WCG 2017 Employee Handbook Tobias Notes (1)

USE OF COMPANY PROPERTY AND EQUIPMENT

Employees are expected to learn and follow all operating instructions, perform
preventive maintenance, where applicable, and observe all safety practices. If you’re unsure
about the proper operation or maintenance of the Company’s property or equipment, ask your
supervisor. Property and equipment that appears damaged, defective, unsafe, or in need of
repair should be reported promptly to your supervisor.

Employees causing damage to the Company’s property and equipment may be subject
to disciplinary action up to and including immediate termination. This includes loss or damage
due to carelessness, negligence, improper use, or unsafe practices. Monetary reimbursement
to the Company may also be required if applicable.

VEHICLE AND DRIVING REQUIREMENTS

Only authorized employees may use Company vehicles. If a Company vehicle incurs
any damage while under the care or responsibility of a particular employee, that employee must
report the damage immediately and may be responsible for paying for some or all of the repair
costs. Likewise, if an employee receives a citation for any violation while operating a Company
vehicle or a personal vehicle while on Company business, the employee is responsible for
paying any fine or penalty incurred and may be subject to discipline, up to and including
immediate termination. All such violations or citations must be reported to your immediate
supervisor immediately. Failure to immediately report a violation or citation may result in
discipline, up to and including immediate termination.

Drinking alcoholic beverages or otherwise violating the drug and alcohol policy is
prohibited in a Company-owned vehicle or in a personal vehicle while on Company business.
Violation of this rule may result in disciplinary action, up to and including immediate termination.

Unacceptable Driving Records: For employees who drive vehicles in the course of their
duties, an accident, a citation for D.U.I., D.W.I., or any other serious driving violation or
citation (even those occurring off-duty) may create an unacceptable driving record. An
unacceptable driving record may result in an employee not being allowed to drive a
Company vehicle or other discipline, up to and including immediate termination.

Seatbelts: All employees must wear a seatbelt while driving or riding in any vehicle, either
personal or Company-owned, while going to or from work, and at all times while
performing Company business. Furthermore, the Company encourages all of its
employees to wear seatbelts at all times, as required by state law.

Use of Cellular Telephones While Driving: For safety reasons, we ask that employees not
talk on their cellular telephones while driving on Company business, unless the cellular
telephone has a “hands-free” mode. Texting is not permitted while operating a vehicle on
company business.

Use of Personal Vehicles for Company Business: Privately owned vehicles may be used by
Winsor Capital employees for business duties. While the employee’s own vehicle
insurance is the primary responding insurance, Winsor Capital’s vehicle insurance may
be accessed if there is a serious accident. Employees who regularly (given a car

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allowance or regularly submitting mileage expense reimbursement requests) use their
own vehicle for company business should adhere to the following rules:

• Maintain a valid driver’s license and acceptable driving record;
• No use of motorcycles for company business;
• Maintain vehicle insurance with minimum 100,000 per person/300,000 per

occurrence/50,000 liability property damage limits of liability and Winsor Capital
or WCG will be added as an additional insured on the automobile policy;
• Provide copies of each new/renewal automobile insurance policy summary sheet
or insurance verification card (both provided by an automobile insurance carrier)
to Winsor Capital’s HR Department;
• Follow all Federal, state and local motor vehicle regulations;
• Use seat belts and make sure all passengers also use seat belts; and
• Immediately notify management if the above criteria cannot be met for any
reason.

Motor Vehicle Record Checks: For applicants and/or employees who drive vehicles (personal
or company vehicles) in the course of their duties, we will check motor vehicle records
(“MVR”) of all applicants prior to making them offers of employment and of all current
employees at least two (2) times each year.

Reporting of Traffic Incidents: Employees who drive either personal or Company vehicles in
the course of their duties must report in writing to their supervisor any citation, D.U.I.,
D.W.I., violation or accident (“incidents”) that occur at any time (on or off duty) after
beginning employment with the Company. Failure to report such incidents within forty-
eight (48) hours of occurrence (i.e., accident or receipt of citation, not conviction on the
charges) may result in discipline, up to and including immediate termination.

Driver’s License: All employees who drive as part of their job duties must have a valid driver’s
license for the state in which the employee resides. Any employee whose driver’s
license is suspended or revoked must report the suspension or revocation to the Human
Resources Representative within 24 hours of the suspension or revocation.

WORKPLACE CHEMICALS

The Company maintains a Hazard Communication Program which includes lists of all
chemicals with which you work which may be hazardous. We also maintain copies of Material
Safety Data Sheets (MSDS) on each chemical, which explain how to safely work with that
chemical, and a written description of our program. We will provide training before you are
assigned to work with or be exposed to a chemical that OSHA has declared “hazardous” in any
way. Before you start a job using chemicals, you should always read container labels or consult
with your supervisor about the MSDS, including what, if any safety equipment including
personal protective equipment [PPE] you should use. You should evaluate any unusual or non-
routine task for chemical hazards and discuss with your supervisor or manager if necessary.
Immediately notify your supervisor of any chemical containers which are leaking, are unlabeled,
or where you are uncertain of how to dispose of a chemical.

If you buy new chemicals, always obtain a copy of the MSDS and give it to your
supervisor before you use the chemical.

Employee Handbook 6/1/2012 Page 50

Copies of our Hazard Communication materials may be obtained from your supervisor.

WORKPLACE SECURITY

To provide a safe workplace for our employees and to provide a comfortable and secure
atmosphere for our guests and others with whom we do business, the Company will not tolerate
any violent acts or even threats of violence.

On Company premises: Any employee who commits or threatens to commit any violent act
against any person while on Company premises will be subject to immediate
termination. The Company premises include our roadways and parking lots.

Off Company premises: Any employee who, while engaged in Company business off the
premises, commits or threatens to commit any violent act against any person will be
subject to immediate termination. Even when off the premises and not involved in
Company business, an employee who commits or threatens to commit a violent act
against another person will be subject to immediate termination, if that threat or violence
could adversely affect the Company or its reputation in the community.

Reporting/investigation procedure: Any employee who is threatened with or subjected to
violence, or who becomes aware that another individual has been threatened with or
subjected to violence, should immediately notify his or her supervisor or someone else in
management. Employees are urged to take all threats seriously. Reports of threats or
violence will be carefully investigated; employee confidentiality will be maintained to the
fullest extent possible; and, when necessary, appropriate action taken to insure the
continued safety of our employees and the public.

PERSONAL APPEARANCE

Our Company’s professional atmosphere is maintained, in part, by the image we present
to our guests. We expect all employees to present a neat, well-groomed appearance and a
courteous disposition. These qualities go further than any other factor in making a favorable
impression on the public and your fellow workers. Personal appearance reflects the degree of
pride one takes both in oneself and in the work one does to meet guest’s needs. Please keep
in mind whether you are required to wear a uniform or not, the following hygiene and
appearance guidelines are to be followed.

The Company will not apply the Personal Appearance policy in a discriminatory or
harassing manner based on race, religion, color, sex, gender identity, sexual orientation,
national origin, ancestry, citizenship status, uniform service member status, marital status,
pregnancy, age, protected medical condition, genetic information, disability, or any other
protected status in accordance with all applicable federal, state and local laws. Any employee
who would like to request an accommodation under the Personal Appearance policy for any of
the above reasons should contact Human Resources. All reasonable requests will be
accommodated unless they cause the Company an undue hardship.

No article of clothing can be too tight or too baggy. Clothing must not expose the chest,
armpits, stomach, waistline or backside including when bending over, sitting down, or otherwise
moving about. The Company, in its sole discretion, will determine when clothing does not meet
these requirements.

Employee Handbook 6/1/2012 Page 51

Good personal hygiene is also important in terms of our guests’ favorable opinion and in
terms of your respect for your fellow employees. Accordingly, employees are expected to come
to work in a clean condition.

Employees are expected to observe our Personal Appearance Policy at all times while at
work. Employees who report to work in unacceptable attire or appearance may be requested to
leave work and return in acceptable attire or appearance. Such time away from work will be
without pay. Violation of this policy may result in discipline, up to and including immediate
termination of employment.

Managers are responsible for insuring that employees project a professional image and
adhere to our Personal Appearance Policy. Each manager will make the determination as to
what is appropriate in his or her department based on the amount of customer contact and
safety considerations. Employees should understand that managers may apply the policy
differently and that they are responsible for following their manager’s instructions.

PERSONAL APPEARANCE STANDARDS – FEMALE

Hair - Hair must be neat, clean and present a well-groomed appearance at all times.
Food handlers servicing the public must maintain clean and neat hairstyles. Extreme hairstyles
or color is unacceptable. Long hair must be pushed close to the head or pulled back, away
from face and securely fastened. Hairpieces/accessories such as bows, headbands, and clips
are permitted as long as they are conservative in style and color. There will be no limitation on
the length of hair if it is concealed under a wig that is in compliance with this policy.

Hairnets/Hats - It is company policy that hairnets and/or hats are to be worn in the
kitchen/food areas at all times. Employees may only wear un-branded hats or hats bearing the
Company’s brand logo.

Clothing - Both uniformed and non-uniformed employees should be certain that their
garments are clean and pressed at all times. Conservative clothing compatible to a hotel
environment or business attire is required for those who do not wear uniforms. Dress or skirt
length (including uniforms) should be no shorter than 4" above the knee. Blue jeans, tank tops,
midriff blouses, peasant style dresses and skirts are not considered professional attire and are
not acceptable.

Cosmetics - Emphasis should always be on natural appearance. Extremes in eye
shadow and lipstick should be avoided. Soft, natural shades are best. Heavily scented
powders and perfumes are discouraged. Fingernails must always be clean and neat and of
professional length. If nail polish is used, extreme colors (such as dark purple dark blue or
black) and styles must be avoided.

Jewelry - Jewelry should be kept to a minimum. Oversized earrings and excessive
numbers of bracelets/rings/earrings are not permitted. Earrings should be no greater than one
pair of earrings, and must be conservative in size, and may be worn in the ear lobe only. Other
visible piercings such as eyebrow, nose, tongue, etc. must be removed while in uniform.
Gauged piercings are not acceptable.

Tattoos - We also want to meet our guests’ expectations in terms of the Company’s
image and style. Visible tattoos are not acceptable. No employee may make visible a tattoo that

Employee Handbook 6/1/2012 Page 52

might be offensive to guests or a violation of our No Harassment Policy. Any employee who
might have such a tattoo must keep it covered while at work or while representing the Company.
Likewise, we do not want to appear extreme to our guests by the number or location of piercings
visible to a customer. As with articles of clothing, the Company managers will determine
whether particular tattoos or piercings (including earrings) should not be visible to our guests.
Please know that if tattoos or piercings are not in keeping with the image that the Company
chooses to present to its guests, you may be required to cover the tattoo and cover/remove the
piercing.


 

Shoes - Shoes must be worn at all times and conform to approved safety standards and
present a professional appearance. All housekeeping and some food and beverage positions
require specific shoes to complete the uniform. These must be purchased by the employee and
must be flat-soled, slip resistant, leather shoes with laces. If departmental requirements dictate
special shoes, your supervisor will tell you. Extreme fads and heel heights greater than 3
inches in shoes should be avoided from both a safety standpoint as well as for the sake of
appearance. Appropriate colored socks/hosiery must be worn by all uniformed and non-
uniformed staff in Housekeeping and Food & Beverage Departments. If you report to work in
improper shoes, you will be released until you return with proper shoes. The following are
examples of shoes that are not acceptable for the work place: flip flops, sandals, crocs and
platforms.


 

NOTE: Exceptions to the clothing policy will be made for special work situations and
promotion events, which must be verified and approved by your department head.


 

PERSONAL APPEARANCE STANDARDS – MALE

 

Hair - Hair must be neat, clean, trimmed and present a well-groomed appearance at all
times. It is company policy that all food handlers wear a hairnet or approved headwear. Your
manager will review this requirement with you. Hair cannot extend past the top of the
shoulders, and cannot be more than 2 inches in height, or cover the eyebrows or earlobes.
Long hair must be pushed close to the head or pulled back, away from face and securely
fastened.

 

• extreme hairstyles, designs, or words cut into the hair are not allowed;
• full beards, mustaches, and goatees are permitted as long as they are neatly

trimmed, closely cropped and grown during time-off. Men who do not wear
beards, mustaches, and goatees must be clean-shaven daily;

• sideburns will not extend past the earlobes; and
• hair pieces are acceptable if color and style are conservative and conform to the

above hair standards.


 

Hairnets/Hats - It is company policy that hairnets and/or hats are to be worn in the
kitchen/food areas at all times. Employees may only wear un-branded hats or hats bearing the
Company’s brand logo.


 

Cosmetics - Cosmetics are only permitted for medical reasons. Fingernails will not
extend past the tip of the finger and nail polish, if used, will be clear.


  Employee Handbook 6/1/2012 Page 53

Jewelry - Jewelry, if any, should conform to conservative styles and be kept to a
minimum. Visible piercings must be removed while in uniform. Gauged piercings are not
permitted.

Tattoos - We also want to meet our guests’ expectations in terms of the Company’s
image and style. Visible tattoos are not acceptable. No employee may make visible a tattoo
that might be offensive to guests or a violation of our No Harassment Policy. Any employee
who might have such a tattoo must keep it covered while at work or while representing the
Company. Likewise, we do not want to appear extreme to our guests by the number or location
of piercings visible to a customer. As with articles of clothing, the Company managers will
determine whether particular tattoos or piercings (including earrings) should not be visible to our
guests. Please know that if tattoos or piercings are not in keeping with the image that the
Company chooses to present to its guests, you may be required to cover the tattoo and
cover/remove the piercing.

Shoes - Shoes must be worn at all times and conform to approved safety standards and
present a professional appearance. All housekeeping and some food and beverage positions
require specific shoes to complete the uniform. These must be purchased by the employee and
must be flat-soled, slip resistant leather shoes with laces. If departmental requirements dictate
special shoes, your supervisor will tell you. Extreme fads in shoes should be avoided from both
a safety standpoint as well as for the sake of appearance. Appropriate colored socks must be
worn by all uniformed and non-uniformed staff in Housekeeping and Food & Beverage
Departments. If you are in doubt, ask your supervisor. If you report to work in improper shoes,
you will be released from duty until you return with proper shoes. The following are examples of
shoes that are not acceptable for the work place: flip flops, sandals, crocs and platforms.

NOTE: Exceptions to the clothing policy will be made for special work situations and
promotion events, which must be verified and approved by your department head.

Uniforms - Employees provided with Company uniforms should also keep them in neat
and clean condition. Employees provided with Company uniforms must wear them at all times
when on duty. At the end of your employment, all uniforms must be returned to your
manager/supervisor. All uniforms must be returned to the hotel upon termination.

Non-Uniformed Personnel- For the ladies and gentlemen of Windsor Capital Group,
Inc. that are non-uniformed, the dress code is considered to be Business Attire unless the hotel
brand standard dictates otherwise.

Men: Suits, Sport coats, sweaters, dress slacks, dress shirts must have collars and
buttons with a tie (unless Brand specifies otherwise), and dress shoes (Brown or Black) in color.
Belt must be worn in the appropriate color and style to compliment appearance.

Female: Pant Suits, Skirt Suits, Dresses, or Dress slacks/skirt with professional blouses,
matching sweaters sets and/or blazers are permissible. Professional Dress shoes must be
worn. Heel height should not exceed 3”.

NAMETAGS

Employee Handbook 6/1/2012 Page 54

Nametags are required to be worn at all times when working. Your nametag, if
required, is part of your uniform, unapproved adornments on your nametag are not permitted. If
your nametag breaks or is lost, please see your supervisor or contact Human Resources for
repair or replacement. Failure to wear approved nametags may result in disciplinary action.
Employees may be charged for replacement of nametags.

EMPLOYMENT OF RELATIVES

The employment of immediate family members (husband, wife, children, parents,
brothers, sisters) of current employees generally is not permitted. Employment of family
members will be the decision of the General Manager and/or Regional Vice President of
Operations. We do not allow any family member to directly supervise another.

COMPANY RELATIONSHIPS POLICY

The Company has adopted this policy in recognition of its responsibility to provide
guidelines on and to caution employees of the potential problems posed by romantic and sexual
relationships with other employees. These problems include conflicts of interest, interference
with the productivity of coworkers, and potential charges of sexual harassment. These problems
can be particularly serious in situations in which one person has a position of authority over the
other, such as in a supervisor-subordinate position.

The Company does not prohibit consensual amorous relationships between employees,
but it does impose the following restrictions:

1. The Company prohibits supervisors and managers from engaging in amorous or
sexual relationships with subordinates and requires the supervisor or manager to
disclose the existence of such relationship immediately. If such a relationship
exists, supervisors and managers are required to take steps to resolve any
potential conflict of interest or impropriety created by the relationship.

2. All employees must avoid amorous or sexual relationships with other employees
that create conflicts of interest, potential charges of sexual harassment, or
discord or distractions that interfere with other employees’ productivity.

3. All employees are expected to behave in a professional manner and avoid
inappropriate displays of affection, etc., in the work environment.

Questions and clarifications will be addressed by the Human Resources Manager or a
representative in the Human Resources Department.

DISCIPLINE AND RULES OF CONDUCT

Employees are expected to observe certain standards of job performance and good
conduct. Failure to meet performance and conduct standards may subject an employee to
discipline, up to and including termination.

Because it is not possible to identify every type of unacceptable conduct and
performance, employees should be aware that conduct not specifically listed below but which

Employee Handbook 6/1/2012 Page 55

adversely affects or is otherwise detrimental to the interests of WCG, other employees, or
guests, may also result in discipline. Poor job performance and employee misconduct includes,
but is not limited to:

• Unsatisfactory work quality or quantity;
• Poor attitude (for example, rudeness, discourtesy, or lack of cooperation)
• Excessive absenteeism, tardiness, or abuse of break and meal period privileges;
• Failure to follow instructions or WCG procedures, or safety regulations;
• Insubordination
• Dishonesty
• Misusing or destroying WCG property or the property of another on WCG

premises;
• Violating conflict of interest rules;
• Disclosing or using confidential or proprietary information without authorization;
• Taking, using, or removing the property of WCG or others without authorization;
• Falsifying or altering WCG records, including the application for employment;
• Falsifying or altering your own time card, punching in or out another employee’s

time, or soliciting another employee to punch your time card;
• Interfering with the work performance of others;
• Engaging in verbal and/or physical altercations;
• Harassing, including sexually harassing, employees, guests or vendors;
• Being under the influence of, manufacturing, dispensing, distributing, using or

possessing alcohol or illegal substances on WCG property while working or not,
or while conducting WCG business;
• Gambling on WCG premises or while conducting WCG business;
• Possessing a firearm or other dangerous weapon on WCG property or while
conducting WCG business;
• Being convicted of a crime that indicates unfitness for the job or raises a threat to
the safety or well-being of the Company, its employees, guests, or property;
• Failing to report to the Company, within five [5] days, any conviction under any
criminal drug statute for a violation occurring while employed;
• Not reporting to work on time, observing the time limits for rest and meal periods,
and not obtaining approval to leave work early;
• Not Receiving authorization from a supervisor or hotel General Manager prior to
working overtime hours; and/or
• Notifying a Manager/Supervisor in advance of anticipated tardiness or absence.
(Reminder: Minimum of 2 hour notification is required)

Employment at the Company is employment at-will and may be terminated at the will of
either the Company or the employee. Your status as an “at-will” employee may not be changed
except in writing signed by you and the President of the Company.

PERSONAL MAIL

All mail delivered to the Company is presumed to be related to our business and will be
opened by the office and routed to your department. Do not use a Company address for your
personal mail or delivered packages.

Employee Handbook 6/1/2012 Page 56

EXIT INTERVIEW

Any employee leaving the Company may be asked to attend an exit interview conducted
by Human Resources, or you may receive a questionnaire mailed to your home address. The
purpose of the interview is to determine the reasons for leaving and to resolve any questions of
compensation, insurance continuation, return of Company property, or other related matters.

NOTICE OF RESIGNATION

In the event you choose to resign from your position, we ask that you give us at least two
weeks (14 day) notice. You must return all Company property (including keys and uniforms) in
your possession or for which you are responsible on your last work day.

TO SUM IT ALL UP

This Handbook highlights your opportunities and responsibilities as an employee of the
Company. By always keeping the contents of the Handbook in mind, you should be successful
in your work at Windsor Capital Group, Inc. Once again, welcome to our Company. We look
forward to working with you.

Employee Handbook 6/1/2012 Page 57

ACKNOWLEDGMENT OF RECEIPT OF EMPLOYEE HANDBOOK

I acknowledge that I have received a copy of the Windsor Capital Group, Inc. (“Company”)
Employee Handbook that covers many important Company policies, including, among other
things the Company’s Drug and Alcohol Policy, Equal Employment Opportunity Policy, No
Harassment Policy, Problem-Solving Procedure, and Electronic Communications Policy.

I will familiarize myself with the Handbook and all of its contents. I agree to abide by these and
all other Company policies. I understand that any violation of a Company policy may result in
serious disciplinary action, up to and including immediate termination of employment.

I understand that this Handbook represents only current policies and benefits and that it does
not create any expressed or implied contract of employment. The Company retains the right to
change these policies and benefits at any time, without advance notice, as it deems
appropriate.

I understand that I have the right to terminate my employment at any time, for any reason with
or without advance notice, and that the Company has a similar right. I further understand that
my status as an at-will employee may not be changed except in writing signed by the
Company’s President or Chief Operating Officer.

Signature Date
Printed Name

Employee Copy – Please keep in Handbook for reference.

Employee Handbook 6/1/2012 Page 58