits beginning on the 90th day of employment. Last minute unscheduled time off (“calling in sick”) disrupts business operations, creates scheduling issues, and should be avoided. For a non-emergency reason or for a foreseeable situation, employees are to provide reasonable advance notification to their Supervisor preferably with one week’s notice but at least one workday (24 hours) advance notice of a need for paid sick leave. For an emergency situation that is unforeseeable, employees are to notify their Supervisor of an intended absence at least two (2) hours before their scheduled shift or workday begins or as soon

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as practicable. Employees are to use their available paid sick leave benefits in minimum increments of two (2) hours.

Sick leave is to be used only for absences due to illness, incapacity due to injury, and appointments with, or treatment by, a health care provider involving the employee, or the employee’s child, parent, spouse or registered domestic partner, or the child of the registered domestic partner, the employee’s sibling, grandparent or grandchild. Paid sick leave may also be used by an employee who is a victim of domestic violence, sexual assault or stalking as specified by applicable law. All sick leave payments will be based on an employee’s regular pay rate in effect at the time such payments are made. Sick leave will be paid on the payday for the next regular payroll period after the sick leave was taken. Sick leave payments also would be coordinated with state disability/paid family leave or workers’ compensation insurance benefit payments so that all such payments will not exceed the employee’s normal weekly gross earnings.

The purpose for sick leave benefits is to provide salary or wage continuation to eligible employees who are absent due to illness or injury. Employees should conserve their sick leave bank in case of an unexpected illness or injury. Sick leave is not to be abused or misused. Sick leave benefits are not earned during any leaves of absence until the employee returns to work.

Full or partial days off due to illness or injury in excess of available sick leave by non-exempt employees will be taken without pay. Exempt employees who have used all of their available sick leave benefits continue to receive their salary for an occasional illness that is less than a full day under this sick leave policy.

However, the salary of exempt employees who have exhausted their sick leave allowance may be deducted for absences of a full day or more due to illness or disability.

Available and unused sick leave may
not be used for personal time-off (other
than for an absence due to illness, medical appointments or another qualifying reason as specified by applicable law), additional vacation time or in conjunction with other types of days off. If all available sick leave benefits have been used and your Supervisor has approved additional time off, employees may use available vacation benefits for the additional time off.

Employees who are absent for three (3) or more consecutive days due to illness or injury may be required to submit a physician’s statement to substantiate the absence. Further, the Company may require proof of illness, injury and/or a doctor or dental appointment in connection with any medically related absence of a shorter duration, including any absence taken on a day immediately prior to or immediately after a holiday or weekend, in order to verify the absence under this policy. Use of sick leave will be allowed, however, with or without submission of a physician’s statement. In addition, before an employee may return to work, the Company may require a doctor’s written verification stating that the employee is capable of resuming his or her job essential job functions. A misrepresentation regarding the need to take sick leave for a purpose other than for a qualifying reason as specified by applicable law may be subject to appropriate disciplinary action.

Unused sick leave will carry over to the following year. Unused sick leave benefits have no cash value upon termination of employment for any reason.

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There is no pay out of unused sick days upon termination of employment for any reason or at any time during employment.

D. Medical, Dental and Vision Insurance
For purposes of health benefits, regular full -time employees are those who work at least 30 hours per week and who have completed (1) a 30 -day orientation period after the date of hire, and (2) a 30- day waiting period immediately thereafter. Such employees are eligible for medical, dental, and vision insurance as of the first of the month following the 30-day waiting period.

The Company pays a percentage of the basic medical insurance premium for employees only. Any modifications or enhanced benefits are paid by the employee, including adding additional family members. The Company does not pay any part of the dental or vision insurance premiums. Employees should consult the Summary Plan Description for more complete information about eligibility and the details of the Company's insurance plans. Copies of the Plan Document and Summary Plan Description are available from Human Resources or your manager. The Plan Documents are controlling.

Except in the case of a qualifying event, employees may only modify their insurance coverage during the initial enrollment period and during open enrollment if the pre- tax premium deduction option was elected. Qualifying events include marriage or divorce, creation or dissolution of a domestic partnership, death of a spouse/domestic partner or child, birth or adoption of a child, or termination of a spouse’s/domestic partner’s employment or other loss of coverage. Ability to make modifications is governed by state and federal law, and by the applicable policy documents. Employees electing the post-tax option for their premium deductions may cancel their coverage at any time.

The Company reserves the right to change, amend or discontinue the medical, dental and vision benefits it offers to its employees at any time, including payment of the premium for an eligible employee’s coverage. The Company’s right to make these changes is not limited by an employee’s length of service, or by an employee’s reliance on the availability of these benefits in deciding whether to accept, continue or retire from employment with the Company.

E. 401K Plan
The Company provides a 401k Plan as a way for employees to defer their pre-tax dollars and save for retirement. Employees are eligible from date of hire to enroll and make elections for deferrals. Deferrals may be made in a flat amount election or a % of eligible pay.

Deferrals will begin on the next quarterly entry date. Quarterly entry dates are January 1 st, April 1st, July 1st and October 1st.

Employees may rollover funds from other qualified plans and IRA’s.

Additional information and enrollment instructions are available from the Human Resources Department or your supervisor.

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F. Workers' Compensation
The Company provides a comprehensive workers’ compensation insurance program at no cost to employees. This program covers injuries or illnesses sustained in the course of employment that require medical, surgical or hospital treatment. Subject to applicable legal requirements, workers’ compensation insurance provides benefits after a short waiting period or, if the employee is hospitalized, immediately.

Employees who sustain work -related injuries or illnesses should inform their supervisor or manager immediately, no matter how minor an on-the-job injury may appear. This will enable an eligible employee to qualify for coverage as quickly as possible. Failure to timely report an injury may jeopardize an employee’s right to certain benefits. Note that all employees who report a work -related injury or illness are subject to post -injury drug and alcohol testing.

Neither the Company nor the insurance carrier will be liable for the payment of workers’ compensation benefits for injuries that occur during an employee’s voluntary participation in any off-duty recreational, social or athletic activity. The Company will not take any adverse action against an employee for filing a workers’ compensation claim.

ALL EMPLOYEES SHOULD REMEMBER THAT WORKERS’ COMPENSATION

FRAUD IS A FELONY IN CALIFORNIA, PUNISHABLE BY IMPRISONMENT IN COUNTY JAIL OR BY FINES OR BOTH IMPRISONMENT AND FINE. THE COURT

MAY ORDER RESTITUTION AS WELL, INCLUDING RESTITUTION FOR ANY MEDICAL EVALUATION OR TREATMENT SERVICES OBTAINED OR PROVIDED.

COMPANY WILL TAKE ALL ACTION NECESSARY TO PROSECUTE CASES OF WORKERS’ COMPENSATION FRAUD.

G. Disability Insurance / Paid Family Leave
Employees are covered by California State Disability Insurance (SDI) and Paid Family Leave (PFL) pursuant to the California Unemployment Insurance Code. SDI insurance is payable when you cannot work because of illness or injury unrelated to your employment or when you are entitled to temporary workers' compensation at a rate less than the daily disability benefit amount. PFL provides a limited wage replacement when employees are unable to perform their regular customary work due to an absence to care for a sick child, parent, spouse or registered domestic partner, or for the birth, adoption, or foster care placement of a new child of the employee or of the registered domestic partner. There are limitations and eligibility requirements in the law. If you have questions about SDI or PFL, please see Human Resources. If you are eligible for a partial wage replacement by the state under the state's PFL program, the Company may require that you take up to two weeks of earned but unused PTO prior to your initi al receipt of these benefits.

Please note that PFL does not provide a separate right to a leave of absence. It is merely a state program that provides wage replacement.

H. Unemployment Insurance
If your employment terminates, you may be eligible to receive unemployment insurance benefits. In most cases, you must file a claim in order to collect this benefit. Should

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such a situation arise, you should inquire about unemployment insurance at the time of separation from service.

No action will be taken against any employee in any manner for testifying in an unemployment proceeding.

I. Social Security
All employees are covered by the Social Security law and are subject to taxes under the Federal Insurance Contribution Act (FICA). A deduction is made from your gros s earnings in accordance with the law as your contribution to Social Security. The Company contributes an amount equal to your deduction.

J. Post-Termination Continuance of Medical Insurance
The Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provides eligible individuals with the option to continue medical insurance coverage under the Company's policy, at their own expense and for a certain period of time, on the termination of employment as well as in other circumstances. For more in formation, please contact Human Resources.

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Section XIV Leave of Absence
A. General Provisions
The Company may grant a leave of absence in certain circumstances. You should notify your manager in writing at least 30 days in advance or as soon as you become aware you may need a leave of absence. The Company will consider your request in accordance with applicable law and the Company's leave policies. You will be notified whether your leave request is granted or denied. If you are granted leave, you must comply with the terms and conditions of the leave, including keeping in touch with the Company during your leave, and giving prompt notice if there is any change in your return date.

You must not accept other employment or apply for unemployment insurance while you are on a leave of absence. You must also not engage in conduct inconsistent with the reasons for taking a leave (e.g., seeking other employment or going on vacation).

Acceptance of other employment while on leave will be treated as a vo luntary resignation from employment at the Company. You must remain in contact with the Company during your leave to advise of any change of circumstances. Benefits, such as PTO and paid holidays do not accrue while you are on a leave of absence.

If you would like to continue your medical, dental or vision insurance coverage during your leave, with the exception of leaves that provide for continuation pursuant to applicable law, you may continue coverage by paying the full amount of the premiums under the provisions of COBRA. Human Resources can give you additional information on this subject.

Depending on the type of leave, you will be required to use accrued PTO concurrently with an unpaid leave of absence. Any PTO payments will be coordinated with any payments under California State Disability Insurance, California Paid Family Leave, workers' compensation, or other wage reimbursement benefits for which you may be eligible so that at no time will you be paid more than your regular compensation.

Seniority shall not accrue during any leave of absence, and PTO shall not accrue during any leave of absence. The Company may hold in abeyance or proceed with any counseling, performance review, or disciplinary action, including discharge, that was contemplated prior to any employee's request for or receipt of a leave of absence or that has come to the Company's attention during the leave. If any action is held in abeyance during the leave of absence, the Company reserves the right to proceed with the action on the employee's return. Requesting or receiving a leave of absence in no way relieves employees of their obligation while on the job to perform their job responsibilities capably and to the Company's expectations, and to observe all Company policies, rul es and procedures.

An employee who is ready to return to work from a leave of absence related to a medical illness or condition, work injury, disability, or pregnancy must submit a medical release to the Company verifying his or her fitness or ability to resume work at least 7 calendar days prior to the expected date of return to work. The Company reserves the right to require, at the Company’s expense, a fitness for duty examination to ensure the employee is capable of performing the essential functions of his job. Family and Medical Leave

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B. Family and Medical Leave
The Company has adopted the following policy to implement the terms of the federal Family and Medical Leave Act (FMLA) and California Family Rights Act (CFRA). Eligible employees are entitled to FMLA/CFRA leave on the terms and conditions stated below.

1. Eligibility
To be eligible for FMLA/CFRA, an employee must have worked for the Company for at least 12 months and have completed at least 1,250 hours in the 12 calendar months prior to the commencement of the leave. Employees must also work at a location where there are at least 50 employees on- site or within a 75- mile radius.

2. Reasons for Leave
Eligible employees may take up to 12 weeks of unpaid family and medical leave within a 12-month period for any of the following reasons:
a. The birth of a child and to bond with or provide care for such child. b. The placement of a child with you for adoption or foster care and to bond with or care for the new child.
c. To care for a parent, child, spouse or registered domestic partner with a serious health condition.
d. For your own serious health condition that renders you unable to perform the functions of your position.
e. Eligible employees with a spouse, registered domestic partner, son, daughter, or parent on active duty or call to active duty status in the National Guard or Reserves in support of a contingency operation may use their 12- week FMLA leave entitlement to address certain qualifying exigencies.

Qualifying exigencies may include activities such as attending military events, arranging for alternative childcare, making financial and legal arrangements, attending counseling sessions, rest and recuperation, and post -deployment briefings.
f. Eligible employees may take up to 26 weeks of FMLA leave to care for a covered service member during a single 12-month period. A covered service member is a current member of the Armed Forces, including a member of the National Guard or Reserves, who has a serious injury or illness incurred in the line of duty on active duty that may render the service member medically unfit to perform his or her duties for which the service member is undergoing medical treatment, recuperation, or therapy; or is in outpatient status; or is on the temporary disability retired list.

A “serious health condition,” as specified above, is an illness, injury impairment or physical or mental condition that involves either an overnight stay in a medical care facility, or continuing treatment by a health care provider for a condition that either prevents the employee from performing the functions of the employee’s

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job, or prevents the qualified family member from participating in school or other daily activities. Subject to certain conditions, the continuing treatment requirement includes an incapacity of more than three full calendar days and two visits to a health care provider or one visit to a health care provider and a continuing regiment of care; an incapacity caused by pregnancy or prenatal visits, a chronic condition, or permanent or long -term conditions; or absences due to multiple treatments. Other situations may meet the definition of continuing treatment.

Leave for either of the first two reasons listed above must be completed within the 12-month period beginning on the date of birth or placement. In addition, in cases where the Company employs both parents, they may take a maximum combined total of 12 weeks’ leave during any 12-month period for the first two reasons.

3. Calculating the 12-Month Period
The Company uses a rolling method to calculate the 12- month period during which eligible employees may take up to 12 weeks of family and medical leave.

4. Pregnancy, Childbirth and Related Conditions
While pregnancy and prenatal care are included in the definition of “serious health condition” under the FMLA, they are not covered under the leave provisions of the CFRA. If you take leave for pregnancy disability (up to four months, as certified by your healthcare provider) and are also eligible for family and medical leave, your FMLA -protected leave will run concurrently with your pregnancy disability leave (see Pregnancy Disability Leave policy below). Once you are no longer disabled by pregnancy/childbirth, you may apply for up to 12 weeks of leave under the CFRA to bond with your newborn.

5. Notice of Leave
If your need for FMLA leave is foreseeable, you must give the Company at least 30 days’ prior written notice. If this is not possible, you must give notice as soon as practicable and you must comply with the Company’s usual and customary notice and procedural requirements for requesting leave, absent unusual circumstances. Failure to provide such notice may be grounds for delay of leave.

Additionally, if you are planning a medical treatment, you must consult with your supervisor or manager regarding the dates of such treatment in order to minimize disruption to the Company’s operations.

If your need for leave is not foreseeable, you must notify the Company as soon as practicable under the facts and circumstances of your situation.

When providing notice, you must include sufficient information for the Company to determine if the leave qualifies for FMLA/CFRA protection and the anticipated timing a nd duration of the leave. Sufficient information may include that the employee is unable to perform essential job functions, the need for hospitalization or continuing treatment by a health care provider, or circumstances supporting the need for military family leave.

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6. Certification
The Company requires requests for FMLA/CFRA be supported by a medical or other certification. When you request leave, the Company will notify you of the requirement for certification and when it is due. If you are unable to obtain the certification due to reasons beyond your control, notify the Company as soon as possible. Failure to provide requested certification in a timely manner may result in delay of leave until required documentation is provided.

A request for leave because of your own serious health condition or to care for a family member with a serious health condition must be supported by a medical certification from a healthcare provider. The medical certification must include the following information:
a. The name, address, telephone number and fax number of the healthcare provider and type of medical practice/specialization;
b. The approximate date on which the serious health condition commenced, and its probable duration;
c. The healthcare provider’s statement documenting the need for leave; d. If you are the patient, a statement from the healthcare provider establishing that you are unable to work at all or perform any one or more of the essential functions of your position due to the serious health condition;
e. If the patient is a covered family member with a serious health condition, confirmation that the family member is in need of care.

The Company, at its expense, may require an examination by a second healthcare provider designated by the Company i f it has a question about the validity of the medical certification initially provided. If the second healthcare provider’s opinion conflicts with the original certification, the Company, at its expense, may require a third, mutually agreed on, healthcare provider to conduct an examination and provide a final and binding opinion.

The Company may require updated medical recertification for additional leave, even if taken for the same medical condition. Failure to timely provide the requested certification, except where it is not practical under the circumstances, may result in delay of further leave until the certification is provided.

7. Medical and Other Benefits
During an approved FMLA/CFRA, the Company will maintain your health benefits as if you continued to be actively employed. If paid leave is substituted for unpaid family and medical leave, the Company will deduct your portion of the health plan premium as a regular payroll deduction. If your leave is unpaid, you must pay your portion of the premium. If yo u miss a premium payment, y our healthcare coverage will cease a t the end of the month in which your last full premium payment was paid.

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Employees are required to use any accrued, unused PTO or Sick Leave benefits during any leave of absence under the FMLA/CFRA, with the exception of leaves qualifying as a pregnancy disability leave, or where the employee is receiving wage replacement benefits due to a work related injury or through a disability benefits plan. In those circumstances, employees may choose to use PTO or Sick Leave benefits, but in no instance shall the sum of wage replacement and PTO/sick leave benefits exceed 100% of the employee’s regular full-time wages.

8. Intermittent and Reduced-Schedule Leave
Leave because of a serious health condition or military caregiver leave may be taken intermittently or on a reduced- leave schedule if medically necessary and if proper certification is obtained. Qualifying exigency leave may also be taken intermittently or on a reduced-leave schedule.

Leave for bonding or the care of a new child must be taken in blocks of at least two weeks, but an employee is allowed to take leave of less than two weeks twice during the one year eligibility period following birth. The leave can be taken in one lump sum. A schedule must be discussed with your supervisor.

9. Reinstatement
Employees returning from FMLA/CFRA leave will be restored to the original or an equivalent position. However, you will not be entitled to any greater right to reinstatement than if you had been employed continuously rather than on leave.

For example, if you would have been laid off if you had not gone on leave, then you will not be entitled to reinstatement. Similarly, if your position has been filled in order to avoid undermining the Company’s ability to operate safely and efficiently while you were on leave, and there is no equivalent position avail able, then reinstatement may be denied.

As a condition of restoring the employee whose leave was occasioned by the employee’s own serious health condition that made the employee unable to perform the employee’s job, the Company requires the employee to obtain and present certification from the employee’s health care provider that the employee is able to resume work.

C. Pregnancy Disability Leave
The Company will grant an unpaid pregnancy disability leave if you are disabled because of your pregnancy, childbirth, or a related medical condition. If you are disabled due to pregnancy, childbirth, or a related medical condition, you may take up to a maximum of four (4) months ( 17 1/3 workweeks for a full -time employee) leave. As an alternative, the Company may transfer you to a less strenuous or hazardous position if you so request, with the advice of your physician, and if the transfer can be reasonably accommodated. If a reasonable accommodation cannot be agreed upon, the Company will request that you become temporarily disabled and your leave status will begin. If an employee requests additional leave after the expiration of the 4 month pregnancy disability leave, the Company will engage in an interactive process with the employee to determine whether the request can be accommodated. Pregnancy disability leave may be taken intermittently or on a reduced work schedule when medically advisable as determined by the employee’s physician.

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If possible, you must provide at least thirty (30) days advance notice for foreseeable events (such as the expected birth of a child or a planned medical treatment for yourself or of a family member). For events which are unforeseeable, you must notify Human Resources at least verbally, as soon as you learn of the need for the leave. Failure to comply with these notice rules is grounds for, and may result in, deferral of the requested leave until you comply with this notice policy. In addition, you must provide the Company with a health care provider's statement certifying the last day you can work and the expected duration of your leave.

Pregnancy disability leaves are without pay. However, you may also utilize accrued PTO or sick leave during the leave. All of those payments will be integrated with any state disability or other wage reimbursement benefits that you may receive. At no time will you receive more than your regular compensation. The Company will continue to maintain and pay for the employee’s group health insurance under the same terms and conditions as if the employee has remained actively employed during the duration of her pregnancy disability leave. The employee is required to continue to pay her por tion of the required monthly insurance premiums, if any, during the leave. You should contact Human Resources for further information.

On the submission of a medical certification from a health care provider that you are able to return to work, you will, in most circumstances, be offered the same position held at the time of the leave or an equivalent position. Employees failing to return on the assigned date may be considered to have voluntarily resigned. However, in the event the Company has to layoff employees due to economic or other business reasons, a pregnant employee will have no greater right to reinstatement than any other Company employee. If the original position is not available due to legitimate business reasons, the employee will be offered any comparable positions for which they are qualified that become available within 60 (sixty) days of their request to return. If no comparable positions become available, the employee will be permanently laid off. If, on return from a pregnancy disability leave you are unable to perform the essential functions of the job because of a physical or mental disability, the Company will attempt to accommodate you.

As a condition of this leave, you must not engage in any conduct inconsistent with the reasons you were granted leave in the first place. You must also maintain periodic contact with the Company to advise as to any change in status.

D. Military Leave (Active And Reserve Service)
Leave without pay is provided to employees who enter military service. This includes the Army, Navy, Air Force, Marine Corps, Coast Guard (and the Reserves for each of those branches), Army National Guard, Air National Guard, commissioned corps of the Public Health Service, and any other category of persons designated by the President in time of war or emergency. Employees returning from military leave are afforded reemployment ri ghts and retain full seniority benefits for all prior service on reemployment in accordance with the Uniformed Services Employment and Reem - ployment Rights Act (USERRA) and the California Military and Veterans Code.

Employees should submit military service orders to the Company for review prior to commencement of the leave. If the uniformed service is for 30 or fewer days, health benefits will continue in the same manner as prior to leave. For service beyond 30 days,

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the law provides COBRA -like continuation benefits. See Human Resources for more information on military leave of absence.

E. Leave for Spouse/Registered Domestic Partners of Those in the Military
Employees who work an average of 20 or more hours per week and who are spouses or registered domestic partners of those in the Armed Forces, National Guard or Reserves are entitled to take up to ten (10) days of unpaid leave when the spouse or registered domestic partner is on leave from deployment during a period of military conflict. The term “period of military conflict” means either of the following:

1. A period of war declared by the Congress; or

2. A period of deployment for which a member of a reserve component is ordered to active duty as that term is defined by law.

To be qualified for leave, employees must provide notice to the Company within two (2) business days of receiving official notice that the spouse or registered domestic partner will be on leave from deployment. Employees must also submit written documentation certifying the leave.

F. Bereavement Time Off
Full-time employees who have completed ninety (90) days of continuous employment are eligible for two (2) days of paid bereavement leave following the death of the employee’s current spouse, current registered domestic partner, parent, grandparent, child, grandchild or sibling. Each day of pay shall be equivalent to pay for the hours the employee was regularly scheduled to have worked. No pay will be provided for days the employee was not regularly scheduled to work.

Employees should notify their supervisor or manager of the need for the leave immediately. Bereavement leave will normally be granted unless there are unusual business needs or staffing requirements. Employees may, with the Company’s approval, use any available PTO for additional time off as necessary. The Company reserves the right to request documentation supporting a request for bereavement leave.

Employees in the orientation period are ineligible for paid bereavement leave.

G. Civic Duty Time Off
The Company encourages employees to serve on jury or witness duty when called.

Employees must notify their supervisor of the need for time off for jury or witness duty as soon as a notice or summons from the court or a subpoena is received.

If you are summoned for jury duty service, the Company will pay you the difference between your jury duty pay and the wages for hours you were scheduled to work, up to five (5) regularly scheduled workdays per year. Any additional time is without pay.

However, employees must use any accrued, unused PTO.

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Verification from the court clerk of having served may be required, and employees will be expected to report or return to work for the remainder of their work schedule on any day they are dismissed from jury or witness duty.

H. Leave for Victims of Domestic Violence, Stalking and Sexual Assault
The Company understands that if an employee is the unfortunate victim of domestic violence, stalking, or sexual assault, the employee may need to take time from work to appear in court in an effort to obtain relief from such violence. It also understands that you may need to take time off to obtain medical attention, to obtain services from a shelter, program, or rape crisis center, to obtain psychological counseling, or to participate in safety planning as a result of domestic violence, stalking or sexual assault.

If you need time off to obtain relief from domestic violence, stalking, or sexual assault, you must give your supervisor or manager reasonable notice that you need time off for this purpose. If you need time off immediately or for an emergency, advance notice is not required, but you may be required to provide documentation or certification of the purpose of your absence within a reasonable time after your time off.

Time off is unpaid. However, employees must use any accrued, unused PTO, and may use sick leave. On the days off from work to obtain relief from domestic violence or sexual assault, the employee will be expected to return to work for the remainder of their work schedule if time permits.

I. Victims of Crime
An employee may be absent from work to attend judicial proceedings related to crime, if (i) the employee is a victim of a crime; (ii) the employee’s immediate family member is a victim of a crime; (iii) the employee’s registered domestic partner is a victim of a crime; or (iv) the child of the employee’s registered domestic partner is a victim of a crime. The employee must give a copy of the notice for each scheduled proceeding that is provided to the victim by the agency responsible for giving notice. When advance notice is not feasible, or an unscheduled absence occurs, the employee must provide the documentation within a reasonable time after the absence.

Time off is without pay. However, employees must use any accrued, unused PTO.

After the appearance, the employee will be expected to return to work for the remainder of their work schedule, if time permits.

J. Voting Time
Because the Company has a continuing interest in encouraging responsible citizens hip, employees are urged to vote for candidates of their choice at local, state and national elections either before or after an employee's regular shift. In extreme cases, employees who do not have sufficient time outside their working hours within which to vote will be allowed to take up to two (2) hours of working time with pay for this purpose.

This time must be used at the beginning or end of the regular working shift, whicheve r allows the most free time for voting and the least time off from working, unless otherwise mutually agreed upon.

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To receive time off for voting, you must advise your supervisor you will need time off at least two (2) working days before election day, receive approval, and present a voter's receipt on your return.

K. Time Off to Attend School Activities
If you are a parent, guardian, or grandparent with custody of a child in kindergarten, grades 1-12, or a licensed day care facility and you wish to take time off to visit your child's school for a school activity, you may take off up to eight (8) hours per calendar month (up to a maximum of 40 hours per calendar year), per child, provided you give reasonable notice to your supervisor of your planned absence. The Company requires documentation from the school or licensed day care facility noting the date and time of your visit.

If both parents of a child work for the Company, only one parent --the first to provide notice--may take the time off, unless the Company approves both parents taking time off simultaneously.

You may also be granted time off to attend a school conference . Time off to attend school activities or a school conference is unpaid, however, employees must use any accrued PTO. Please contact your supervisor if time off may be needed for this reason.

L. Personal Leave of Absence
Under certain circumstances, employees may be granted a personal leave of absence.

Any accrued PTO must be used during this leave. The remainder of the leave will be without pay.

Requests for personal leave must be submitted to your supervisor in writing. The Company will only grant personal leave for compelling reasons and will take into account factors such as business needs and length of service. Personal leave will not, under any circumstances, be granted for the purpose of obtaining or performing work for another employer. Personal leave is granted at the sole discretion of the Company.

Personal leave shall not exceed one (1) month (30 calendar days) and may only be requested once a calendar year. PTO will run concurrently with the leave and count towards the 30 calendar day allotment. No benefits will accrue during personal leave.

Health benefits ordinarily provided by the Company will continue through the end of the month in which the 30
th day of absence occurs. Employees should contact the Human Resources Department prior to their leave to arrange for payment of continuing health benefits.

The Company will make reasonable efforts to return employees to the same or similar position held prior to the personal leave, subject to staffing and business requirements.

M. Organ Transplant and Bone Marrow Policy
The Company shall grant a paid leave up to thirty (30) business days to an employee who is an organ donor in any one year period for the purpose of donating his/her organ to another person. The one year period is measured from the date the leave begins and shall consist of 12 consecutive months.

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The Company shall grant a paid leave of up to five (5) business days to an employee who is a bone marrow donor in any one year period. The one year period is measured from the date the employee’s leave begins and shall consist of 12 consecutive months.

In order to receive a leave the employee shall provide written verification to the Company that he/she is an organ or bone marrow donor and that there is a medical necessity for the donation of the organ or bone marrow.

This leave is not a break in service. The Company will maintain health coverage for the duration of the leave in the same manner the coverage would have been maintained if the employee had been actively at work during the leave period.

The Company requires that if PTO is available that an employee take up to five days of earned unused PTO for bone marrow and up to two weeks of earned unused PTO for organ donation. Time not covered by PTO will be paid by the Company.

FMLA/CFRA will not run concurrently with this leave. The leave may be taken in one or more periods, but in no event shall exceed the amount of leave required by law. Upon expiration of an authorized leave, the Company will restore a donor to the position held by him/her when the leave began or to a position with equivalent seniority status, employee benefits, pay and other terms and conditions of employment. The Company may decline to restore an employee as required because of conditions unrelated to the rights under this leave.

The Company shall not interfere with, restrain, or deny the exercise or attempt to exercise a right established by this leave. The Company shall not discharge, fine, suspend, expel, discipline, or in any other manner discriminate against an employee who exercises a right provided under this leave and/or opposes a practice made unlawful by this leave.

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Section XV Separation From Employment
A. Resignation
If you decide to end your employment with the Company, the Company asks that you give at least two (2) weeks written notice, if possible. Employees occupying supervisor and management positions are requested to give at least four (4) weeks written notice.

This will give the Company the opportunity to make the necessary adjustments in its operations. Employees who do not provide the requested notice will be considered ineligible for rehire.

Please return all property owned by the Company prior to your departure.

Resigning employees will be asked to participate in an exit interview, during which the Company may solicit the employee for information on various subjects related to their employment and general employment conditions.

Employees who voluntarily resign and give at least 72 hours of notice will be given their final paycheck on their last day of employment. If an employee resigns without notice, the Company will have the employee’s final pay ready for the departing employee within 72 hours of the time that the employee first notified the Company of his or her resignation. The check will include any accrued unused PTO. The Company reserves the right to advance the employee’s separation date, and may pay the employee through the two-week notice period. This does not alter the nature of the voluntary resignation.

B. Involuntary Terminations
While the decision to commence employment is consensual, the same is not always true when the time comes to terminate the employment relationship. As an at -will employer, the Company reserves the right to end the employment relationship at any time, with or without cause or notice.

In the event your employment is terminated, you will be required to participate in an exit interview and you must return all Company property prior to your departure. Employees will be given their final paycheck, including all earned and unpaid wages and PTO, on their last day of employment.

C. Reductions in Force
While the Company hopes to continue growing and providing employment opportunities, business conditions, client demand, and other factors are unpredictable. Changes or downturns in any of these or other areas could create a need to restructure or reduce the number of people employed. In light of these uncertainties, please be advised that it may become necessary to conduct layoffs at some point in the future.

In the event the Company determines to lay off any employee or a number of employees, the Company retains full discretion to select which employee(s) will be laid off. While the Company retains full discretion, some of the relevant factors might include the Company's operational requirements and the skill, productivity, ability, and past performance of those involved, without regard to tenure.

- 56 - Employee Handbook – Rev. May 1, 2015
D. Exit Interview
In the case of both voluntary and involuntary terminations, you will be asked to participate in an exit interview, during which the Company may solicit the employee for information on various subjects related to their employment and general employment conditions within the Company.

E. Severance Compensation
The Company does not have a severance pay plan or policy.

F. References
All reference requests should be directed to Human Resources. No other employee is authorized to release references for a current or former employee.

In response to reference check inquiries, the Company will disclose only dates of employment and the title of the last position held. If an employee authorizes in writing, the Company will provide a prospective employer with information as to the last level of compensation. No further information will be provided.

- 57 - Employee Handbook – Rev. May 1, 2015
Receipt And Acknowledgment
This is to acknowledge I received a copy of Southland Transit, Inc.’s (“STI” or “the Company") Employee Handbook and understand it sets forth the terms and conditions of my employment as well as the duties, responsibilities, and obligations of employment with the Company. I understand and agree it is my responsibility to read the Employee Handbook and abide by the rules, policies, and standards set forth in the Employee Handbook. I understand and agree that I should consult Human Resources and/or my supervisor/project manager regarding any questions not answered in the Employee Handbook or if I am uncertain or unclear about anything relating to my employment. I understand I must comply with the policies and procedures contained in the Employee Handbook and any revisions made to it, and that if I fail to comply, I may be subject to disciplinary action, up to and including termination.

I have entered into my employment relationship with the Company voluntarily and acknowledge there is no promise of long-term employment and no specified length of employment. I also acknowledge that my employment with the Company is not for a specified period of time and can be terminated at any time for any reason, with or without cause or notice, by me or by the Company. I acknowledge that no oral or written statements or representations regarding my employment can alter the foregoing. I further acknowledge that no supervisor or employee has the authority to enter into an employment agreement--express or implied--providing for employment other than at will.

I acknowledge that, except for the policy of at -will employment, the Company reserves the right to revise, delete, and add to the provisions of this Employee Handbook. All such revisions, deletions, or additions must be in writing and must be signed by management. No oral statements or representations can change the provisions of this Employee Handbook. I also acknowledge that, except for the policy of at -will employment, terms and conditions of employment with the Company may be modified at the sole discretion of the Company, with or without cause or notice at any time.

No implied contract concerning any employment -related decision, term of employment, or condition of employment can be established by any other statement, conduct, policy, or practice.

I understand the foregoing agreement concerning my at-will employment status and the Company's right to determine and modify the terms and conditions of employment is the sole and entire agreement between me and the Company concerning the duration of my employment, the circumstances under which my employment may be terminated, and the circumstances under which the terms and conditions of my employment may change. I further understand this agreement supersedes all prior agreements, understandings, and representations concerning my employment with the Company.

I acknowledge that the Company’s property and technical resources, as discus sed in the Employee Handbook, belong to the Company and the Company therefore has the right to monitor, inspect and search all property and technical resources at any time. I hereby consent to the Company’s monitoring, inspection and search and I further acknowledge that I have no expectation of privacy in connection with my use of the Company’s property or technical resources.

My signature below certifies I understand this acknowledgement, my at -will status and the Company’s right to monitor.

Employee Signature Date

Employee Name [Printed]

EMPLOYEE COPY
Setting the Standard for Community
Transit in Southern California
Southland Transit Inc.

DRUG & ALCOHOL
POLICY
NOTE: Additional requirements and/or disciplinary actions established under STI authority are entered in bold-faced type. Requirements of the Drug-Free Workplace Act (not covered under Part 655) are in Italics.

Setting the Standard for Community Transit in Southern California 3650 Rockwell Avenue, El Monte, California 91731
626.258.1310 • Fax626.258.1329
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DRUG AND ALCOHOL POLICY
Southland Transit, Inc.

Revised October 2019
1 POLICY STATEMENT
Southland Transit, Inc. (STI) is dedicated to providing safe, dependable and efficient transportation services to our customers. We recognize that our safety-sensitive employees' and affiliate's use of illegal drugs and misuse of alcohol poses a significant risk to public safety, as well as the employee's and affiliate's health and well-being, and can cause loss of efficiency, productivity, or a disruptive work environment. In view of this, STI has adopted this policy that is designed to:

1.1 create a work environment free from the adverse effects of drug abuse and alcohol misuse;

1.2 deter and detect employees' and affiliates' use of illegal drugs and misuse of alcohol;

1.3 prohibit the unlawful manufacture, distribution, dispensation, possession, or use of controlled substances; and

1.4 encourage employees and affiliates to seek professional assistance anytime personal problems, including drug or alcohol dependency, adversely affect their ability to safely perform their assigned duties.
2 PURPOSE
The purpose of this policy is to assure worker fitness for duty and to protect our employees, affiliates, passengers, and the public from the safety and health risks posed by the misuse of alcohol and use of prohibited drugs. This policy also is intended to comply with all applicable State and Federal regulations governing workplace anti-drug use and alcohol misuse programs in the transportation industry. They include DOT 49 CFR Part 40, as amended ("Procedures for Transportation Workplace Drug and Alcohol Testing Programs"); FTA 49 CFR Part 655 as amended ("Prevention of Alcohol Misuse and Prohibited Drug Use in Transit Operations"): DOT 49 CFR Part 29 ("Drug-Free Workplace Act of 1988"); and CA Govt. Code Section 8350 et. seq. ("Drug-Free Workplace Act of 1990"). This policy incorporates the requirements of above regulations for safety-sensitive employees and others when so noted. 3 APPLICABILITY
Unless otherwise noted in specific provisions, this policy applies to all STI employees, including leased, part-time, or contract personnel. It applies to off-site lunch periods or breaks when an employee is scheduled to return to work or is on-call.

The application of this policy to non-safety-sensitive employees is under STl's own authority. Visitors, invitees, and vendors are also prohibited from entering the STI premises and from conducting any work on behalf of the company when illegal substances are present in their system, or the odor of alcohol is present on their breath. 21Page
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4 PREEMPTION OF STATE AND LOCAL LAWS
If any conflict occurs between State and local laws and any requirement of the above mentioned Federal regulations, the Federal regulations prevail. However, Federal regulations do not pre­ empt provisions of State criminal laws that impose sanctions for reckless conduct attributed to prohibited drug use or alcohol misuse, whether the provisions apply specifically to transportation employees, employers, or the public in general.
5 DEFINITIONS
Adulterated Specimen: A specimen that has been altered, as evidence by test results showing either a substance that is not a normal constituent for that type of specimen or showing an abnormal concentration of an endogenous substance.

Alcohol Use: The drinking or swallowing of any beverage, liquid mixture or preparation (including any medication) containing alcohol. For purposes of this policy, alcohol is alcohol regardless of source.

Alcohol Violation: Under STI authority the presence of alcohol in the body at a concentration of 0.02 or greater as measured by an EBT device.

Breath Alcohol Technician (BAT): An individual who instructs and assists employees or applicants in the alcohol testing process and operates an Evidential Breath Testing (EST) device.

Cancelled Test: A drug or alcohol test that has a problem identified that cannot be or has not been corrected, or which Part 40 requires to be cancelled. A cancelled test is neither a positive nor a negative test.

Collector: A person who instructs and assists individuals at a collection site, who receives and makes an initial inspection of the specimen provided by the individual, and who initiates and completes the Custody and Control Form (CCF).

Controlled Substances: Any drug classified by the U.S. Drug Enforcement Agency (DEA) into the five schedules or classes on the basis of their potential for abuse, accepted medical use, and accepted safety for use under medical supervision. Medications containing any controlled substance must be prescribed by a physician who has a valid DEA license number.

Designated Employer Representative: An employee or employees authorized by the company to take immediate action(s) to remove employees from safety-sensitive duties following a positive test, test refusal, or other policy violations.

Dilute Specimen: A urine specimen with creatinine and specific gravity values that are lower than expected for human urine.

Disabling Damage: Damage which precludes departure of a motor vehicle from the scene of the accident in its usual manner in daylight after simple repairs, including damage to motor vehicles that could have been driven, but would have been further damaged if so driven. "Disabling damage" does not include:
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• Damage, which can be remedied temporarily at the scene of the accident without special tools or parts.
• Tire disablement without other damage even if no spare tire is available. • Headlamp or taillight damage.
• Damage to turn Signals, horn, or windshield wipers, which may make them inoperative.

DHHS: Department of Health and Human Services.

DOT: Department of Transportation .

Drugs: The drugs for which tests are required under DOT and FTA regulations. They are Marijuana, cocaine, amphetamines, phencyclidine (PCP) and opioids.

Drug Abuse: Use of any illegal drug or controlled substance without a valid prescription, misuse of legally prescribed drugs, or use of illegally obtained prescription drugs. This includes use of prescription drugs legally prescribed to another individual.

Evidential Breath Testing Device (EBT) A device that is approved by the National Highway Traffic Safety Administration (NHTSA) for the evidential testing of breath at the .02 and .04 alcohol concentrations, and appears on ODAPC's Web page for "Approved Evidential Breath Measurement Devices" because it conforms with the model specifications available from NHTSA.

FTA: Federal Transit Administration .

Vehicle: A bus, electronic bus, van, automobile, rail car, trolley car, trolley bus or vessel.

Medical Review Officer (MRO}: A licensed physician (medical doctor or doctor of osteopathy) responsible for receiving laboratory drug test results, who has knowledge of substance abuse disorders, and has the appropriate medical training to interpret and evaluate an individual's confirmed drug and/or validity test results together with the individual's medical history and any other relevant biomedical information. (See Appendix B for a detailed discussion of the MRO's roles and responsibilities.)
Non-Negative Specimen: A urine specimen that is reported as adulterated, substituted, positive for drug(s) or drug metabolite(s), and/or invalid.

Positive Drug Test: The result reported by an HHS-certified laboratory when a specimen contains a drug or drug metabolites that is equal or greater than the cut off concentration.

Refusal to Test: Includes circumstances or behaviors such as:
• Failure to appear at the collection site in the time allotted. (Except for Pre-Employment Drug test.)
• Leaving the collection site before the testing process is completed . (Except in pre- employment testing when leaving before the test begins is not considered a test refusal). • Failure to provide a urine, breath, or saliva specimen as required by DOT Part 40. • Failure to permit the observation or monitoring of specimen collection when it is required. • Failure to provide a sufficient amount of urine or breath specimen without a valid medical explanation .
• Failure or refusal to take a second test when required by the collector or DER 41Page
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• Failure to undergo a medical evaluation when required by the MRO or the DER. • Failure to cooperate with any part of the testing process. (Example: refusal to empty pockets when directed by the collector; behave in a confrontational way that disrupts the collection process; fail to wash hands after being directed to do so by the collector.) For an observed collection , failure to follow the observer's instruction to raise clothing above the waist, lower clothing and underpants, and to turn around to permit the observer to determine if individual is wearing any type of prosthetic device that could be used to interfere with the collection process.
• Possession or wearing of a prosthetic or other device that could be used to interfere with the collection process.
• If the MRO reports a verified adulterated or substituted test result. • Admitting adulteration or substitution of the specimen to the collector or the MRO. • Leaving the scene of the accident without just cause prior to submitting to a drug and alcohol test when required.
• In alcohol testing, refusal to sign Step 2 of the Alcohol Testing Form (ATF).

NOTE: A REFUSAL TO TEST CARRIES THE SAME CONSEQUENCES AS A POSITIVE TEST RESULT.

Screening Test Technician (Sill: A person who instructs and assists employees in the alcohol testing process and operates an alcohol screening device, such as a breath or saliva device, other than an EST.

Specimen Validity Testing: A test used to determine if a urine specimen is adulterated, diluted, substituted, or invalid.

Split specimen: In drug testing , a part of the urine specimen that is sent to a first laboratory and retained unopened, and which is transported to a second DHHS-certified laboratory for testing upon employee request following a verified positive or a verified adulterated or substituted test result from the primary specimen.

Substance Abuse Professional (SAP): A person who evaluates employees who have violated a DOT drug and alcohol regulation and makes recommendations concerning education, treatment, follow-up testing, and aftercare.

A licensed physician (medical doctor or doctor of osteopathy) or a licensed or certified psychologist, social worker, employee assistance professional, state-licensed marriage and family therapist, or drug and alcohol counselor certified by an organization listed at https://www .transportat ion.gov/odapc/sap , with knowledge of and clinical experience in the diagnosis and treatment of alcohol and drug related disorders, knowledge about the SAP function as it relates to employer interests in safety-sensitive duties, and knowledge of the DOT agency regulations applicable to the employers for whom evaluations of employees are completed, and the DOT SAP Guidelines and who keeps current on any changes to these materials
Substituted specimen: A specimen with creatinine and specific gravity values that are so diminished or so divergent that they are not consistent with normal human urine.

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6 EDUCATION AND TRAINING
The education and ongoing awareness component of this policy will include display of posters, distribution to all employees of the drug and alcohol policy and other informational materials, and periodic information seminars.

As required by FTA regulations, the company will provide to all safety-sensitive employees a minimum of 60 minutes of training on the effects and consequences of prohibited drug use on personal health, safety, and the work environment, and on the signs and symptoms that may indicate prohibited drug use. Information on the signs, symptoms, health effects and consequences of alcohol misuse is presented as Appendix A of this policy.

Supervisors who may make reasonable suspicion referrals shall receive a minimum of 60 minutes of training on the physical, behavioral, and performance indicators of probable drug use, and at least 60 minutes of training on the physical, behavioral, speech, and performance indicators of probable alcohol misuse.
7 CONTACT PERSON
Any questions about this policy or any aspect of the company's drug-and alcohol- free program should be referred to:

Norma Mota (DAPM)
3650 Rockwell Ave
El Monte, CA 91731
Phone # 626-258-3384
[email protected]
8 COVERED EMPLOYEES
As a condition of employment, all employees and independent contractors are required to submit to drug and alcohol tests administered in accordance with Parts 40 and 655. (Non­ safety- sensitive employees are covered under STl's own authority). A refusal to submit to a test as directed will be considered to be a positive test result and the employee will be subject to all the attending consequences as stated in this policy. (Please refer to Section 5.0 - DEFINITIONS for specific circumstances or behaviors that are considered refusal to test.) As defined by the FTA. Safety-sensitive employees include those who perform, or may be called upon to perform, the following safety-sensitive functions.

8.1 Operating a revenue service vehicle, even when it is not in revenue service;

8.2 Operating a non-revenue service vehicle when required to be operated by a Commercial Driver's License (COL) holder;

8.3 Controlling dispatch or movement of a revenue service vehicle;

8.4 Maintaining (including repairs, overhaul and rebuilding) a revenue service vehicle or equipment used in revenue service.

Supervisors are considered safety-sensitive only if they perform, or may be called upon to perform, any of the above safety-sensitive functions.

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The company has analyzed actual job duties performed, or may be called upon to perform, by all of its employees and has determined that the following job classifications are considered safety-sensitive for the purposes of this policy.
• Drivers
• Dispatchers
• Mechanics
9 DRUGS TESTED FOR
• Marijuana (THC)
• Cocaine
• Opioids
o Codeine
o Morphine
o Heroin (6-AM)
o Hydrocodone
o Hydromorphone
o Oxycodone
o Oxymorphone
• Amphetamines
o Methamphetamine
o MOMA (Ecstasy)
o MDA
• PCP
10 PROHIBITED BEHAVIORS

10.1 Illegal Drugs
Unless legally prescribed, the prohibited drugs listed on Section 9.0 are illegal and employees are prohibited from consuming any of them at all times. Employees or independent contractors may be tested for illegal drugs anytime they are on duty or subject to duty.

10.2 Prescription or Over-the-Counter Medication
Under STI policy, the appropriate use of legally prescribed drugs and non-prescription medications is not prohibited. However, employees or independent contractors must notify their manager and may not perform any safety-sensitive function if their medication carries a warning label that mental functioning, motor skills or judgment may be adversely affected, unless the medication is being used in accordance with the instructions of a physician who has provided a written determination that the substance will not adversely affect the ability to safely perform safety-sensitive duties.

NOTE: While medical marijuana is a legal drug in California, it is prohibited bv Federal law for safety sensitive employees. Under ST/ policy it is also prohibited for those in non-safety sensitive positions.
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A prescription is considered valid only if it is in writing and indicates the employee's or independent contractor's name, date, the name of the substance, quantity or amount to be taken, and the period of authorization. Prescriptions written by physicians who are not licensed by the U.S. Drug Enforcement Agency, or controlled substances obtained illegally outside the United States are not considered valid medical prescriptions under this policy. It is a violation of this policy to use any controlled substance in a manner that is inconsistent with the prescription. Any covered employee who violates this section of the policy is subject to disciplinary action, up to and including termination.

10.3 Alcohol
Safety-sensitive employees and independent contractors are prohibited from consuming alcohol in any form:
• while performing safety-sensitive functions;
• within 4 hours prior to performing safety-sensitive functions; • while they are on call
• Eight hours following an accident requiring a post-accident alcohol test, unless the test was completed within 8 hours.

Alcohol tests are conducted only just before, during, and just after the employee's or independent contractor's performance of a safety-sensitive function. An alcohol test is considered a violation if the employee's or independent contractor's BAC is at 0.02 or greater.

Under the company's own authority, the same prohibitions as stated above for both drugs and alcohol are applicable to non-safety-sensitive employees as well. 11 TYPES OF TESTING

11.1 PRE-EMPLOYMENT TESTING
All applicants for employment or independent contractor status, or any employee or independent contractor transferring from a non-safety-sensitive to a safety-sensitive position will be required to undergo a pre-employment drug test at a time and place designated by the company. A verified negative drug test result must be received from the MRO prior to the employee being assigned to safety-sensitive functions. If a pre-employment test is cancelled, the individual will be required to undergo another test and successfully pass the test with a verified negative result.

In accordance with the revised Part 40, the company will check on the drug and alcohol testing background of new hires and other employees and independent contractors beginning safety­ sensitive work after obtaining the individual's written consent. This Background Check applies to applicants who worked for any DOT-regulated employer in the previous 2 years. If the individual refuses to provide the written consent, he/she will not be hired into the safety-sensitive position.

In addition, if the individual has had a positive DOT pre-employment drug or alcohol test, or has refused such a test, within the previous 2 years he/she will not be hired until and unless the individual has provided a documentation of successful completion of the return-to-duty process, which includes a SAP referral, evaluation and treatment plan.

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In addition, if the employee or independent contractor has not performed any safety-sensitive function for at least ninety (90) consecutive calendar days regardless of the reason and has been out of the random pool for this period, he or she must pass a pre-employment drug test before being allowed to return to safety-sensitive duties.

11.2 REASONABLE SUSPICION TESTING
Whenever a supervisor has reason to believe that an employee or independent contractor has used a prohibited drug and/or engaged in alcohol misuse, reasonable testing will be conducted .

The referral will be made by a trained supervisor based on the specific, contemporaneous, and articulable observations concerning the appearance, behavior, speech, or body odors of the employee or independent contractor. The supervisor who makes the referral need not be the individual's own supervisor, as long as he/she has received training in detecting the signs and symptoms of drug use and alcohol misuse. The supervisor's observations will be documented and such documentation shall be kept in the employee's or independent contractor's confidential drug and alcohol testing file.

A reasonable suspicion alcohol test will be conducted only if the reasonable susp1c1on observation is made just before, during, or just after the employee's or independent contractor's performance of safety-sensitive function.

Once a supervisor has made a reasonable suspicion determination, he/she must remove the individual from performing any safety-sensitive functions and arrange to have the individual accompanied to the testing site immediately. If the alcohol test is not conducted within two hours, reason for the delay must be documented and kept in the employee's or independent contractor's reasonable suspicion test file. All attempts to complete the alcohol test must cease after eight hours and the reason for the inability to conduct testing documented.

11.3 POST-ACCIDENT TESTING
Any covered driver operating a public transportation vehicle at the time of an accident will be required to submit to drug and alcohol tests as soon as practicable after the accident. For purpose of this policy, "accident" is defined as an accident involving a public transportation vehicle where the result is:
• An individual dies;
• An individual suffers a bodily injury and immediately receives medical treatment away from the scene;
• The public transportation vehicle (if bus, electric bus, van , or automobile) or any other vehicle(s) involved in the accident suffers a disabling damage as a result of the accident and is transported away from the scene by a tow truck or other vehicle.

11.3.1 Fatal Accidents
Whenever there is a loss of human life, any surviving covered driver operating the public transportation vehicle at the time of the accident shall be tested for drugs and alcohol. Any safety-sensitive personnel not in the vehicle but whose performance could have contributed to the accident also shall be tested.
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11.3.2 Non-fatal Accidents
Following non-fatal accidents, the covered driver operating the vehicle at the time of the accident shall be tested unless his/her performance can be completely discounted as a contributing factor to the accident. Any other safety-sensitive personnel whose performance could have contributed to the accident also shall be tested.

11.3.3 Other Post-Accident Testing Requirements
Covered drivers involved in an accident that requires testing must remain readily available for testing, including notifying the company of their location if they leave the scene of the accident before testing to obtain emergency medical care, or to obtain assistance in responding to the accident. They will be considered to have refused to submit to testing if they fail to do so.

Covered drivers are prohibited from using alcohol for eight hours following an accident or until the post-accident testing is completed, whichever occurs first. Every effort will be made to conduct alcohol testing within two hours after the accident. In the event the alcohol test is delayed beyond two hours, the company will prepare and maintain a record stating the reason(s) for the delay. If an alcohol test is not administered within eight hours following the accident, the company will cease all efforts to administer the test and document the reason for the inability to test. In the event a drug test is not administered within 32 hours from the time of the accident, the company will cease all attempts to administer the drug test and will document the reason for the inability to conduct testing. This requirement should not be construed to delay the necessary medical attention for injured people following the accident.

If STI is unable to perform post-accident tests in accordance with FTA regulations, the company will use the post-accident test results administered by State or local law enforcement personnel under their own authority. This is acceptable only under limited circumstances and the test results must be obtained in conformance with State and local law.

Whenever possible, covered drivers undergoing post-accident tests shall be escorted to the collection site. If this is not possible covered drivers may use their own form of transportation to get to the collection site within the prescribed time limits.

11.4 RANDOM TESTING
As required by FTA regulations, safety-sensitive function employees and covered drivers are required to undergo random drug and alcohol tests to deter use of prohibited drugs and misuse of alcohol. The random selection will be conducted using a scientifically valid method, such as a random number table or a computer-based random number generator, which gives each covered employee or independent contractor an equal chance of being selected every time a selection is made. As is the nature of random selection, it is possible for some individuals to be tested several times in one year, and other individuals not to be tested for several years.

Management does not have any discretion on who will be selected.

A random alcohol test will be conducted only during, just before, or just after the employee's performance of safety-sensitive duties. Every effort will be made by the company to spread random testing reasonably throughout the calendar year, all days of the week, and all hours when safety-sensitive functions are performed. The testing dates and times are unannounced and employees or independent contractors are required to immediately proceed to the designated collection site following notification.
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STI will conduct random drug and alcohol tests at a minimum annual percentage of covered employees and independent contractors as required by the FTA. The rates are subject to change on an annual basis, depending on the industry-wide positive rate determined by the FTA from the annual reports submitted by covered employers.

11.5 RETURN-TO-DUTY TESTING
STI has a zero tolerance policy, which means the disciplinary action for a first positive or test refusal is termination. However in the event that an employee who has previously violated the policy is allowed to return to work for any reason, he/she must complete a return-to­ duty process prescribed by the SAP. This includes successful completion of the rehabilitation, treatment or education program outlined by the SAP, and obtaining a verified negative return-to­ duty drug test and/or alcohol test under 0.02. In addition, all return- to-duty tests will be required to be collected under direct observation.

11.6 FOLLOW-UP TESTING
In addition to the Return-to Duty test described in Section 11.5 above, an employee or independent contractor who previously tested positive, or refused to take a required test, shall be subject to follow-up testing for drugs and/or alcohol as prescribed by the SAP, for a minimum period of 12 months to a maximum of five years. As mandated by the FTA, the individual must undergo a minimum of six follow-up tests during the first 12 months of the individual's return to duty. Although they are both unannounced, follow-up testing is apart and separate from random testing. The duration and frequency of testing will be designated by the SAP, but the actual follow-up testing dates will be decided by the individual's manager or supervisor. In addition all follow-up testing will be required to be collected 1,mder direct observation. The employee or independent contractor is responsible for payment of all costs associated with follow-up testing.
12 DRUG & ALCOHOL TESTING PROCEDURES
All DOT drug and alcohol tests required under this policy will be administered in accordance with the "Procedures for Transportation Workplace Drug and Alcohol Testing Programs" (49 CFR Part 40), as amended.

Throughout the testing process, the privacy of the individual will be protected and the integrity and validity of the process will be maintained. The drug testing procedure will include a split specimen collection method, and a Federal Custody and Control Form with a unique identification number to ensure that the correct test result is attributed to the correct employee or independent contractor. An initial screening test using an immunoassay technique will be performed. If the specimen is positive for one or more of the drugs tested, then a confirmation test will be performed in accordance with Part 40 procedures, as amended. If the test is confirmed positive, the MRO will conduct a verification process, which includes giving the employee or independent contractor an opportunity to provide a valid medical explanation for the positive test result.

Additionally, the laboratory will conduct specimen validity testing to determine if a urine specimen has been adulterated, diluted, or substituted. STI requires its employees and independent contractors to take a second test with no advance notice if the MRO reports a negative-dilute test result. Depending on the creatinine level reported by the lab, the MRO may 11 I Page
order the second test to be collected under direct observation. Should this second test result in another negative-dilute, the test will be considered a negative. This will be the test of record and no additional testing will be required unless STI is directed to do so by the MRO.

If the laboratory reports to the MRO an "Invalid Result" or' Rejected for Testing" (because of a fatal or uncorrectable flaw), a recollection may be required by the MRO and depending on the circumstances, the recollection may be directly-observed. The laboratory is required to keep positive, adulterated, substituted or invalid specimens for one year, or longer if requested.

Records for each specimen and employer-specific reports are required to be kept for two years.

The retention time may be extended upon written request by the MRO, STI, employee, independent contractor, or DOT agency.

Tests for alcohol concentration will be conducted using an alcohol screening device and an evidential breath testing (EBT) device if the screen test is at 0.02 BAC or greater. A DOT Alcohol Testing Form will be used and a unique sequential number will be assigned to each test.

Copies of the detailed drug and alcohol specimen collection procedures are available upon request from the Contact Person identified in Section 7.0 of this policy 13 DIRECTLY-OBSERVED URINE SPECIMEN COLLECTION
Under the following circumstances, the employee or independent contractor will be directed to undergo an immediate urine specimen collection under direct observation with no advance notice:
• If the laboratory reported to the MRO that a specimen is invalid and there was no adequate medical explanation for the result;
• If the MRO reported that the original positive, adulterated, or substituted test result had to be cancelled because the split specimen testing could not be performed; • If the MRO reported a negative-dilute test result from the initial test with a creatinine level between 2 to 5 mg/di;
• If the drug test is a return-to-duty or a follow-up test; • If the collector observes materials brought to the collection site or employee or independent contractor conduct that clearly indicates an attempt to tamper with a specimen;
• If the temperature on the original specimen was out of range; or • If the original specimen appeared to have been tampered with.

The observer shall be the same gender as the employee or independent contractor, but need not be a collector. The observer must request the individual to raise his or her shirt, blouse or dress/skirt, as appropriate, above the waist; lower clothing and underpants to mid-thigh, and to turn around to show the observer that he/she is not wearing any prosthetic or similar device that could be used to interfere with the collection process. If none is observed, the individual may return clothing to its proper position for observed urination. The observer is responsible for ensuring that the specimen goes from the employee's body into the collection container. If the employee declines to allow a directly-observed collection when required under this policy, it is considered a refusal to test.
14 MONITORED URINE SPECIMEN COLLECTION
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Under those circumstances when a multi-stall restroom has to be used for urine specimen collection and the facility cannot be adequately secured, the collector will conduct a monitored collection. The monitor shall be the same gender as the employee or independent contractor, unless the monitor is a medical professional. The monitor will not watch the individual void into the collection container. However, if the monitor hears sounds or observes attempts to tamper with a specimen, an additional collection under direct observation will be ordered. If the employee or independent contractor declines to permit a collection authorized to be monitored, the employee or independent contractor is considered to have refused to test.

15. SPLIT SPECIMEN TESTING
After notification by the MRO of a verified positive drug test or refusal to test because of adulteration or substitution, the employee or independent contractor has 72 hours to request (verbally or in writing) a test of the split specimen. There is no split specimen testing authorized for an invalid test result. After 72 hours have passed, the request can be considered only if the employee or independent contractor can present to the satisfaction of the MRO information that unavoidably prevented the employee or independent contractor from making a timely request.

Following the employee's or independent contractor's timely request, the MRO shall send a written request to the primary laboratory to forward the split specimen to a second DHHS­ certified laboratory for testing without regard to the cut-off concentration. If the split specimen test fails to reconfirm the presence of the drug(s) or drug metabolite(s) that were present in the primary specimen, a validity test will be conducted. If the original test was reported adulterated, the second laboratory will test for the adulterant detected in the primary specimen. If it was a substituted test result, the laboratory will test for creatinine concentration and specific gravity values consistent with substitution criteria established in Part 40.

If the second laboratory fails to reconfirm the substance detected in the primary specimen or the adulterant identified, or if the split specimen is unavailable for testing, the test shall be cancelled. The MRO shall report the cancellation and the reasons for it to the DOT, STI, the employee, or the independent contractor. In the case of the split specimen being unavailable, the employee or the independent contractor shall be directed, with no advance notice, to submit another specimen under direct observation.

All costs related to split specimen testing will be paid by the employee or the independent contractor. The employee or independent contractor shall be reimbursed if the second test invalidates the original test or if the test was cancelled. 16 CONSEQUENCES
Any safety-sensitive employee or independent contractor who has a verified positive drug test result, an alcohol concentration of 0.02 or above, or refuses to submit to a drug or alcohol test (including adulteration or substitution) shall be:

1. Immediately taken out of safety-sensitive duty;

2. "Referred to at least 2 SAPs or a substance abuse counselor for (alcohol result below .04) for evaluation, education or treatment and provided educational materials." At STl's discretion, non-safety-sensitive employees also may be removed from duty and referred to a substance abuse counselor.
13I Page
FTA regulations allow individual employers to determine the discipline to be imposed on employees who violate the FTA regulations or company policy. It is the policy of STI to terminate safety-sensitive employees or independent contractors after a first violation.

Non-safety-sensitive employees may be allowed to return to work provided they successfully complete the return-to-duty process discussed in Section 11.5. Such employees will be subject to follow-up testing at their own expense. Any subsequent drug and alcohol policy violation will result in immediate discharge. 17 REFERRAL, EVALUATION AND TREATMENT
If an employee or independent contractor (including an applicant) tests positive for drug(s) or alcohol or refuses to submit to a test when required , STI shall advise the employee or independent contractor of the resources available for evaluating and resolving problems associated with prohibited drug use and alcohol misuse and document such referral. The Employee or independent contractor shall be given the names, addresses and phone numbers of SAPs acceptable to the company and a list of community hot line numbers. The individual will be responsible for any costs associated with the SAP evaluation and any recommendation(s). 18 CONFIDENTIALITY AND ACCESS TO FACILITIES AND RECORDS Employees and independent contractors have a right to examine their own drug and alcohol testing records, provide information to dispute the results, and have access to any pertinent data such as EBT calibration or drug testing laboratory certification. They also have a right to obtain a copy of their own drug and/or alcohol testing results by submitting a written request to the Drug and Alcohol Program Manager identified in Section 7 of this policy.

STI will do everything possible to safeguard the confidentiality of drug and alcohol testing records and protect the privacy of the individuals tested. Individual test results or medical information will be released to third parties only with the employee's or independent contractor's specific written consent, or to those parties authorized by the DOT or FT A to receive such information without the employee's or independent contractor's consent. Specific written consent applies only to a particular piece of information released to a particular person or organization at a particular time. Blanket releases are specifically prohibited by DOT.

The employee's or independent contractors' written consent is not required in administrative or legal proceedings such as:
• A lawsuit, grievance, or administrative proceeding brought by, or on behalf of the employee or independent contractor, resulting from a positive drug or alcohol test or a refusal to test; or
• A criminal or civil action resulting from an employee's or independent contractor's performance of safety-sensitive duties where the alcohol or drug test information is deemed relevant.

Access to the company facilities and drug and alcohol program records also must be provided, without the employee's or independent contractors' consent, to DOT or FT A agency representatives; the National Transportation Safety Board as part of an accident investigation; or a Federal, state or local safety agency with regulatory authority over the Company or the employee or the independent contractor; state or grantee required to certify to FTA compliance with 49 CFR Part 655 and Part 40. Also, on June 13, 2008, DOT adopted a rule authorizing 14 I Page
employers and TPA's to disclose to state commercial driver licensing (CDL) authorities the drug and alcohol violations of employees who hold CDL's and operate commercial motor vehicles, when a State law requires it.
19 DRUG-FREE WORKPLACE ACT of 1988 (DFWA) REQUIREMENTS
Under the DFWA, employees are prohibited from the unlawful manufacture, distribution, dispensing, possession, or use of a controlled substance in the workplace. Employees are required to notify management in writing of any criminal drug statute convictions he/she receives for a violation occurring in the workplace, no later than five calendar days after such a conviction. Within 10 calendar days of receiving such notice, ST/ shall provide written notification of the conviction to the FTA. Within 30 calendar days of receiving notice of the convicf;on, the company shall take appropriate disciplinary action, or require the employee to participate and successfully complete a drug rehabilitation program Approved By: ~-------
Jasdffsnow --
Vice President/COO
15 I Pag e

SAFETY AND TRAINING PROGRAM

POLICY AND PROCEDURE

REVISED

Redacted due to Proprietary or Confidential Information (PDF Pgs. 182-214)

1 CUSTOMER SERVICE

HANDBOOK
Transit Division

This handbook supersedes all other Customer Service Handbooks only January 2011
FORM 300-002

2 A. General Rules

At times, situations not covered by these rules, the Employee handbook, Code of Safe Practices, and the Injury and Illness Plan may arise. Reservation Agents and Dispatcher (CSR’s) must exercise good judgment when encountering these situations. All such situations must be reported to a dispatch or a supervisor.

1. Knowledge of Rules and Procedures

A CSR must become familiar with all rules and regulations. Ignorance of rules, procedures, special orders and/or instruction will not excuse negligence or omission of duty. When necessary, CSR’s must seek guidance from the lead dispatch or supervisory personnel regarding clarification of any procedure or special instruction.

2. Special Orders and Instruction

Special orders and instructions supersede all above mentioned rules and regulations contained herein and are to be obeyed while in effect. Special orders and instruction may be issued in the form of;
• Bulletins
• Notices
• Memos
• Schedule letters

3. Compliance with instructions

Operators must accept responsibility for and carry out the oral or written instruction of any authorized STI representative. Authorized STI representatives may include;
• Dispatch
• Road Supervisor
• Safety and Training manager
• Project or General Manager
• President, Vice President, and/or Director

4. Bulletin Boards, Mailboxes

Operators must consult the bulletin boards and check their mailbox, if provided, before and after each day’s assignment. Upon return from any absence from duty, an Operator must consult the bulletin board for updates and changes. The addition of, defacement of, or unauthorized removal of, any material posted by STI is considered gross misconduct, and is grounds for disciplinary action.

3 5. Laws and regulations
At no time may a CSR instruct an Operator to maneuver their vehicle in a way that is against the law. This includes, but not limited to speeding, u-turns, and over capacity.

6. Cooperation with Law Enforcement & Fire Department Agencies

CSR’s must cooperate with law enforcement and fire department agencies. If such cooperation creates a dangerous situation or departure from an established STI procedure, notify the appropriate supervisor. The CSR must submit a report regarding the incident at the end of their work assignment.

B. POLICY
All staff, i.e. CSR’s, Dispatcher, must answer the telephone in a standard, professional manner, ensuring consistent, polite, and quality service.

1. CSR’s are required to follow standard telephone answering procedures when answering the phone.

2. Must allow adequate time for each individual calling and not rush through the call.

3. CSR’s must be ready to answer the call. The CSR may not answer the call and immediately put the caller on hold.

4. The initial call is to be answered with “Good [morning/afternoon, as appropriate]; “(name of Service), how may I help you?”

5. If caller asks for a specific CSR, try to handle the inquiry directly and not transfer the caller.

6. If the caller asks to speak to a manager or someone higher up, refer the caller to an available supervisor.

7. Placing a caller on hold: If a caller must be put on hold, tell the caller that they are being placed on hold and why. Remember to ask the callers’ permission and to wait for an answer.

8. Taking a transferred call: When accepting a transferred call, provide a short introduction such as, “This is [your name], how may I help you?”

9. Each contract has their own reporting procedure. Each CSR must obtain the information in the form of an addendum.

B. SAFETY

1. Reporting for Duty
When reporting for duty, CSR’s must be in proper uniform and fully equipped to work at the time and place determined by their assignment or as instructed by supervisory personnel.

4 2. Supplies
CSR’s must obtain all the supplies required to perform their assignment and must secure them properly.

3. Service Delays
When an Operator contacts Dispatch because of a service delay, the call must be logged in the Call Center Book. Every attempt must be made to help the Operator to make up their time. If the time can not be made up, contact a supervisor immediately.

The time notified of the delay and time notified that they are back in service must be documented in the Book.

4. Running Time
Speed must be governed so that Operators arrive at time points safely and on schedule.

5. Litter
All litter must be disposed of properly in trash receptacles.

6. Unattended Buses
Dispatch must document or acknowledge when an Operator calls stating that they or leaving their vehicle and when they return.

7. Freeway or City Emergency
If a vehicle becomes disabled on a freeway or in a city, the Dispatcher must notify maintenance and a supervisor immediately. In some cases notifying the CHP may be appropriate.

8. Operating While Ill or Fatigued
If an Operator calls stating that they are ill, every attempt must be made to find a replacement Operator and a supervisor must be notified.

9. Animals on Board the Bus
Each contract that STI operates has different rules regarding transporting animals. Check with your General/Project Manager for rules governing transporting of animals. Service animals are allowed with no exception. If other animals are permitted to be transported, they must be transported in a suitable carrier.

10. Reporting Accidents or Incidents
If an operator is involvement in any accident or incident, whether actual or alleged, it must be reported to a supervisor immediately. An accident/incident report must be completed at the end of the shift.

5 11. Request for Assistance
Any request for emergency assistance must be made through dispatch. An Operator may personally request the assistance of a law enforcement officer located at the scene; however, notify dispatch immediately after.

12. Striking a Fixed Object or Unattended Vehicle
If a STI vehicle strikes a fixed object or an unattended vehicle, a reasonable effort must be made to locate the property owner or driver of the vehicle. If unable to locate have the Operator leave a note providing their name, vehicle number, and their facility address. An accident/incident report must be completed at the end of the shift.

13. Witness Reports
Operators who witness an accident must report the incident to dispatch and submit an incident report upon completion of their assignment.

14. Disabled Bus Outside of yard
An Operator notifies dispatch of a disabled vehicle, Dispatch mist immediately contact maintenance and a supervisor. If mechanical assistance or a supervisor does not arrive within 30 minutes, call the Operator again and continue to do so at 30 minute intervals until assistance arrives for an update.

If a mechanic arrives and repairs or replaces the vehicle prior to the arrival of a supervisor, note it on the Daily Rollout Sheet.

C. APPEARANCE

1. General Statement
STI’s public image is largely influenced by the appearance of its employees.

CSR’s must maintain a neat, clean, and professional appearance at all times.

2. Reporting for Duty
When reporting for duty, an operator must appear neat, clean, and orderly and dressed in a complete uniform.

3. Dress Code
All CSR’s must follow the company dress code and any contractual code.

D. OPERATOR/CUSTOMER RELATIONS

1. Customer Relations
Keeping in mind all the rules and procedures, CSR’s are to provide at a minimum, continual service. Continual service is:
• Operating safely while striving for reliable service. • Greeting customers/acknowledging their patronage.
• Fair/consistent treatment of all customers.
6 • Being prepared to assist customers with special needs. • Answering questions/providing informational material. • Maintaining a clean and safe bus.

2. Deviating from Procedures
CSR’s may encounter situations that require deviating from prescribed procedures. When these situations arise, operators are to consider their safety and that of their customers and the equipment. CSR’s will use their best judgment to decide what procedure best serves the customer but never violating or compromising basic rules and safety practices. Contact dispatch if a situation requires it.

3. Fair and Consistent treatment of Customers
Operators are required to treat all customers in a consistent, courteous, respectful, and professional manner at all times.

4. Greeting Customers
Operators are required to greet all customers.

5. Reliable Service
CSR’s should strive for delivering reliable courteous, service.

E. COMMUNICATION

1. General Statement
This section contains specific rules governing safe and efficient communication. Operators must use good judgment when dealing with situations that may require the use of the radio. Situations arising not covered in this section should be reported to dispatch.

2. Radio Conduct
Vehicle equipped two-way radio system falls under the direction of and regulated by the Federal Communications Commission (FCC). Operational conduct prohibited by federal law includes:
• Use of obscene or profane language.
• Unauthorized use of messages.
• Excessive, false, or deceptive signals or communications. • Unauthorized calls sign.
• Tampering
CSR’s bear the responsibility to project a positive image by transmitting clear concise messages via radio. Unnecessary comments, slang terms, and profanity are prohibited.

7 3. Radio restriction
CSR’s must never:
• Request that Operators give customers information over the handset or radio speaker.
• Allow the use of the radio system by unauthorized persons. • Disclose the radio’s characteristics or emergency features to customers or other unauthorized persons

4. Telephone Communications
When an CSR is unable to contact an Operator via radio, he/she should document the incident and never contact the via cellular phone unless it is an emergency. Contact your General/Project Manager.

5. Cellular Phone Use
CSR’s are forbidden to use a cell phone while on duty in the Call Center. This also includes the use of Hands-free devices. A CSR must never contact an Operator via cell phone while they are driving.

6. Dispatch System and MDT Use
CSR’s must input all information correctly into the dispatch system. Unless instructed otherwise, all dial-a-ride trips must be inputted and dispatched through the dispatch system.

ADDENDUMS

Each contract operates with different rules and regulations; therefore every CSR must check with their General/Project Manager for current addendums. The addendums will list all contract related rules and regulations that must be followed.

8 ACKNOWLEDGMENT AND RECEIPT OF CUSTOMER SERVICE

HANDBOOK

I have this day received a copy of the Southland Transit, Inc., Transit Division Customer Service Handbook. I understand the Handbook contains important information on the company’s general personnel policies and on my privileges and obligations as an employee. I understand that I am expected to read, understand and adhere to company policies and to familiarize myself with the material in the Handbook. If I should have questions about the contents of this Handbook I may direct questions to a company representative.

I agree to abide by the policies and procedures contained herein. I understand that the policies contained in this employee handbook may be added to, deleted or changed by the company at any time. The company will advise employees of material changes within a reasonable time. Failure to comply could result in disciplinary actions including termination of employment.

EMPLOYEE NAME _______________________________________

SIGNATURE _______________________________________

DATE_____________________

2013

ACCIDENT/INCIDENT

PREVENTION MANUAL

Setting the Standard for Community
Transit in Southern California

MEMO

TO: ALL EMPLOYEES

FROM: SCOTT TRANSUE

VICE PRESIDENT/COO

DATE: NOVEMBER 1, 2013

SUBJECT: ACCIDENT/INCIDENT PREVENTION PROGRAM

The attached Accident/incident Prevention Program was created to provide safe, courteous, clean, reliable, and effective on-time service to our passengers.

The safety of the services we operate is of paramount concern. Our goal is to provide transit patrons and employees with the highest degree of safety that is practical. As a result, all Southland Transit Personnel are charged with the responsibility of ensuring the safety of passengers, employees, property, and those who come in contact with the system.

The Director of Safety & Training is authorized and directed to develop, implement, and administer a comprehensive and coordinated system safety program to prevent, control, and resolve unsafe conditions which may occur.

It is the responsibility of each Southland Transit employee to cooperate with the Director of Safety and Training and provide her with any requested information to assist in any investigation or inspection that is being conducted.

I look forward to everyone’s cooperation with this as we work to improve our safety culture within the company.

Sincerely,

Scott Transue
Vice President/COO

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1. INTRODUCTION

A fundamental goal of our services is to provide passengers and employees with the highest level of safety that is practical and consistent with the mission of the transit system we operate. Accomplishing this goal with any degree of efficiency requires us to develop and implement a comprehensive safety program. This program will address the three primary safety functions of a transit system, which are as follows:

1. to prevent the occurrence of accidents/incidents.

2. to respond to and recover from accidents/incidents,

3. and to learn from accidents/incidents that occur.

1.1 PURPOSE AND SCOPE

This manual identifies safety issues that must be addressed and resolved in order to provide passengers, employees, and the general public with the highest degree of safety that is practical. Included in this document is guidance on the following safety issues:

1. Development and implementation of an accident/incident prevention program

2. Selection, training, evaluation and, if necessary, termination of transit system employees

3. Promotion of patron safety/awareness

4. Design options available in the vehicle procurement phase that will prevent accidents/incidents

5. Development of safety policies and procedures

This guidance is intended for managers, safety directors, and operations staff.

1.2 BACKGROUND

The implementation of a comprehensive accident/incident prevention program will result in a reduction in accidents/incidents, and therefore, a reduction in casualty claim costs, vehicle repair costs, and the cost of insurance premiums. In addition, it will also reduce the number of employee and passenger injuries. A properly designed accident/incident prevention program, after development and implementation, will NOT cost money but save money.

The primary purpose for the existence of our services is to move people safely . In order accomplish this goal, we must be able to identify all hazards in order to eliminate, minimize or control them, and identify all safety-related responsibilities, delegating these STI Accident/incident Prevention Manual Page 2

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responsibilities to the proper units within the organization and providing these units with the resources to carry out their assigned responsibilities. We have the responsibility of applying operating, technical, and management techniques and principles to the safety aspects of the system throughout its life cycle to reduce hazards to the lowest practical level through the most effective use of available resources. This process is known as system safety.

Accident/incident prevention is a priority of every bus operation. Generally, practices that are used to prevent accidents/incidents and promote safe driving fall into one of three categories.

• Safety Management—including training, incentives to reward good performance, progressive discipline for adverse performance, operator selection, operator work rules and procedures, labor, safety awareness, and intervention for employees at risk.

• Management—including accident/incident data tracking and analysis, accident/incident investigation, public and passenger education, hazard identification and resolution, safety inspections, safety committees, and supervision.

• Operations—includin g bus stop location and design; rout e selection and scheduling; use of checkers on buses; and technology applications, such as cameras on buses, “black box” recorders, daytime running lights, and dual mirrors.

Specific practices that are used to prevent accidents/incidents and promote safe driving vary widely among transit systems, although most systems use all three types noted previously to some extent. There is no comprehensive inventory of such practices for operators to readily reference, nor have best practices been evaluated in a systematic manner.

SC
OPE

The phrase “ accident/incident prevention practices” covers a very wid e range of activities at the typical transit system. The first three categories below deal directly with the bus operator— the obvious focus of most bus accident/incident prevention practices. The last four categories deal more indirectly with the bus operator. Descriptions of all categories follow.

1. Driver selection and hiring refers to practices used to identify and attract potential candidates who have the proper skills and aptitude to become a safe and competent bus operator.

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2. Driver training refers to the initial training of new operators, regularly scheduled refresher training, and retraining triggered by one or more preventable accidents/incidents or observation of driving problems by supervisory personnel.

3. Safe driver incentive practices refers to practices intended to reward bus operators for safe driving (i.e., for having no preventable accidents/incidents within a specific time period).

4. Customer safety practices refers to practices that help a passenger avoid personal injury accidents/incidents while boarding, riding, or exiting a bus. Many of these practices target passengers with disabilities.

5. Management practices refers to activities that ensure that management is fully aware of bus accident/incident trends and that identify specific problems with individual operators or types of buses. Examples include safety audits, ride checks, computerized accident or incident databases, safety committees for accident/incident review, and practices for “accident/incident repeater” drivers.

6. Bus technology safety improvements refers to practices that enhance passenger safety and reduce accidents/incidents by increasing the visibility of the bus for pedestrians and for the drivers of other vehicles. Examples include low- floor buses, improved doors and door controls, improved driver vision through mirrors and lighting, high-visibility brake lights and warning signs, and daytime running lights.

7. O
perating environment practices refers to practices that help create a safer operating environment for buses.

Providing Incentives for Safe Driving

Southland Transit, Inc. (STI) will provide safet y awards to recognize bus operators and maintenance employees who work accident/incident free. The awards include safety pins or patch an d certificates, jackets, and a watch, depending on the number of years of accident/incident-free driving.

The minimum criterion for the first patch (i.e., the 1-year safe driver patch) is 1 calendar year without a preventable accident/incident. Subsequent awards are based on each additional calendar year without a preventable accident/incident.

STI recognizes an employee each month as employee of the month. This employee is nominated by his or her peers for excellent job performance and accomplishments.

The employee of the month shall receive a certificate;
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• dinner for two;
• a special parking spot for the month;
• and a c ommendation from the Project Manager.

The employee of the month then becomes eligible to be selected as the employee of the year. The employee of the year shall receive a plaque;
• a $100 gift certificate;
• and other recognition at the annual Company Safety Banquet

STI shall sponsor an annual safety banquet. The purpose of this banquet is to honor bus operators and maintenance employees who have worked accident/incident free for the past year. During the banquet, the employees of the month are recognized and the employee of the year is announced.

Monitoring and Managing Bus Operator Safety Performance

Each Project Manager is required to make safety ride check s with each of their employees twice a year. Durin g the ride check, the manager observes the operator’s safety habits, appearance, customer relations, and general operation of the bus. At the conclusion of the ride check, the manager reviews the results with the operator and discusses any recommendations that may be necessary. The ride checks help improve the rapport between managers and bus operators. The Safety Director also makes ride checks when an operations supervisor makes a recommendation.

O
perations supervisors provide on-street supervision of the STI transit operations. The supervisors are responsible for overseeing STI operations and for ensuring that all safety- related operating policies are adhered to. Supervisors routinely take corrective action to solve observed problems. In additio n to supervising the bus operators, the supervisor also takes care of other safety-related problems (e.g., alerting operators about poor weather and road conditions, inspecting detours, and reporting traffic problems).

Employees are required to report all accidents/incidents at the time of occurrence.

Employees are required to report collision accidents/incidents, passenger accident/incidents, witnesses, vandalism, discovered vehicle damage, student misconduct, work-related injury, and passenger problems. All reports are reviewed and investigated by supervisory personnel, at which time the Project Manager will assign a preliminary point value to the report. The Project Manager will also make a preliminary determination on whether the accident/incident was preventable or non-preventable.

After reviewing the investigative material, including the Project Managers determination of points and preventablity a three-member, accident/incident judging committee will provide the Project Manager with a final point count and determination of preventablity .

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This committee is comprised of the Safety Director, a Project Manager, and a Risk Manager. Determinations are based on written standards for defensive driving.

Employees are then given written notification of the determination.

STI has a strict disciplinary code for excessive preventable accidents/incidents that occur within a consecutive twelve (12) month period, as follows:

ACCIDENT/INCIDENT REVIEW

1. The operator is off for the remainder of their shift. The time will be paid at their regular rate of pay.

2. If the collision involved another party resulting in property damage over $250.00 and/ or injury, the operator is off pending accident/incident review.

3. The review shall take no more than two (2) days. Example, collision on Monday, the driver is off and the review must be completed by the end of the day on Wednesday with the operator being notified of the results.

- If the results were non-preventable, the operator will be compensated at their regular wage for the missed days.

- If the collision was deemed preventable, the operator will not be compensated for missed work and will face disciplinary actions as stated below.

DEFINITIONS

• NON-PREVENTABLE
The operator did everything reasonable to prevent the collision

• PREVENTABLE
The operator did not do what was reasonable to prevent the collision

CLASSIFICATION

• 1 point
o A preventable collision resulting in property damage less than $250.00 with no bodily injury.

• 2 points
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o A preventable collision resulting in property damage of more than $250.00 but less than $1500.00 or bodily injury. Any vehicle being towed from the scene.

• 3 points
o Any collision resulting in severe property damage, severe injury, or as a result of operator negligence. Any preventable wheelchair incident.

DISCIPLINE

1. 1 POINT collision will result in a written warning.

2. 2 POINT collision will result in a written warning and suspension without pay with the possibility of termination of employment.

3. 3 POINT collision will result in automatic termination of employment.

ACCUMULATION

• Accumulation of 3 points within a floating 12 month period will result in termination of employment.

The company has the right at any time to terminate employment for any and all collisions and incidents.

STI’s safety and training department has formulated a series of questions that help determine preventability and also help teach operators the meaning of defensive driving. The supervisor or other individual responsible for determining preventability is instructed to gather the facts about an accident/incident and then apply the questions when making the determination.

STI’s definition of defensive driving, as contained in the instructions accompanying the use of the interview questions, provides clear guidance to both operators and supervisors. These instructions include the following text:

A defensive driver is one who makes allowances for the lack of skill and lack of knowledge on the part of the other driver, who recognizes that he has no control over the un- predictable actions of other drivers and pedestrians, nor over conditions of weather and road, and who, therefore, develops a defense against all these hazards;
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I. Intersection Accidents/incident s

1. Did our operator approach the intersection at a speed safe for the conditions?

2. Was the operator prepared to stop before entering the intersection?

3. At a blind corner, did the operator pull out
slowly, ready to shift their foot to the brake
pedal?

4. Did the operator make sure the other driver would stop for a traffic light or stop sign?

5. Did the operator obey all traffic signs?

6. Did the operator signal well in advance of his change in direction?

7. Did the operator turn from proper lane?

8. Was the operator alert for the turns of other vehicles?

9. Did the operator avoid overtaking and passing in the intersection?

10. Did the operator refrain from jumping the starting signal or riding through the caution light?

IF THE ANSWER TO ANY QUESTION IS “NO,” OUR

OPERATOR WAS NOT DRIVING DEFENSIVELY AND IS AT
FAULT.

II. Hit Other in Rear

1. Was our operator maintaining the safe
following distance, namely one bus-length for
every 10 miles per hour of travel, which should
be doubled at night and doubled again in wet
weather?

2. Was the operator keeping their eyes and mind ahead of the car ahead?

3. Did the operator approach the green traffic
light cautiously, expecting the driver ahead to
stop suddenly on the signal change?

4. Did the operator keep from skidding?

IF THE ANSWER TO ANY QUESTION IS “NO,” OUR

OPERATOR WAS NOT DRIVING DEFENSIVELY AND IS AT
FAULT.

III. Backing Accidents/incidents
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Setting the Standard for Community
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1. Was it necessary to back?
a. Did our operator have to park so close
to the car ahead as to require backing
to leave the parking space?
b. Was it necessary to drive into the
narrow street, dead-end street, or
driveway from which the operator
backed?
c. Did he back immediately after looking?

2. Did the operator use his horn while backing?

3. Did the operator look to the rear without depending on the rear vision mirror?

4. If the distance was long, did the operator stop, get out, and look around occasionally?

IF THE ANSWER TO ANY QUESTION IS “NO,” OUR

OPERATOR WAS NOT DRIVING DEFENSIVELY AND IS AT
FAULT.

IV. Pedestrians

1. Did the operator drive through congested
sections expecting that pedestrians
would step in front of his bus?

2. Was the operator prepared to stop?

3. Did the operator keep as much
clearance between his vehicle and
parked cars as safety permitted?

4. Did our operator refrain from
passing vehicles that had stopped
to allow pedestrians to cross?

5. Did the operator refrain from jumping the starting signal or riding through the caution light?

6. Was the operator aware of groups of
children, and was he prepared to stop if
one ran into the street?

7. Did the operator give all pedestrians the right-of-way?

IF THE ANSWER TO ANY QUESTION IS “NO,” OUR

OPERATOR WAS NOT DRIVING DEFENSIVELY AND IS AT
FAULT.

V. Pulling from Curb
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1. Did the operator look to front and rear
for approaching and overtaking traffic
immediately before starting to pull out?

2. Did the operator look back rather than depend upon rear vision mirror?

3. Did the operator signal before pulling from curb?

4. Did the operator start out only when his
action would not require traffic to change
its speed or direction in order to avoid
him?

5. Did the operator continue to glance back as he pulled out?

IF THE ANSWER TO ANY QUESTION IS “NO,” OUR

OPERATOR WAS NOT DRIVING DEFENSIVELY AND IS AT
FAULT.

VI. Skidding

1. Was our operator driving at a speed safe for condition of weather and road?

2. Was the operator keeping at least twice
the safe following distance for dry
pavement; one bus length for every ten
miles per hour of speed?

3. Were all the operator actions gradual?

4. Was the operator expecting or alert for loose gravel, grease, oil, etc.?

IF THE ANSWER TO ANY QUESTION IS “NO,” OUR

OPERATOR WAS NOT DRIVING DEFENSIVELY AND IS AT
FAULT.

VII. Parked

1. Was our operator parked on the right side of the street?

2. Was it necessary to park near the intersection?

3. Did the operator have to park on the traveled part of the street, on the curve, or on the hill?

4. Where required, did the operator warn traffic?

5. Did the operator park parallel to curb?

6. Was it necessary to park so close to alley or directly across from driveway?

IF THE ANSWER TO ANY QUESTION IS “NO,” OUR

OPERATOR WAS NOT DRIVING DEFENSIVELY AND IS AT
FAULT.

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VIII. All Others

1. Could our operator reasonably have done anything to avoid the accident/incident?

2. Was the operator speed safe for the conditions?

3. Did the operator obey all traffic signals?

4. Was the operator vehicle under control?

IF THE ANSWER TO ANY QUESTION IS “NO,”

OUR OPERATOR WAS NOT DRIVING
DEFENSIVELY AND IS AT FAULT.

Specialized Safety Practices

A bus damage reduction program initiated in December 2013 The purpose of this program is to eliminate all blin d (i.e., unreported) accidents/incidents and to promote safe driving. Each bus is repaired and made damage free. When a bus is damage free, a blue sticker is placed in the front wind- shield. When a bus operator is assigned a bus with a blue sticker, they are required to report any discovered damage prior to leaving the garage. When the vehicle is returned to the yard, designated personnel will inspect each vehicle and report any damage. This covers all vehicles from relief to maintenance to buses and minivans.

2. DEVELOPING AN ACCIDENT/INCIDENT

PREVENTION PROGRAM

An efficient, successful approach to the prevention of accidents/incidents involves the establishment of a pro-active safety program that includes the systematic identification of potential accidents/incidents and the implementation of preventive actions.

Preventing the occurrence of accidents/incidents requires the identification and resolution of hazards and potentially unsafe conditions. This can be achieved through the adoption and implementation of the system safety concept.

An effective response to accidents/incidents can be accomplished through the adoption and implementation of the emergency preparedness concept.

Learning from the accident/incident is accomplished through the accident/incident investigation process. At the completion of the investigation, that which has been learned should be integrated into the safety and training program to ensure that the accident/incident does not occur again. The following sections discuss the development and implementation of the system safety concept and program and their important roles in an accident/incident prevention program.

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2.1 ACCIDENT/INCIDENT PREVENTION THROUGH SYSTEM SAFETY

As stated, a safety program must be proactive, and safety hazards must be identified and resolved prior to the occurrence of accidents/incidents. Establishing a proactive safety program can be accomplished through the adoption and introduction of the system safety concept. System safety is defined as the application of special technical and managerial skills to the systematic, forward-looking identification and control of hazards throughout the life cycle of a project, program, or activity. This process spans the entire system life cycle and begins during the acquisition (concept definition, design, construction, and inspection/testing/certification) and operation (operation, training, maintenance, modification, and disposal) phase of the system life cycle.

2.2 IMPLEMENTATION OF A SYSTEM SAFETY PROGRAM

Preventing accidents/incidents is the responsibility of all personnel, up to and including the VP/COO and CEO. The fundamental aim of system safety is to ensure that all transit personnel practice a proactive approach to safety. The system safety programs are established and documented in order to ensure that the safety program is proactive and that all personnel understand and respond appropriately.

The first step in the establishment of the system safety program is obtaining the commitment of the top management.

Once management commitment is obtained, the Safety Director responsible for coordinating, developing, and implementing the safety program should ensure that it clearly recognizes the safety role and responsibilities of each employee of the transit system. The purpose of the program is to provide the transit system patrons and employees the highest degree of safety possible by minimizing the risks to which they and the equipment are exposed. The safety staff should emphasize this purpose when explaining and justifying to other transit departments their involvement in the system safety program.

2.2.2 System Safety Program Plan

The system safety program plan is the written plan that documents the implementation and operation of the system safety program. It is intended to guide the implementation of the program and to document the roles and responsibilities of all individuals and departments within the transit system.

The system safety program plan should be a dynamic document that is continually referred to and revised as the program is modified. To accomplish this, the plan should be brief and to the point. A long tedious document will not be of assistance to the transit system as people tend not to utilize it after development. An example of the table of contents of a system safety program plan is as follows:

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• Policy and introduction.
• Brief description of the system.
• Safety roles and responsibilities of all transit system personnel. • Detailed discussion of the role and responsibility of the safety officer and/or department.
• Process that is employed to be proactive in identifying and resolving hazards. • Process for monitoring and revising the system safety program. This should include a schedule for the implementation.

2.3 THE PROACTIVE PROCESS

The identification of hazards and potential accidents/incidents is the responsibility of all transit system employees. The mechanism by which potential accidents/incidents are identified will, however, differ depending on the roles and responsibilities dedicated to system safety. The safety officer or safety staff will have the primary responsibility and work with other transit system personnel to continually identify and resolve hazards and potential accident/incident conditions.

There are four basic alternative methods of identification that must be employed to identify hazards and potential accidents/incidents. These methods are:

• Examination of data from previous accidents/incidents or operating experience Review of generic hazard checklists
• Judgement of knowledgeable individuals, i.e., transit personnel, outside experts, etc.; case studies of accident/incident; scenarios
• Formal hazard analysis techniques

With the exception of the checklists, the initial step in identifying the hazards in each of these methods is to identify the accident/incident that may result if the hazard(s) is not eliminated or controlled. For the purposes of this discussion, the identified accident/incident events are the safety issues that must be resolved to provide the passengers, employees, and general public with the highest level of safety practical.

2.3.1 Data From Previous Accidents or Incidents

Examination of previous accident/incident/incident experience can provide insight into what has happened in the past. Staff will investigate each accident/incident and periodically conduct a detailed examination of their operating experience and accident/incident data. This examination will serve to identify the hazards that led to the accidents/incidents and how those hazards may be resolved; thus, preventing future accidents/incidents. Failure to review accident/incident history and learn from it will result in a reoccurrence of those accidents/incidents.

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Identification of hazards through a review of previous accident/incident data or experience is an important step in the resolution of potential safety hazards. However, a review of past accident/incident data does not provide a complete analysis of hazard identification, because the hazards identified will be limited only to those that caused previous accidents/incidents. New and potential hazards will not be identified.

Furthermore, in the reporting and investigation of accidents/incidents, if the pertinent information isn't collected and the incident isn't classified by type and the details of its occurrence, it will not be possible to use the results to improve vehicle procurement, employee selection, operations, or transit safety nationally.

A review of data on incidents that did not result in a accident/incident, but easily could have. Research on transit accidents/incidents has demonstrated that, for almost every type of accident/incident, there is a recognizable pattern or chain of events leading up to its occurrence. For example, a bus operator with a drinking problem will probably have several minor collisions or other infractions on his/her driving record that suggest the nature of his/her problem. If these records are reviewed, this employee can be identified before a major accident/incident occurs. Likewise, mechanical difficulties, such as failure of a brake light or turn signal, can be discovered during an inspection before they cause an accident/incident. If a transit system can recognize and respond to these difficulties quickly and efficiently, they can prevent accidents/incidents.

3. THE ROLE OF EMPLOYEES AND PATRONS IN

BUS ACCIDENT/INCIDENT PREVENTION

The prevention of accidents/incidents is the responsibility of every employee! Safety is a daily process that involves planning and foresight rather than reports and reactions after accidents/incidents occur. Employees are the key to providing safe transit operations. It has been estimated that approximately 85% of all bus accidents/incidents each year occur as the result of human error. If a bus system wants to prevent accidents/incidents, personnel hiring and training are perhaps the two most important issues to be addressed.

This chapter discusses several requirements bus systems should consider when hiring personnel and designing training programs that will result in accident/incident prevention. It also stresses the importance of refresher and accessibility training and contains a section on ways in which to train patrons to improve their awareness and safety.

3.1 SCREENING AND HIRING QUALIFIED PERSONNEL

Transit employees, especially individuals hired to assist and transport passengers, play a crucial role in providing safe transportation. Quite often, it may be difficult to hire employees who are motivated and dedicated because of low wage rates or the location STI Accident/incident Prevention Manual Page 14

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of operation. The ability of the employee to perform job duties effectively and safely often becomes secondary. In adopting this approach the system may be putting the employee, the passenger, and the fiscal integrity of the system at risk.

Before we decide upon its criteria for hiring personnel, the system needs to determine exactly what services it requires of its personnel, and exactly what level of skill is necessary to perform those services. Most transit systems have minimum standards for the physical and mental capabilities of applicants. In addition, the Americans with Disabilities Act (ADA) requires that capability standards be based on the performance and duties required by a specific position and not on the physical and mental capabilities of the person. Transit personnel, especially bus operators and dispatchers, must have certain skills in order to successfully perform their jobs. Requiring the presence of these skills does not violate state or federal laws. However, when establishing such criteria the following conditions must be followed:

• The physical and mental criteria used by the transit system are proven job- related or required by law, such as CDL.
• Any testing utilized to determine physical or mental capacities of the applicants must be proven to accurately measure those functions which are job-related, i.e., the test cannot just test reading ability.
• All required tests are given to all prospective employees within that job classification.
• The position requirements and the skills required to perform them are stated clearly in the transit agency's personnel policies. These requirements must be applied equally to all driver candidates.
• A specific doctor or group of doctors to give all driver physicals. This ensures that a consistent and legitimate physical is provided. Transit systems can establish with the doctor the appropriate physical for the driver if the DOT physical is not used.
• Due to the aging process, the transit system may want to establish additional components to the physical for all drivers after the age of 45.

Job descriptions should be reviewed and developed prior to advertising the position or interviewing applicants.

• Examination of the position duties and objectives is crucial in order to make a determination of the qualifications required to perform the essential job functions. • Identification of the non-essential functions. Non-essential functions are those tasks being performed by the "incumbent" in the position that are not specifically required by the position or that could be re-assigned to other transit personnel or positions.
• Establishment of measurable job standards for each position is necessary for objective and appropriate evaluation. The job standards must relate to the essential job functions.

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• Identification of the critical skills and experience necessary for the performance of the essential job functions.
• Development of job related criteria may be assisted by using the system's Advisory Board, composed of disabled riders.

Because of the safety sensitive nature of their operations, personnel may not working under the influence of drugs or alcohol. Thus, when screening applicants, evidence of drug or alcohol use should never be overlooked, our written drug/alcohol policy (as prescribed by the Federal Transit Administration) covers the use of both illegal and prescription drugs, as well as the use of alcohol.

When reviewing the applicant's driving record, it should be state any relevant penalties or sanctions such as ineligibility for hiring or termination. We shall require a minimum of five years of driving experience before an applicant can even submit an application.

This means that the minimum age of a driver is twenty-one. With this inclusion in the policy, we can feel assured of a more stable work force. The following is a checklist of important requirements for which applicants must be reviewed:

• Physical and mental qualifications of applicant
• Can the applicant pass the DOT physical?
• Are there any physical conditions that will inhibit job performance? o Black outs
o Heart conditions
o Diabetes requiring insulin
o Disabilities that inhibit the ability to drive and assist passengers in the manner required by the system and ADA
o Visual impairment, i.e., color blindness/inadequate night vision o Hearing impairment
• Applicant's use of drugs and alcohol
• Has the applicant passed a drug/alcohol screen?
• Does the applicant use prescription drugs? if so, what kind? Does it affect his or her ability to drive?
• Does the applicant have a record of alcoholism or excessive drinking? Recovering or active user?
• Applicant's motor vehicle record
• Is the license free of alcohol-related or serious moving violations, i,e., reckless driving, careless driving?
• If not, how long has it been since the last serious infraction? • How many speeding tickets does the applicant have on record? • Felony conviction record search
• Does the applicant have a felony on record? if so, what type of crime did he or she commit, and how long ago was the conviction?
• Minimum age requirement
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• Since you cannot ask the age of the applicant, you can set a minimum standard by asking how long has the applicant been driving consistently? • The transit system may require a minimum of five years of driving experience which establishes a minimum age of 21.
• Personality/attitude
• Does the applicant appear to possess the ability/attitude necessary to follow procedures (especially those concerning passengers with disabilities) in a caring and supportive manner?

3.2 ORIENTATION AND TRAINING OF EMPLOYEES

Even when the best personnel have been hired, a comprehensive orientation and training program is necessary to assist in achieving the safety and operating goals of our company. Effective orientation and training programs will provide the driver with all of the skills and information he or she will need to respond to daily, unknown and/or unexpected events. A strong base of knowledge will assist the employee in effectively preventing accidents/incidents or responding to accidents/incidents that do occur.

3.2.1 Safety Training for Drivers, Dispatchers and Road Supervisors

Training will prepare a driver for typical hazards that will be encountered. This includes identification of the conditions that lead to hazards; the nature of the hazards; clues that signal an impending hazard; actions that can break the chain of events leading to an accident/incident; and the specific skills and actions that must be performed by the trainee, Furthermore, the trainee must understand how these actions increase safety so that he or she can directly evaluate the effectiveness of various options during a crisis situation. Issues specific to the vehicle operation that should be addressed in driver training programs include the following:

• General orientation to system, policies and procedures. • Federal, state and local safety rules and regulations including OSHA, state safety belt and right to know laws.
• Familiarization with transit system properties and the local area; route training; location of fire, police and medical facilities; supervisory notification. • Use and adjustment of operator's seat, seat belt, mirrors, sun visor, windshield wipers, etc.
• Vehicle pre-trip and post-trip inspections.
• Safe operation and limitations of brakes, doors, door interlocks, kneeling system, wheelchair lift, etc.
• Proper use of communications systems.
• Safe acceleration/deceleration rates.
• Safe driving practices, traffic hazards, evasive maneuvers, target fixation, threshold braking. (Classroom defensive driving is not sufficient.) • Night, expressway and severe weather driving conditions.

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• Transit system emergency procedures.
• Operator's obligations under ADA.

Driver training issues directly related to passenger safety include the following:

• The causes of on-board passenger injuries and how to minimize them (i.e., slip and falls, sudden stops, etc.)
• Understanding of the physical limitations of the employee (ergometric), elderly and disabled passengers (i.e., sensitivity training)
• It should be noted that ADA requires transit systems to document the achieved proficiency level of operators upon completion of sensitivity training and how their proficiency was determined. Pass/fail tests are an effective gauge of competence if the test measures the proficiency of the required task. Refresher training is also mandated to insure retention of required proficiency.
• Bus overcrowding
• First aid and CPR
• Passenger Assistance Techniques - training materials which provide appropriate physical assistance methods
• On-board altercations and appropriate actions by the driver • Passenger illness
• Accidents and incidents
• The role and responsibilities of the operator in emergency situations • Emergency/standard operating procedures for collisions, fire, etc. • Passenger Evacuation Procedures
• Location and use of emergency exits and equipment
• How to complete accident/incident forms
• Bus stop safety concerns
• Other issues identified by Disabled Advisory Committee/Project Action • Lift operations, including how to operate the manual "back-up" system if the power source should fail
• Wheelchair securement and passenger restraints

3.2.2 Safety Training and Orientation for Maintenance

The safety orientation and safety training of maintenance employees should include the following:

• Familiarization with shop and overall facility
• Emergency evacuation plan
• Management policies
• Scope and objectives of bus maintenance program
• Applicable federal, state, local, and transit system rules and regulations, including ADA, EPA, OSHA
• Use and care of personal protective equipment
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• Safe operation and maintenance of on-board bus equipment • Communications equipment
• Safe operation of shop tools and equipment
• Emergency/road call procedures
• Drug/alcohol use policy
• Hazardous waste disposal procedures, spill containment and reporting • Maintenance documentation requirements and procedures • Operational safety issues, i.e., blood-borne pathogens, right-to-know • Proper preventative maintenance procedures for lift equipment and other items provided for accessibility

3.3 PERSONNEL EVALUATION AND TERMINATION PROCESSES

A written policy and procedure addressing the process, schedule, and criteria on which an employee's job performance is to be evaluated. These criteria should objectively evaluate job performance, not "subjective aspects of personality." Employee performance evaluations should NEVER be a surprise.

3.3.1 Probationary Period

During the employee's probationary period, several evaluations should be conducted with the individual and his or her immediate supervisor. These evaluations should state not only what the individual is doing well, but also what items need improvement and specific dates for courses of action to be taken to meet the agency standard.

3.3.2 Annual Evaluations

Annual evaluations are equally as important. If supervisors are coaching and working with employees on a continual basis, evaluations should only reflect what has transpired and what is expected during the next year. Evaluations should reflect those items that need improvement, necessary corrective methods or procedures, and a review time- line. Evaluations should not be a "surprise."

3.3.3 Employee Personnel File

A personnel file should be maintained for each employee. This file is private and should be viewed and revised only by authorized personnel as stated within the personnel policy. Employees may view their own file under supervision, but should not be able to remove or copy items out of the file. Suggested items to be assembled into the file include the following:

• Driver's application, including references
• All previous evaluations
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• All training courses taken, dates and results of tests • Copies of license checks and current license
• Medical exams
• Written reprimands, commendations
• Written or documented verbal passenger compliments or complaints • Other items required by state or federal law

3.3.4 Discipline and Termination

Unfortunately, not all employees are able to perform job functions to the level required by the system. Employees performing in an unsatisfactory manner, even after assistance by the supervisor, should be terminated for the safety and effectiveness of the system.

4. PROCEDURES TO PREVENT BUS

ACCIDENTS/INCIDENTS

The development, implementation and dissemination of adequate policies and procedures is an essential element of a program to prevent the occurrence of accidents/incidents. Policy considerations and procedures require considerable forethought and analysis of the potential alternatives. They also require an evaluation of both short term and long term effects and consequences. It is imperative that all policies and procedures be in writing and routinely updated. To ensure knowledge and understanding as well as compliance, policies and procedures should be included in the training program for new employees and refresher training for present employees.

4.1 PREVENTIVE MAINTENANCE

The goal of an effective preventive maintenance program should be to have no vehicle breakdowns or unscheduled repairs between preventive maintenance inspections. To achieve this goal of vehicle operation without inadvertent breakdowns, the institution of a program to identify potential maintenance problems before they result in vehicle breakdowns. To play a significant role in accident/incident prevention, a properly executed and timed preventive maintenance program must be developed based on manufacturer recommendations on preventive maintenance needs, the transit system operating data, and the experience of the transit system personnel. Communication between drivers and maintenance personnel is an essential element of such a program.

Perhaps the most neglected "road to safety" is the interface between the maintenance function and operations. In many systems, the prevailing attitude voiced by the maintenance staff is that "The drivers break 'em, we fix 'em." Conversely, the drivers claim that "We tell 'em, but they never fix 'em." In many drivers' opinions, the best STI Accident/incident Prevention Manual Page 20

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indicator that the shop has looked at a defect is the perennial glob of grease left somewhere (usually on the seat) by a mechanic.

Failure to take the driver's role in preventive maintenance seriously, or to understand the need for communication, will result in poor interdepartmental relations. It will also lead to the nightmare of "breakdown maintenance" with an increase in the unscheduled maintenance required of the transit vehicles. In other words, failure to motivate and train drivers to administer proper pre-trip/post-trip inspections (including some diagnostics) will only provide an incentive against reporting defects.

The preventive maintenance program must specifically match the needs/demands of each system and take into account the Original Equipment Manufacturers'(OEM) recommendations on the type and proper intervals for maintenance. Vehicle or system operating data can be analyzed to assist in identifying failure modes and the appropriate maintenance intervals. Experimental components should be monitored on a strict schedule. If the inspection and maintenance program is properly monitored, important adjustments or changes in the preventive maintenance program may be identified before failures occur. As an example, routine inspections may reveal wear patterns in brakes which indicate deviations from the OEM anticipated component life, and if the preventive maintenance program is modified, it will prevent premature mechanical failure. Safety department personnel should be involved in the development of the preventive maintenance program and the specific maintenance procedures. This involvement will ensure familiarity with the procedures and processes should questions regarding maintenance arise during accident/incident investigations. In addition, safety personnel may assist maintenance managers by alerting them to potential accident/incident exposures created by hazardous procedures identified during the procedure review.

Finally, continuous pro-active training in procedures and proper preventive maintenance practices is critical to successfully preventing accidents/incidents due to mechanical defects/failures. An improperly trained mechanic will not be capable of detecting potentially defective components during inspections or properly completing follow-up repairs. Accident/incident prevention practices can be emphasized during such training as well.

Accident/incident prevention is not a stand-alone function of the safety department.

Failure to address the role of the maintenance department in accident/incident prevention can only result in failure of a significant part of accident/incident prevention efforts. Appendix H presents an example of a maintenance checklist that could be employed when determining if these are vehicle mechanical problems.

4.2 PRE-TRIP/POST-TRIP INSPECTIONS

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Proper pre-trip and post-trip inspections are a key building block to the foundation of operating a fleet free of potential accident/incident causing mechanical defects. A brief pre-trip/post-trip inspection of the vehicle to ensure that safety systems are operating and the vehicle is not likely to become disabled before completing its route. The necessary discipline for enforcing consistent, high quality driver inspections must be initiated, supported, and maintained by all management personnel in every department and at all levels. Sufficient time must be provided for the drivers to conduct proper pre- and post-trip inspections. Clean, well-lit areas should be provided where the inspection can be conducted. Large convex mirrors attached to buildings, sign posts, etc, in the inspection area will assist drivers in completing inspections of lighting systems expeditiously.

For several reasons, training for pre-trip/post-trip inspections should involve maintenance personnel and be constantly emphasized during all driver training. First, it provides a chance for drivers and maintenance personnel to get acquainted. A tour of the maintenance facility should be conducted to show drivers and other personnel the types of preventive maintenance and repair work done in the shop. Show and tell sessions are very effective for getting drivers to understand proper operation of components, proper inspection of tires, and proper defect card/form completion. The importance of complete defect descriptions in assisting problem diagnosis and preventing repeat repairs should be emphasized. The chain of command in the maintenance shop should be outlined, complete with procedures for reporting potential rework/repeat repairs.

Maintenance management personnel must dedicate themselves to breaking down the communication barriers that exist between many drivers and mechanics. Training sessions and policies that explain that drivers are "internal customers" should be developed. Mechanics, responsible for receiving defect cards and translating them into suitable repairs, should be instructed to resolve the reported problem without "glossing over" potential major defects.

The pre-trip/post-trip inspection should at least include an inspection of the following safety systems:
• Steering
• Brakes
• Headlights, clearance and identification lights, turn signals, stop lights, tail lights, tag lights
• Mirrors
• Back-up alarms
• Tire inflation, sidewall and tread condition
• Fuel/hydraulic/cooling systems for obvious leaks
• Door operation and proper interlock operation
• Passenger signal system
• Radio
• Lift, full cycle and securement devices
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• Horn
• Fire extinguisher, first aid kit, flares, triangles, dragging equipment • Windshield wipers/washers
• Broken stairs or other tripping hazards
• Loose seats, grab rails, etc.
• Operational emergency exits (roof and windows)

Pre-trip inspections are limited in depth and will not identify all safety problems.

Thorough shop inspections and the appropriate maintenance, preventive or corrective, will minimize the potential for accidents/incidents or disabled vehicles. Preventive maintenance is intended to minimize or anticipate potential system or component failures before they occur. Examples of preventive maintenance are periodic oil changes, vehicle tune-ups, the replacement of light bulbs at set intervals, and regular lift cycling. Corrective maintenance occurs when a component or system fails. Corrective maintenance requires the vehicle be taken out of service. Frequency of inspection and an example of items that should, as a minimum, be inspected are contained in Appendix I.

4.3 POLICY ISSUES AND PROCEDURES CONCERNING LIFTS

Drivers must understand the policies concerning lifts and the procedures for normal and emergency operations. Consideration should be given to the following concerns:
• Is full operation or cycling of the lift required in the vehicle pre-trip inspection or check prior to start of service?
• If the lift fails, how does the manual back-up work and are all the parts required to operate the system in the proper place?
• Is the driver allowed to stand on the lift while assisting passengers? This may help the passenger feel safer and initially may be easier for the driver. However, if the lift fails or the driver falls, there is no one to handle the emergency situation or passengers. Who will assume that responsibility if the driver is injured? • What procedures will the driver use in handling wheelchairs? Training should include actual hands-on training with wheelchairs. Classroom discussions without hands-on training cannot teach the driver how to safely handle a person in a wheelchair, or to properly secure the mobility device and/or passenger. • How should drivers be trained to operate vehicles? A recognized, systematic training program should be provided. The time to practice is during training, not with the passengers or in an emergency.
• Will all mobility devices and wheelchairs be allowed on the lift with the passenger?
• Will passengers be allowed to stand on the lift platform? This is required to be in compliance with current ADA regulations if a passenger insists on standing on the lift. However, a passenger may be vulnerable to loss of balance and may fall off the lift platform.

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o Several safety issues to be addressed include the following: not all mobility devices have brakes or will fit on the lift platform and one type of wheelchair has a gasoline engine and carries five gallons of flammable explosive gas.

4.4 POLICY ISSUES AND PROCEDURES CONCERNING RESTRAINT AND

SECUREMENT DEVICES

In transit systems where passenger restraints and wheelchair securement devices are present, the transit system should establish and clearly communicate to the employees and drivers the transit system policy on their use. Issues that need to be addressed include the following:
• Are all passengers required to use seat belts?
• Should drivers assist passengers in buckling their seat belts? • What actions should the driver take if a passenger releases the seat belt while the vehicle is moving?
• What should the driver do if a passenger refuses to wear a seat belt? • What if a passenger in a wheelchair refuses to use a lap belt? Will the driver continue on the route?
• How should we react if a passenger consistently refuses to comply with the system policies?
• How do we notify passengers or agencies of system policies, requirements and consequences?
• If the system does not provide child restraint systems, what does the driver do if a parent does not have one when boarding the vehicle?

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Driver Policy
Point System
This Driver Point System Policy has been prepared for your information and understanding of the driving practices of Southland Transit, Inc. Please read it carefully.

Upon completion of your review of this policy amendment, sign the statement below, and return it to your supervisor by the due date.

I, ____________________, have received and read a copy of the Driver Point System Policy, which outlines the policy point system, as well as my responsibilities as a driver.

I have familiarized myself with the contents of this policy. By my signature below, I acknowledge, understand, accept and agree to comply with the information contained in the Point System Amendment provided to me by Southland Transit, Inc. I understand this policy is not intended to cover every situation which may arise during my employment, but is simply a general guide to the practices and expectations of Southland Transit, Inc.

I understand that Southland Transit, Inc, Driver Point System Policy is not a contract of employment and should not be deemed as such.

______________________________________
(Employee signature)

Please return by: ______________________
(put date here)

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System Security and Emergency
Preparedness Plan
(SSE PP)
Southland Transit, Inc.

Glossary of Terms
Emergency: A situation which is life threatening to passengers, employees, or other interested citizens or which causes damage to any transit vehicle or facility or results in the significant theft of services and reduces the ability of the system to fulfill its mission.

Fatality: A transit-caused death that occurs within 30 days of the transit incident.

Injury: Any physical damage or harm to a person that requires immediate medical attention and hospitalization.

Safety: Freedom from danger.

Security: Freedom from intentional danger
Security breach: An unforeseen event or occurrence that endangers life or property and may result in the loss of services or system equipment.

Security incident: An unforeseen event or occurrence that does not necessarily result in death, injury, or significant property damage but may result in minor loss of revenue.

Security threat: Any source that may result in a security breach, such as vandal or disgruntled employee; or an activity, such as an assault, intrusion, fire, etc.

System:

System security:

System security
A composite of people (employees, passengers, others), property (facilities and equipment), environment (physical, social, institutional), and procedures (standard operating, emergency operating, and training) which are integrated to perform a specific operational function in a specific environment.

The application of operating, technical, and management techniques and principles to the security aspects of a system throughout its life to reduce threats and vulnerabilities to the most practical level through the most effective use of available resources.
management: An element of management that defines the system security requirements and ensures the planning, implementation, and accomplishments of system security tasks and activities.

Southland Transit, Inc.

SSEPP Page 2of12
System security
program: The combined tasks and activities of system security management and system security analysis that enhance operational effectiveness by satisfying the security requirements in a timely and cost-effective manner through all phases of a system life cycle.

Threat: Any real or potential condition that can cause injury or death to passengers or employees or damage to or loss of transit equipment, property, and/or facilities.

Threat analysis: A systematic analysis of a system operation performed to identify threats and make recommendations for their elimination or mitigation during all revenue and non revenue operation.

Threat probability: The probability a threat will occur during the plan's life. Threat probability may be expressed in quantitative or qualitative terms. An example of a threat-probability ranking system is as follows: (a) frequent, (b) probable, (c) occasional, (d) remote, (e) improbable, and (f) impossible.

Threat resolution: The analysis and subsequent action taken to reduce the risks associated with an identified threat to the lowest practical level.

Threat severity: A qualitative measure of the worst possible consequences of a specific threat:

Unsafe condition
• Category 1 - Catastrophic. May cause death or loss of a significant component of the transit system, or significant financial loss. • Category 2 - Critical. May cause severe injury, severe illness, major transit system damage, or major financial loss.
• Category 3 - Marginal. May cause minor injury or transit system damage, or financial loss.
• Category 4 - Negligible. Will not result in injury, system damage, or financial loss.
or act: Any condition or act that endangers life or property.

Vulnerability: Characteristics of passengers, employees, vehicles, and/or facilities that increase the probability of a security breach.

Southland Transit, Inc.

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Background
The terrible tragedy of September 11, combined with nation's continuing war on terrorism, has created a heightened threat environment for public transportation. In this new environment, the vulnerabilities of public agencies and the communities they serve to acts of terrorism and extreme violence have greatly increased. Threat assessments issued by the Federal Bureau oflnvestigation (FBI) have consistently placed public transportation at the top of the critical irljrastructure protection agenda, along with airports, nuclear power plants, and major utility exchanges on the national power grid.

To establish the importance of security and emergency preparedness in all aspects of our organization, Southland Transit, Inc. has developed this System Security and Emergency Preparedness (SSEP) Program Plan. This SSEP Program Plan outlines the process to be used by our company to assist our transit clients in making informed decisions that are appropriate for our operations, passengers,· employees and communities regarding the development and implementation of a comprehensive security and emergency preparedness program.

As a result of this program, we hope to achieve not only an effective physical security program, but also to enhance our coordination with our transit agency clients and local and regional law enforcement agencies. Improved communication will increase their awareness of our resources and capabilities, and improve our readiness to support their efforts to manage community-wide emergencies.

In order to be effective, the activities documented in this SSEP Program Plan focus on establishing responsibilities for security and emergency preparedness, identifying our methodology for documenting and analyzing potential security and emergency preparedness issues, and developing the management system through which we can track monitor our progress in resolving these issues.

1. Goals
The SSEP Program provides our company with a security and emergency preparedness capability that will:
~ Ensure that security and emergency preparedness are addressed during all phases of system operation, including the hiring and training of personnel; the procurement and maintenance of equipment; the development policies, rules, and procedures; and coordination with local public safety and community emergency planning agencies ~ Promote analysis tools and methodologies to encourage safe system operation through the identification, evaluation and resolution of threats and vulnerabilities, and the on­ going assessment of our capabilities and readiness
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=> Create a culture that supports employee safety and security and safe system operation (during normal and emergency conditions) through motivated compliance with rules and procedures and the appropriate use and operation of equipment

2. Objectives
In this new environment, every threat cannot be identified and resolved, but we can take steps to be more aware, to better protect passengers, employees, facilities and equipment, and to stand ready to support community needs in response to a major event. To this end, our SSEP Program has five objectives:

1. Achieve a level of security performance and emergency readiness that meets or exceeds the operating experience of similarly-sized companies around the nation

2. Increase and strengthen community involvement and participation in the safety and security of our system

3. Develop and implement a vulnerability assessment program, and based on the results of this program, establish a course of action for improving physical security measures and emergency response capabilities

4. Expand our training program for employees, volunteers and contractors to address security awareness and emergency management issues
Philosophy
Southland Transit, Inc. hopes to ensure that, if confronted with a security event or major emergency, our personnel will respond effectively, using good judgment, ensuring due diligence, and building on best practices, identified in drills, training, rules and procedures.

This level of proficiency requires the establishment of formal mechanisms to be used by all personnel to identify security threats and vulnerabilities associated with our operations, and to develop controls to eliminate or minimize them. The SSEP Program also requires process for:

1. Coordinating with local law enforcement and other public safety agencies to manage response to an incident that occurs on a transit vehicle or affects transit operations, and

2. Identifying a process for integrating our resources and capabilities into the community response effort to support management of a major event affecting the community.

Southland management expects all employees, especially those working directly with passengers, to support the SSEP Program.

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Division of Responsibilities
All Personnel
All Southland employees must understand and adopt their specific roles and responsibilities, as identified in the SSEP Program, thereby increasing their own personal safety and the safety of their passengers, during normal operations and in emergency conditions.

To ensure the success of the SSEP Program, all personnel must participate by:

1. Immediately reporting all suspicious activity, no matter how insignificant it may seem, to the their immediate manager or dispatcher;

2. Immediately reporting all security incidents

3. Using proper judgment when managing disruptive passengers and potentially volatile situations

4. Participation in all security and emergency preparedness training, including drills and exercises

5. Becoming familiar with, and operating within, all security and emergency preparedness procedures for the assigned work activity

6. Accurately completing all appropriate reports.

Chief Operating Officer
After insuring coordination with our clients, the Chief Operating Officer (COO) has the overall authority to develop and execute the company's SSEP Program. Ultimate accountability for implementation of the SSEP Program rests with the COO. In addition, the COO is responsible for the following specific activities:

1. Ensuring that sufficient resources and attention are devoted to the SSEP Program, including:
o Development of standard operating procedures related to employee security duties;
o Development and enforcement of safety and security regulations; o Development emergency operating procedures to maximize transit system response effectiveness and minimizing system interruptions during emergencies and security incidents;
o Provision of proper training and equipment to employees to allow an effective response to security incidents and emergencies.

2. Development of an effective notification and reporting system for security incidents and emergencies.

3. Designating a Point of Contact (POC) to manage the SSEP Program for each client agency.

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4. Communicating security and emergency preparedness as top prioritie$ to all employees.

5. Developing relations with outside organizations that contribute to the SEPP Program, including local public safety and emergency planning agencies.

SSEP Program Points of Contact (POC)
To ensure coordinated development and implementation of the SSEP Program, the COO has designated each Project Manager as the Security and Emergency Preparedness Point of Contact (POC) for development and implementation of the SSEP Program. Each POC, who reports directly to the COO for SSEP purposes, has been granted the authority to utilize resources to develop the SSEP Program and Plan, to monitor its implementation, and to ensure attainment of security and emergency preparedness goals and objectives.

The POC has the responsibility for overseeing the SEPP Program on a daily basis. The POC will be the direct liaison with their operators and dispatchers, regarding the Program. The POC will also serve at the Southland's primary contact with their client agencies and associated public safety authorities. To the extent that liaison is necessary with state and federal agencies, the COO will serve as the lead liaison for the company.

In managing this Program, the POC will:

1. Be responsible for successfully administering the SSEP Program and establishing, monitoring, and reporting on the system's security and emergency preparedness objectives.

2. Review current project safety, security and emergency policies, procedures, and plans, and identifying needed improvements.

3. Develop and implement plans for addressing identified improvements.

4. Coordinate with local public safety agencies, local community emergency planning agencies, and local human services agencies to address security and emergency preparedness; including participation in formal meetings and committees.

5. Develop, publish, and enforce reasonable procedures pertinent to agency activities for security_ and emergency preparedness.

6. Provide adequate driver training and continuing instruction for all employees (and volunteers and contractors) regarding security and emergency preparedness.

7. Ensure performance of at least one emergency exercise annually.

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Supervisors
Supervisors are responsible for communicating the company's security policies to all employees. For this reason, supervisors must have full knowledge of all security rules and policies. Supervisors must communicate those policies to operations personnel in a manner that encourages them to incorporate SSEP practices into their everyday work. The specific responsibilities of supervisors include the following.

1. Having full knowledge of all standard and emergency operating procedures.

2. Ensuring that drivers make security and emergency preparedness a primary concern when on the job.

3. Cooperating fully with the SSEP Program regarding any accident investigations as well as listening and acting upon any security concerns raised by the drivers.

4. Immediately reporting security concerns to the POC.

In addition, when supporting response to an incident, supervisors are expected to:

1. Provide leadership and direction to employees during security incidents;

2. Handle minor non-threatening rule violations;

3. Defuse minor arguments;

4. Determine when to call for assistance;

5. Make decisions regarding the continuance of operations;

6. Respond to fare disputes and service complaints;

7. Respond to security related calls with police officers when required, rendering assistance with crowd control, victim/witness information gathering, and general on­ scene assistance;

8. Complete necessary security related reports;

9. Take photographs of damage and injuries; and

10. Coordinate with all outside agencies at incident scenes.

Drivers
In addition to the general responsibilities identified for ALL PERSONNEL, drivers are responsible for exercising maximum care and good judgment in identifying.and reporting suspicious activities, in managing security incidents, and in responding to emergencies. Each driver will:

1. Take charge of a security incident scene until the arrival of supervisory or emergency personnel;

2. Collect fares in accordance with company policy (if applicable);

3. Attempt to handle minor non-threatening rule violations;

4. Respond verbally to complaints;

5. Attempt to defuse minor arguments;

6. Determine when to call for assistance;

7. Maintain control of the vehicle;
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8. Report all security incidents to company dispatch;

9. Complete all necessary security related reports; and

10. Support community emergency response activities as directed by company policies and procedures.

Other Personnel
Other personnel who support our operations also have responsibilities for the SSEP Program.

Dispatchers are expected to:
• Receive calls for assistance
• Dispatch supervisors and emergency response personnel • Coordinate with law enforcement and emergency medical service communications centers
• Notify supervisory and management staff of serious incidents • Establish on-scene communication
• Complete any required security related repo1is
• Provide direction to on-scene personnel
Mechanics are expected to:
• Report vandalism
• Report threats and vulnerabilities of vehicle storage facilities • Provide priority response to safety and security critical items such as lighting • Maintain facility alarm systems
Threat and Vulnerability Identification
The primary method used by our operations to identify the threats to our transit systems and the vulnerabilities of the system is the collection of incident reports submitted by drivers and supervisors and information provided by local law enforcement and contractors.

Information resources include the following:
• Operator incident reports
• Risk management reports
• Bus maintenance reports
• Marketing surveys
• Passengers' letters and telephone calls
• Management's written concerns
• Staff meeting notes
• Statistical reports
• Special requests
• Type of incidents
o Crimes against persons
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o Crimes against property
o General incidents
• Disposition of incidents (same as disposition of call for service) Security testing and inspections may be conducted to assess the vulnerability of the transit system. Testing and inspection includes the following three-phase approach:
• Equipment preparedness - to ensure that security equipment is operable and in the location where it belongs
• Employee proficiency - To ensure that employees know how and when to use security equipment
• System effectiveness - To evaluate security by employing security system exercises.

Evaluation
The SSEPP is a "living document" and needs to address issues associated with system security and emergency preparedness on a timely and proactive basis. It is incumbent upon all appropriate Southland personnel to constantly evaluate the effectiveness of the SSEPP as well as implementation. The SSEPP POC's will work with their respective clients to ensure that the SSEPP is evaluated for effectiveness on at least an annual basis. The tools and checklists that follow will provide the basis for conduct of these regular evaluations.

Points of Emphasis

1. Awareness - Train all security and maintenance personnel to spot suspicious-looking or unfamiliar people or objects.

2. Communication - Teach employees and/or tenants the importance of awareness; encourage them to identify and report anything that appears out-of-the-ordinary.

3. Screening - Develop and implement systems for identifying and controlling visitor access to the building.

4. Inspection - Establish strict procedures for the control and inspection of packages and materials delivered to the building, particularly those intended for critical areas.

5. Procedures - Instruct all personnel, particularly telephone switchboard or reception personnel or Call Center personnel, on what to do if a bomb threat is received.

6. Surveillance - Instruct security and maintenance personnel to routinely check unattended public or open areas, such as rest rooms, stairways, parking garages and elevators.

7. Lighting- Make sure that all of the facility's access points are well-lit.

8. Systems Awareness - Unexpected interruptions in the building's fire or security systems may not be coincidental; train personnel to identify and address them immediately.

9. Local Authorities - Contact local government agencies to determine their procedures for dealing with bomb threats, search, removal and disposal.

10. Contingency - Assure adequate protection and off-site backup for classified documents, proprietary information, critical records and activities essential to the operation of your business.

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(
System Security Considerations

1. Security Plan established, which addresses all operations modes and contracted services

2. System security responsibilities and duties established

3. Personal safety awareness/education programs for passengers and employees and community outreach

4. Security equipment regularly inspected, maintained and functionally tested; including personal equipment issued to security personnel

5. Contingency SOPs developed; drills and table-top exercises conducted for extraordinary circumstances, includ_ing - terrorism (including chemical/ biological agents/ weapons of mass destruction); Riot I Domestic unrest; Catastrophic natural events; and System-wide communications failure

6. Planning, coordination, training and mutual aid agreements with external agencies (state, local police, MTA, etc.)

7. Security SOPs reviewed on a regular basis and updates made as needed to Security Plan

8. Security equipment installed, inspected, and maintained to monitor trespass activities

9. Data collection established for all security issues I incidents; analysis performed and recommendations made; document control established, including follow-up

10. Security risk/vulnerability assessments conducted, documented and reviewed

11. Contingency plans for loss of electrical power and radio or phone communications

12. Standard Operating Procedures for critical incident command, control, and service continuation/ restoration

13. Security training provided to all staff levels (from front-line "eyes and ears" concept to professional level security training)

14. Background checks on employees and contractors (where applicable)

15. Regular assessments of employee security proficiencies conducted

16. Employees issued quick reference guidelines for security situations

17. Emergency contacts list developed I current I and responsibilities for call-outs identified

18. Visitor, deliveries and contractor facility access procedures developed I visible identification required

19. Security checklists developed and regularly used for verifying status of physical infrastructure and security procedures

20. Agency employees identifiable by visible identification and/or uniform

21. Policy and procedures in place for facilities key control.

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SUMMARY
As a transit service contractor, we have a supporting role in the development of an effective SSEPP. The primary responsibility is with our government agency clients. As a result our success will be mixed; some of our clients will ignore the threats which will make our efforts more difficult and less successful. Some of our clients will try to develop plans without our involvement which will make their success less likely. Some of our clients will embrace this effort and welcome your participation which will make the effort the most effective. Our job is to make the effort in every case.

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VEHICLE SAFETY PROGRAM
PLAN

SECTION TITLE
MANAGEMENT 1 COMMITMENT
COMPLIANCE 2 RESPONSIBILITIES
3 DRIVERS - INITIAL
HIRE

QUALIFICATIONS
Southland Transit, Inc.

SSEPP
Appendix A Vehicle Safety Program Implications

COVERED POLICIES AND PROCEDURES
);;> Safety Policy Statement
);;> Chief Operating Officer
);;> Drivers, mechanics and others operating
agency vehicles (and volunteers)
);;> Vehicle Accident Prevention (VAP)
Committee
);;> Safety incentive program(s)
);;> Qualifications
);;> Initial Training
);;> Application
);;> Interviews
);;> Physical Requirements
);;> Age
);;> Knowledge of English
);;> Driver Licensing
);;> Operating Skills
);;> Criminal Record Checks
);;> Ability to perform simple math
);;> Reasonable knowledge of the service area
and ability to read basic maps
);;> A road test given by a designated Agency
Supervisor is required
);;> A written driving skills test is required

ADDITIONAL ISSUES IN SSEP PROGRAM
./ MEMORANDUM AUTHORIZING SYSTEM

SECURITY AND EMERGENCY

PREPAREDNESS(SSEP)PROGRAM
./ EXPANDED TO ADDRESS SSEP PROGRAM
./ CREATION OF SSEP PROGRAM POINT OF

CONT ACT (POC)
./ COMMITMENT TO ADDRESS SSEP ISSUES IN
HIRING
./ EXPANSION OF NEW HIRE APPLICATION

PROCESS TO EMPHASIZE IMPORTANCE OF

SAFETY, SECURITY AND EMERGENCY

PROCEDURES
Appendix A
Page I of5

VEHICLE SAFETY PROGRAM
PLAN

SECTION TITLE

INITITAL TRAINING

DRIVERS-
ONGOING 4 SUPERVISION AND

TRAINING

EMERGENCY
5 DRIVING

PROCEDURES
Southland Transit, Inc.

SSE PP

COVERED POLICIES AND PROCEDURES
~ Agency Policies and Procedures
~ Federal and State Guidelines and
Regulations
~ Pre and Post rrip Inspections
~ Vehicle Familiarization
~ Basic Operations and Maneuvering
~ Special Driving Conditions
~ Backing
~ Bad Weather
~ Boarding and Alighting Passengers
~ Defensive Driving Course (DOC)
~ Passenger Assistance Training - DRIVE
Training
~ On Road
~ Training - refresher/retraining
~ Evaluation and supervision
~ Motor vehicle record checks
~ Annual physical examination
~ Safety meetings
~ Seat-belt usage
~ Discipline/recognition
~ Preventable accidents/injuries
~ Emergency driving procedures
~ Accident causes
o Slippery road surfaces
o Driving at night
o Driving through water

ADDITIONAL ISSUES IN SSEP PROGRAM
./ ADDITIONAL TRAINING TO ADDRESS

SECURITY AWARENESS, REPORTING

SUSPICIOUS ACTIVITY, REPORTS AND

DOCUMENTATION, AND PRE AND POST TRIP

INSPECTIONS
~ ADDITIONAL REFERSHER TRAINING AND
"PROFICIENCY TESTS" FOR KNOWLEDGE OF

EMERGENCY PROCEDURES
./ ADDITIONAL RESPONSIBLITIES FOR

SUPERVISION
./ EXPANSION OF EMERGENCY PROCEDURES

TO INCLUDE ADDITIONAL SECURITY AND

EMERGENCY CONDITIONS
~ EXPANSION OF EMERGENCY PROCEDURES

TO INCLUDE SUPPORT OF COMMUNITY
Appendix A