Oswego Creative Employee Handbook

EMPLOYEE
POLICY AND
PROCEDURE
MANUAL

WELCOME TO OSWEGOCREATIVE

Congratulations and welcome to Oswego Creative! We are excited that you have decided to join us and look forward
to a long, happy and successful partnership together. At the heart of Oswego Creative, there are many different
talents, perspectives, and interests. We wear many hats and bring a unique, expert mindset to the world of video
production, marketing, and advertising. You were hired because we believe you can help us to deliver even higher
levels of customer satisfaction. We want to ensure that your interactions with other Oswego Creative employees
and our customers will reflect the value that Oswego Creative places on creativity, customer support, originality,
freedom, and family.
The purpose of this Manual is to introduce you to Oswego Creative, give you some information about our history,
our clients and what we do. You will also find information about your terms and conditions of employment, our
expectations around your behavior and our policies and procedures.
This Manual is by no means an exhaustive guide to your employment with us. It has been developed to act as a
resource and reference for you. The policies within this Manual are easily listed and easily accessed via the contents
page. This Manual will be updated as required as our business evolves and grows. You will be notified of any changes
as they occur. If you have any questions about the content, please do not hesitate to ask.

All the best,
Bob Mizke - Oswego Creative, Co-founder, President and Chief Creative Officer
Dom Giarratano – Oswego Creative, Vice-President & Executive Producer

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ABOUT OSWEGO CREATIVE

OUR MISSION

Oswego Creative is video production and digital marketing agency where pictures and words come together to truly
communicate the essence of our client's message.
When we combine the practice of listening with the art of creativity, we consistently deliver a product with impact.
We accomplish this with professionalism and teamwork, knowing each person involved has an important role to
play.
Oswego Creative is where our reputation matters, where our clients are happy, they came, where expectations are
surpassed, and deadlines are met.
Oswego Creative is where change is not feared, and where new ideas are welcome.
Oswego Creative is family, where our staff is happy to work.

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OUR COMPANY HISTORY

The story of Oswego Creative starts in 1978 when Bob meets Bert. Bert meets Bob. Long story short, the two get
married. After working as an anchor, reporter, producer, and writer at Channel 7 News, they quit their jobs and
decide to venture into the advertising/video production world. Before co- founding Oswego Creative, Bob was a
vice president for a large, national ad agency. Bob calls this era his Ph.D. course in business. Not only did Bob
provide clients with innovative, creative solutions, he also learned about advertising and how to run a business. In
starting Oswego Creative, Bob and Bert not only wanted to deliver high-quality executions, and they also wanted to
have the freedom to take care of their family. From their very first hire, Bob and Bert have extended that mindset
to every employee.

Oswego Creative started without any start-up money or investors. Bob and Bert knew that Oswego Creative
wouldn't grow into something huge overnight; it had to happen organically. Their goal was to start with one client
and do the best they could for them. That grew into two clients, and three, four. Oswego Creative grew by word of
mouth and by doing good work. They took care of people, did a good job, and outperformed expectations. Since its
inception more than a quarter of a century ago, Oswego Creative has evolved into a modern video production and
digital marketing agency that has worked with hundreds of clients spanning across many industries.

In 2020, Dom and Kat Giarratano – both long-time employees who have worked their way up and through the
organization partnered with Bob and Bert to usher in a new era of management and ownership, while carrying on
the traditions of Oswego, what the company is at its core and carry on the legacy that’s been created.

WHAT WE DO

Oswego Creative is a video production and digital marketing agency, and we provide the following products and
services to our clients:

VIDEO - Oswego Creative is a full-service video production company built on the idea that our customers deserve
professional, customer-focused video solutions.

MEDIA - Oswego Creative has years of experience in buying traditional media and in placing digital media across
some of the most prominent online properties.

DIGITAL - Oswego Creative develops cutting-edge, digital marketing strategies and tactics for clients that effectively
promote the videos we produce for them.

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YOUR EMPLOYMENT

PAYROLL

Your pay cycle is bi-monthly with payday on the 15th and the last day of each month. If payday falls on a weekend,
you will be paid on the Friday before. Your paycheck will be automatically deposited electronically into the bank
account details you provide to Oswego Creative. Taxation payments are automatically deducted from your salary.

Changing Pay Details
Please advise the Office Manager via email should you wish to change any payment details like changing or closing
your bank account. Please ensure you notify us before the date you want the change to be effective by. Your payroll
contact is the Office Manager, and all requests for changes should be made directly in person to the Office Manager.
Never provide any personal financial or banking information by email.

HEALTH INSURANCE

Oswego Creative is proud to deliver employee health insurance far above the norm. Oswego Creative provides
employees with Health Insurance through the NECA/IBEW Family Medical Care Health Plan. To be eligible for health
insurance, employees must complete a full month, the first to the last day of one month to qualify for coverage. For
example, if a new employee starts working at Oswego Creative on the 5th of the month, the beginning of the initial
eligibility period would not begin until the first of the following month.

After completing a full month of employment with Oswego Creative, employees must pay one month in advance for
their coverage contribution. After these two conditions have been met, then coverage will begin on the first day of
the third month of their employment. We understand that these conditions are confusing, but these conditions are
set by the NECA/IBEW Family Medical Care Health Plan, and we must abide by their policies. If you choose to utilize
Oswego Creative's health insurance plan, the Office Manager will assist you in completing the necessary paperwork.

401K

Oswego Creative provides employees with a matching 401K plan after one year of employment. Managed through
PAI, Oswego Creative will match up to 4% for the maximum employee contribution of either 10% of salary or a max
yearly contribution of $18,500. If you elect to be a part of this benefit, the Office Manager will assist you in
completing the necessary paperwork. Any contributions to the Oswego Creative 401K plan are automatically
deducted from your paycheck.

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HOURS OF WORK

Office/Business hours are generally between 8:30 am to 5 pm Monday through Friday. Your hours of work will
depend on business needs and the requirements of the work you are assigned.
Your Manager will work with you to establish your standard hours of work and break times. Oswego Creative
adopts a common-sense approach to managing work hours.
Overtime and Additional Hours
All positions at Oswego Creative are salaried positions. The nature of our business requires travel and unconventional
work hours, and we expect people to be flexible regarding work outside conventional office hours. Working overtime
or additional hours are considered part of the job, and there is no overtime rate for working extra hours. If you
cannot for some reason work reasonable additional or overtime hours you must notify your Manager as soon as
practicable with the reasons as to why.
Lateness for Work
Any absence or late arrival due to illness, injury or any other reason, and the expected duration of leave must
be personally reported to your supervisor as soon as practicable (and before your standard starting time wherever
possible). If you are unable to do this personally, you are requested to ask someone to telephone on your behalf.
After this, you must keep your Manager informed of your progress.
Wherever possible, you should make dental, medical, business or other appointments outside your regular working
hours, or try to minimize the impact of the lost time.
It is essential that you be ready to commence work at your usual starting time as other employees and the business
depend on you and your contribution.

OSWEGO CREATIVE COMPANY CREDIT CARD

All employees will receive a company credit card for all business expenses and Oswego Creative will reimburse
employees for pre-approved expenses adequately incurred by employees in the proper performance of their duties.
If an employee accidentally charges a personal expense to the company credit card it is their responsibility to
reimburse Oswego Creative for the personal expense.

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TRAVEL

Work at Oswego Creative often requires traveling for client projects. Reasonable traveling expenses, incurred in the
performance of an employee's duties, will be reimbursed, provided that all claims are made through the Tallie
expense reporting system, approved by the appropriate manager and supported with the necessary documentation.
The repayment of personal reimbursable expenses is at all times subject to the authorization of the client for whose
project the expenditure was made in support of and only after the client has reimbursed Oswego Creative for these
expenses.

Travel Requests
Employees should arrange travel and accommodation through the Oswego Creative Travel Coordinator. All travel
requests should be made to the Travel Coordinator via the Travel project in the Oswego Creative Basecamp system.

In the travel request, the employee needs to provide:

• Client
• Project Name (which should be consistent with all other projectdocumentation)
• Travel Dates
• Employees and or freelancers that will be traveling
• Location(s)
• Hotel, rental car, and other trip requirements
• Is the trip Billable or Non-Billable

Generally, air travel will be by economy class, with a carrier chosen by the Oswego Creative. If you have frequent
flyer account, please provide the account numbers to the Travel Coordinator so they can make your reservations
supporting these accounts.

Traveling with Gear
Traveling for Oswego Creative often requires traveling with gear that requires specialized cases and preparation of
traveling. Employees entrusted with traveling with gear are responsible for the safe and protective packing of these
cases. This includes wrangling cords, ensuring lenses and camera gear is set and that all light kits/sticks/stands are
safely packed. Cases are not to exceed 50 pounds (even when the airline weight allowance is higher) as the cases
cannot handle the additional weight. If a case is improperly packed and results in damage to the case or equipment,
it may be the responsibility of the employee to replace the damaged or broken equipment/case.

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Production Gear Use
From cameras to lenses to audio equipment to lighting, Oswego Creative is committed to providing our employees
with the high-quality equipment required for our employees to deliver high-end video executions. Oswego Creative
is constantly evaluating its equipment and inventory to make sure that we have the right type and volume of
equipment. Employees need to treat work equipment as if it was their own equipment and to notify their manager if
and when equipment isn't functioning properly.

Ideally Oswego Creative will have enough equipment to execute all scheduled productions. However, there might
be situations where there isn't enough equipment to cover all active productions. In those cases, Oswego Creative
will look to renting equipment in order to adequately service all productions. Oswego Creative understands that
employees may have their own personal gear that could be used to address equipment shortages. Any use of
personal equipment must be approved by Oswego Creative management prior to use. Personal gear should never
be used over Oswego Creative equipment based solely on personal preference of one piece of equipment over
another. The use of personal gear is not covered under Oswego Creative's equipment insurance and any damage
to personal equipment while in use during a Oswego Creative production may not be reimbursed or replaced.

Expenses while Traveling
Prior to leaving on any work related travel, it is the responsibility of the employee to confirm if the project has a
per diem limit on the amount that can be reimbursed for expenses on that project. If the project has a set per diem,
it is the responsibility of the employee to stay within the expense range. If the employee exceeds the per diem range,
the employee is responsible for paying the difference.

If a project does not have a set per diem, Oswego Creative employs a "common sense" approach to project
expenses. For expenses like food and beverage, the employee should ask themselves if what they are considering
ordering is something they would order if they were spending their own money. Projects without a set per diem are
not blank checkbooks and employees should use good judgement in their expense decisions. Oswego Creative
reserves the right to deem any expense excessive and require the employee to pay for the expense. Oswego Creative
utilizes the GAS's per diem calculator (https://www.gsa.gov/travel/plan-book/per-diem-rates) to determine
to establish fair expense levels while traveling.

Traveling "in town" for Work

There are times when the nature of our work includes 'in town' travel. This is defined as a location or a project
where an overnight stay is not required. Any location that is more than two-hours from our offices in Lakewood is
defined as enough of a distance to allow for a hotel stay. Anything closer than two-hours is not defined as enough of
a distance to allow for a hotel stay. In instances where a hotel stay is NOT required, we will not pay mileage
reimbursement but will allow for gas reimbursement for your personal vehicle, provided a receipt is submitted. If
you do not wish to drive your personal vehicle, and the location is less than 2-hours away, please carpool with your
colleagues. Employees have an option of driving their personal vehicle to a location that requires a hotel stay, and we
will reimburse for gasoline, but not for mileage.

Alcohol Consumption while Traveling
Good judgement should be used in regard to expenses associated to consumption of adult beverages when
traveling. Some clients will not reimburse Oswego Creative for expenses associated with the consumption of
alcohol. It is the responsibility of the employee to make sure that it is OK to consume alcoholic drinks as part of
a reimbursable expense.

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Oswego Creative policy is only one alcoholic drink can be included in a client reimbursable expense. If the employee
would like to have a second alcoholic drink, it is their responsibility to personally pay for these additional drinks.
Additionally, alcoholic drinks should never be consumed in the course of a workday and only ordered after work has
concluded for the day.

Receipts
For all work-related expenses employees are required to secure and submit a receipt for the expense. If an employee
loses or cannot produce a receipt or other type of documentation for a work-related expense the employee is
personally responsible for that expense and must reimburse Oswego Creative for said expense.

Cash Expenses
Whenever possible employees should utilize their Oswego Creative credit card for all project and travel related
expenses. In the exceptions where the use of the Oswego Creative company credit card is not possible, employees
are encouraged to use their personal cash for these expenses. The employee is still responsible for securing a
receipt for these cash expense.

Tipping
The use of skycaps and bellhops is encouraged because of the unique nature of the gear and cases that we use in
the course of our work. Employees will be reimbursed for cash tips during the course of a project. Since tipping is
an expense where a receipt is impossible to secure, employees are allowed to submit expenses without
documentation for these expenses.

EXPENSE REPORTING

Oswego Creative utilizes the Tallie online expense reporting system for the submission, review and approval of all
company related expenses. Each employee will be trained on the ins and outs of the Tallie system prior to the
submission of their first expense report.

Expense reports are to be submitted after the close of the company credit card statement at the end of each month.
Each and every employee is responsible for the accurate and complete completion of their expense reports within a
week of the closure of the credit card statement.

The employee is responsible for knowing the following aspects required for the completion of their expense
reports:

• Client Name
• Project Name
• Nature of Expense (Billable/Non-Billable)
• Expense Catagory
• Client Responsible for Expense
• Reason for Expense

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Projects with expenses that straddle billing cycles need to submit multiple reports for those expenses.

The repayment of employee personal and cash expenses are at all times subject to the authorization of the client
for whose project the expenditure was made in support of and only after the client has reimbursed Oswego Creative
for these expenses.

CELL PHONE

Since the nature of Oswego Creative's business involves a significant amount of travel, Oswego Creative provides
each employee with a company cell phone. Your company cell phone not only acts as your mobile device but also
functions as your office phone.

If you have a cell number, you would like to keep as your Oswego Creative phone number; you can work with the
Office Manager to port over your current number to the Oswego Creative cellular plan. If there are any early
termination fees associated with canceling your cell phone contract, those fees are the responsibility of the
employee and will not be reimbursed by Oswego Creative. If you have a cell plan (for example a family plan) that
you would like to stay on, Oswego Creative provides a monthly stipend to reimburse for Oswego Creative related
usage on your personal device/plan. If you choose to do this, please submit a monthly copy of your cell phone bill
to the Office Manager for reimbursement.

Oswego Creative provides a base level iPhone device for employees. Company cell phones are expected to last the
employee two years. Upon the end of the device’s usage cycle, Oswego Creative will provide the employee with a
newer model. If your Oswego Creative cell phone is either lost or damaged before the end of the device’s usage
cycle date, all costs to repair or replace the device are the responsibility of the employee. Lost or damaged devices
must be replaced as soon as possible. If an employee would like a newer model or a model with enhanced features,
the employee can request an upgraded device. If the employee decides to do this, they are responsible for paying the
difference between the cost of a base model phone and the device they are requesting. At the end of the two- year
cycle, Oswego Creative will take ownership of the old device with the intention to resell the device. There will be
no compensation back to the employee for their contribution for an enhanced device.

If an employee is part of the Oswego Creative cell plan, it is understood that the primary purpose of this device is
for business related work. Employees are responsible for appropriate use of company shared data and shall limit
their personal data use on Oswego Creative devices. Oswego Creative encourages the use of WiFi as much as
possible to help maintain appropriate levels of data usage. If an employee abuses this and their data use results in
additional costs to the company, the employee is responsible for any overage charges.

All employees are required to record a voicemail message where they identify themselves by name.

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IBEW MEMBERSHIP

A condition for employment at Oswego Creative is membership in the International Brotherhood of Electrical
Workers (IBEW). As a leading creative services provider for the IBEW international office and numerous locals around
the country, being a "Union Shop" puts Oswego Creative at a competitive advantage for keeping and earning work
for the IBEW and other unions. As a signatory of the IBEW, it also allows a small business-like Oswego Creative to
access benefits like the IBEW/NECA health insurance plan, providing a high-quality insurance plan for employees
that might otherwise be cost prohibitive for the company and the individual.
The Oswego Creative Office Manager will work with you to fill out the required paperwork for membership in the
IBEW. Each new employee is required to pay $25 initial membership fee, and then a small portion of each paycheck
is automatically deducted to cover your monthly IBEW dues. The Office Manager can explain how this amount is
calculated and what your monthly contribution will be.

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BUSINESS ENVIRONMENT

WORK AREAS

It is important that your workstation and or desk remain clean and tidy and free of boxes, papers, and magazines. We
expect that your workstation will be cleared and tidied at the end of every day. Any items that require storage
should be put away, hard copy paper files should be kept to a minimum, with soft copies of files stored on the
relevant shared drive electronically.

SECURITY

Entry to the Oswego Creative premises during and outside of regular business hours will be by way of security
pass/key/door code.
It is the responsibility of every Oswego Creative employee to ensure that this key/security pass is kept in safe custody.
It must be returned on demand.
If building access devices are lost or misplaced, you must notify your Manager immediately so that they can be
canceled. Replacement of building access devices are the financial responsibility of the employee.
Employees must ensure that all confidential/sensitive documents are locked away at night. You should make sure
that your personal belongings and valuables are locked away and secured. Company insurance does not cover
private property.

KITCHEN

Please keep the kitchen area clean at all times, cleaning up after use. You should be mindful that this is a public area
and you should be respectful to others by always cleaning up after yourself. If you use dishes, wash them
immediately after use or place them in the dishwasher. Maintain the common kitchen area is everyone's
responsibility.
If there are any issues with these facilities, you should notify your Manager immediately.

MEETING ROOMS

Oswego Creative has two communal work areas: the huddle room and the open conference table. These common
areas are available to everyone to use on a first come basis. Please tidy up after meetings, take away your dirty
cups, files papers, etc. Place chairs back in position and clean all work away.

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EMPLOYEE CONDUCT

CODE OF CONDUCT POLICY

This policy affirms Oswego Creative's belief in responsible social and ethical behavior from all employees. This policy
clarifies the standards of conduct that Oswego Creative expects of all employees.

Our employees contribute to the success of our organization and that of our clients. Oswego Creative wholeheartedly
endorses that all employees are not deprived of their fundamental rights. Furthermore, our employees have an
obligation to the business, our clients and themselves to observe high standards of integrity and fair dealing.
Unlawful and unethical business practices undermine employee and client trust.

Our Code of Conduct policy applies to all employees and provides the framework of principles for conducting
business, dealing with other employees, clients and suppliers. The Code of Conduct does not replace legislation, and
if any part of it conflicts, the law takes precedence. This policy is based on the following:

• Act and maintain a high standard of integrity and professionalism
• Be responsible and scrupulous in the proper use of Oswego Creative information, funds, equipment and

facilities
• Be considerate and respectful of the environment and others
• Exercise fairness, equality, courtesy, consideration, and sensitivity in dealing with other employees, clients

and suppliers
• Avoid apparent conflict of interests, promptly disclosing to an Oswego Creative senior manager any issue

which may constitute a conflict of interest
• Promote the benefits of Oswego Creative
• Perform duties with skill, honesty, care, and diligence
• Abide by policies, procedures and lawful directions that relate to your employment with Oswego Creative

and our clients
• Avoid the perception that any business transaction may be influenced by offering or accepting gifts
• Under no circumstances may employees offer or receive money
• Any employee, who in good faith, raises a complaint or discloses an alleged breach of the Code, while

following correct reporting procedures, will not be disadvantaged or prejudiced. All reports will be dealt with
in a timely and confidential manner.

Oswego Creative expects co-operation from all employees in conducting themselves in a professional, ethical and
socially acceptable manner of the highest standards.

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Any employee in breach of this policy may be subject to disciplinary action, including termination.

Should an employee have doubts about any aspect of the Code of Conduct, they must seek clarification from the
President and or the Executive VP.

This policy will be regularly reviewed by Oswego Creative, and the Office Manager will implement any necessary
changes.

DRESS CODE POLICY

Oswego Creative's objective in establishing a safe and comfortable environment includes setting some basic
standards for workplace dress code. This policy is to enable all people to project a professional image that is in
keeping with the needs of our clients and customers to trust us.

Office Dress Code
As a creative company, we allow for a casual work environment. Unless clients, prospects or any other visitors are
scheduled to visit the Oswego Creative office, employees are allowed to wear casual attire. When we are expecting
visitors, employees working in the office are expected to dress business casual attire during work hours.

On-Location Dress Code

While traveling you must keep in mind that you are not only a representative of Oswego Creative but also the
clients we are working for. When you are working at a client location, you need to abide by their rules and policies
including dress code. For example, if you are working in a country club environment, you are required to wear
appropriate attire which is most cases in a collared shirt and Khaki pants. As a general rule, when on-location we
expect all Oswego Creative representatives (including freelancers) to wear business casual work attire.

In the case of a client on-location project is a unique environment (construction zone, security sensitive location,
etc.) employees are expected to wear attire appropriate for that environment that conforms to the attire
requirements for that location. To access construction sites, Oswego Creative may require PPO gear to perform
their job. Oswego Creative provides PPO gear for use on construction sites:

• Hardhat
• Safety Vest
• Gloves
• Protective Glasses

If your role at Oswego Creative takes you to construction sites, you will need construction boots. Oswego Creative
does not provide this, and it is the responsibility of the employee to have the appropriate footwear while working
in a construction zone.

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IT, INTERNET, EMAIL AND SOCIAL MEDIA POLICIES

Internet
Oswego Creative provides the internet for business use. Limited private use is permitted if the private use does not
interfere with a person's work and that inappropriate sites are not accessed, e.g., pornographic, gambling.
Management has the right to access the system to check if private use is excessive or improper.

Failure to comply with these instructions is an offense and will be subject to appropriate investigation. In severe cases,
the penalty for an offense, or repetition of an offense, may include dismissal. Staff needs to be aware that some
forms of internet conduct may lead to criminal prosecution.

Email
1. Email facilities are provided for formal business correspondence.
2. Take care to maintain the confidentiality of sensitive information. If emails need to be preserved, they should
be backed up.
3. Limited private use of email is allowed if it doesn't interfere with or distract from an employee's work.
However, management has the right to access incoming and outgoing email messages to check if an
employee's usage or involvement is excessive orinappropriate.
4. Non-essential email, including personal messages, should regularly be deleted from the ‘Sent Items,' ‘Inbox'
and ‘Deleted Items' folders to avoid congestion.
5. All emails sent must include the approved business signature.

To protect Oswego Creative from the potential effects of the misuse and abuse of email, the following instructions
are for all users:

1. No material is to be sent as an email that is defamatory, in breach of copyright or business confidentiality,
or prejudicial to the good standing of Oswego Creative in the community or to its relationship with staff,
customers, suppliers and any other person or business with whom it has a relationship.

2. Email must not contain material that amounts to gossip about colleagues or that could be offensive,
demeaning, persistently irritating, threatening, discriminatory, involves the harassment of others or concerns
personal relationships.

3. The email records of other persons are not to be accessed except by management (or persons
authorized by management) ensuring compliance with this policy, or by authorized staff who have been
requested to attend to a fault, upgrade or similar situation. Access in each case will be limited to the
minimum needed for the task.

4. When using email, a person must not pretend to be another person or use another person's computer
without permission.

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5. Excessive private use, including mass mailing, "reply to all" etc. that are not part of the person's duties is not
permitted.

6. Failure to comply with these instructions is a performance improvement offense and will be investigated. In
severe cases, the penalty for breach of policy, or repetition of an offense, may include dismissal.

This policy also applies to all employees, contractors, and freelancers of Oswego Creative who have an active profile
on a social or business networking site such as LinkedIn, Facebook, or Twitter; write or maintain a personal or
business' blog; and/or post comments on public and/or private web-based forums or message boards or any other
internet sites.
Professional Use of Social Media
Oswego Creative expects its employees to maintain a certain standard of behavior when using Social Media for work
or client purposes.
This policy applies to all employees, contractors, and sub-contractors of Oswego Creative who contribute to or
perform duties such as:

• maintaining a profile page for Oswego Creative on any social or business networking site (including,
but not limited to LinkedIn, Facebook, or Twitter);

• making comments on such networking sites for and on behalf of Oswego Creative;
• writing or contributing to a blog and commenting on other people's or business' blog posts for and on

behalf of Oswego Creative; and/or
• posting comments for and on behalf of Oswego Creative on any public and private web-based forums or

message boards or other internet sites.
No employee, contractor or sub-contractor of Oswego Creative is to engage in Social Media as a representative or
on behalf of Oswego Creative unless they first obtain Oswego Creative's written approval.
If any employee, contractor or freelancers of Oswego Creative is directed to contribute to or participate in any form
of Social Media related work, they are to act professionally at all times and in the best interests of Oswego Creative.
All employees, contractors, and freelancers of Oswego Creative must ensure they do not communicate any:

• Confidential Information relating to Oswego Creative or its clients, business partners or suppliers.
• Material that violates the privacy or publicity rights of another party;and

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• information, (regardless of whether it is confidential or public knowledge), about clients, business partners
or suppliers of Oswego Creative without their prior authorization or approval to do so; on any social or business
networking sites, web-based forums or message boards, or other internet sites.

Confidential Information includes any information in any form relating to Oswego Creative and related bodies,
clients or businesses, which is not in the public domain.

Private / Personal Use of Social Media

Oswego Creative acknowledges its employees, contractors, and freelancers have the right to contribute content to
public communications on websites, blogs, and business or social networking sites not operated by Oswego
Creative. However, inappropriate behavior on such sites has the potential to cause damage to Oswego Creative, as
well as its employees, clients, business partners, and suppliers.

All employees, contractors, and freelancers of Oswego Creative must also refrain from posting, sending, forwarding
or using, in any way, any inappropriate material including but not limited to material which:

• is intended to (or could) cause insult, offense, intimidation or humiliation to Oswego Creative or its clients,
business partners or suppliers;

• is defamatory or could adversely affect the image, reputation, viability or profitability of Oswego Creative, or
its clients, business partners or suppliers; and

• contains any form of Confidential Information relating to Oswego Creative, or its clients, business partners
or suppliers.

All employees, contractors, and freelancers of Oswego Creative must comply with this policy. Any breach of this
policy will be treated as a serious matter and may result in disciplinary action including termination of employment
or (for contractors and freelancers) the termination or non-renewal of contractual arrangements.

SMOKING POLICY

Oswego Creative has a non-smoking policy. Smoking is not permitted on Oswego Creative property or in offices at
any time.

Smokers who need to take breaks should do so in their allotted breaks (no more than 2 per day in addition to their
lunch break). These breaks must be limited to 5 minutes from leaving the workplace to recommencing work. These
breaks must not be taken at the entrance to Oswego Creative offices. Excessive smoking breaks will be regarded as
absenteeism and performance improvement action may be taken.

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ALCOHOL AND DRUGS POLICY

Oswego Creative is concerned by factors affecting an employee's ability to safely and effectively do their work to a
satisfactory standard. The business recognizes alcohol or other drug abuse can impair short-term or long-term work
performance and is an occupational health and safety risk.

Oswego Creative will do its utmost to create and maintain a safe, healthy and productive workplace for all
employees. Oswego Creative has a zero-tolerance policy with regard to the use of illicit drugs on their premises or
the attending of other business-related premises (e.g., clients) while under the influence of illegal drugs.
Contravening either of these points may lead to instant dismissal.

Oswego Creative does not tolerate attending work under the influence of alcohol. This behavior may result in
performance improvement action or dismissal.

Oswego Creative, at times, makes alcohol available to staff over the age of 21. Limiting the consumption of any
alcohol made available is the responsibility of the employee. Driving over the legal limit or under the influence of
illicit drugs is illegal.

DISCRIMINATION AND SEXUAL HARASSMENT

Oswego Creative is committed to providing a workplace free from discrimination, sexual harassment, and bullying.
Behavior that constitutes discrimination, sexual harassment or intimidation will not be tolerated and will lead to
action being taken, which may includedismissal.

For this policy, the following definitions apply:

Direct discrimination occurs when someone is treated unfavorably because of a personal characteristic that is
protected under Colorado law.

Sexual harassment includes unwelcome conduct of a sexual nature in circumstances in which it could reasonably
be expected to make a person feel offended, humiliated or intimidated a reasonable person, having regard to all the
circumstances, would have anticipated that the person harassed would be offended, humiliated or intimidated.

WORKERS' COMPENSATION POLICY

All employees may be eligible for workers' compensation benefits if injured while at work. If there is an injury:

1. The first priority is medical attention. The injured worker or nearest colleague should contact one of
Oswego Creative's first aiders. For a serious injury also call an ambulance.

2. Any employee who is injured on the job, experiences a safety incident or a near miss, must report the
incident to their manager.

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3. Oswego Creative will let the injured employee know in writing that we have received
notification of any injury or illness.

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VACATION AND LEAVE

GENERAL LEAVE

Unless specified otherwise, employees referred to in this policy mean permanent full-time employees.
All planned leave has to be mutually agreed and take into account workloads and the employee's needs. Leave
must be approved in advance, except when the employee can't anticipate the absence. Any documents regarding
leave will be kept on the employee's personnel file and the leave time needs to be documented on the appropriate
work calendars.

ANNUAL LEAVE

Oswego Creative does not have a set number of annual leave days per year policy. Applications for leave need to
be lodged two weeks in advance. Pre-purchase of travel arrangements or accommodations does not guarantee
approval. Oswego Creative asks that leave be taken when, if possible, the employee's workload is in a down period
and/or doesn't negatively impact the ability of the company to complete client-related work. Employee is
responsible for making arrangements for work responsibilities are covered while they are away from the office.

PROBATIONARY LEAVE

New employees are considered to be in a probationary period and as such, cannot request leave unless in
emergency situations. We understand that leave plans may have been established prior to starting work at Oswego
Creative. This should have been discussed prior to accepting employment at Oswego Creative. In these cases, please
inform your manager as soon as possible to make appropriate arrangements.

PERSONAL (SICK) LEAVE

An employee should notify his/her manager as soon as possible if they are unable to attend work due to illness or
injury. Management, at its discretion, may request evidence such as a medical certificate showing that the employee
was entitled to take personal leave during the relevant period.

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TIME IN LIEU

Work hours at Oswego Creative can be unpredictable, unconventional and do not always follow a traditional 8:30
to 5, Monday through Friday schedule. Because of this is the nature of the business, Oswego Creative does not
grant time in lieu to an employee who is required to work outside their regular hours. If an employee has worked
a period of after traditional hours and or weekends, they are welcome to request a day off if they feel they need
to make up for time spent working an unconventional schedule. These time off requests are subject to the
employee's managers approval and must follow the leave policy.

JURY DUTY

An employee is entitled to paid leave for jury duty per legislation. An employee on jury service should supply the
official request to attend, the details of attendance and the amount the court has paid them.

EMERGENCY SERVICES LEAVE

If an employee needs to take a temporary absence from work because of voluntary emergency management
activities (for example, as a volunteer dealing with an emergency or natural disaster as a member of the Army
Reserve) then they should ask management for leave as soon as possible after they become aware of the need to
take leave.

Oswego Creative will support such activities wherever possible, as an essential community service. Oswego Creative

may require evidence of these activities at itsdiscretion.

PREGNANCY LEAVE

Oswego Creative encourages employees to inform their manager of their pregnancy as soon as possible. However,
we respect that an employee may not wish to advise us of her pregnancy earlier than the minimum notice period.

We also respect an employee's wishes regarding when it is appropriate to tell colleagues about the pregnancy.
Oswego Creative is committed to ensuring the safety of pregnant employees and considers harassment, bullying,
and discrimination to be unacceptablebehavior.

Safety at work
Oswego Creative understands pregnancy to be a healthy and normal process and recognizes that women have
different experiences. When an employee notifies her manager that she is pregnant, the manager will ask the
employee to let them know if they experience any changes to their work capacity during the pregnancy. The
employee and her manager will then discuss what is needed to keep the employee safe at work and adjustments
will be made accordingly where possible.

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Working until the birth
A pregnant employee may work until the expected date of birth of her child. If she wishes to continue working in the
last six weeks of her pregnancy, she may be requested to provide a medical certificate within seven days confirming
she is fit to work. If the medical certificate indicates the employee is not fit for work, she may be required to start
parental leave or take a period of unpaid leave as soon as practicable.
Pregnancy Leave
Female employees receive two months paid time off, plus one-month unpaid leave. Male employees receive two
weeks paid leave. If there are extenuating circumstances, they will be handled on a case-by-case basis.
Return to work
Towards the end of the leave period, the employee and manager should confirm the employee's intention to return
on the agreed date. The employee also may want to discuss any requests for flexible work arrangements at this
time.
An employee must provide four weeks’ notice if they want to extend their leave beyond the return date that was
initially advised.
Breastfeeding at work
Oswego Creative aims to understand and support mothers in the workplace, including accommodating
breastfeeding as much as possible e.g. providing a private space.
An employee should discuss her needs with her manager and Oswego Creative will endeavor to make a private space
available or other arrangement made by agreement. Depending on the employee's duties this may include cover
while she is away from her work environment.

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EMPLOYEE PERFORMANCE

PROBATION PERIOD

The three-month probationary period is a time for both the employee and the business to assess suitability, fit and
competency within a role. During this period the Oswego Creative commits to reviewing employee performance,
and at the end of this time, continuous permanent employment will be confirmed. This probation period will
include:

1. Managers to give informal and formal appraisal during the probation period.
2. Give at least one formal evaluation four weeks before the end ofprobation.
3. At the end of the probation period, complete a final probation appraisal and advise the employee

of the result.

PERFORMANCE MANAGEMENT

The purpose of performance management is to improve performance. It is an ongoing process. It should include
an informal and formal review. We encourage a two-way process, that is, employees can also give management
feedback on performance.

All employees will undergo a formal performance review with their immediate managers at least one times a
year.

1. The manager and the employee agree on the date for a performance appraisal meeting to allow time
to prepare.

2. The manager and employee will meet and openly and constructively discuss performance over the
period.

3. The manager and the employee will agree on any objectives and outcomes for the next appraisal
period.

4. Training and development will be considered as part of the process.
5. Notes should be taken of the meeting and, copies kept.
6. Outside of this formal process, employees are encouraged to raise any issues they have when they arise.

PERFORMANCE IMPROVEMENT

Where warranted Oswego Creative will use improvement processes to improve performance. Should such
improvement processes be unsuccessful in improving an employee's performance, Oswego Creative may decide to
end an employee's employment. Depending on the circumstances, performance improvement action may include
verbal or written warnings, counseling or retraining.

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Oswego Creative requires a minimum standard of conduct and performance which will be made clear to employees
in management appraisals. If an employee does not meet this standard, Oswego Creative will take appropriate
corrective action, such as training. Formal performance improvement procedures will generally only start when
other corrective action fails.

If an employee deliberately breaches business policy or procedure or engages in misconduct, Oswego Creative may
start improvement procedures, or, in cases of serious misconduct or breach of policy, may dismiss an employee.

Each employee must understand their responsibilities, be counseled and given the opportunity to reach the
standards expected of them. Oswego Creative will provide an employee the opportunity to defend themselves
before management takes further action.

If an employee deliberately breaches business policy or procedure or engages in misconduct, Oswego Creative may
start improvement procedures, or, in cases of serious misconduct or breach of policy, may dismiss an employee.

Each employee must understand their responsibilities, be counseled and given the opportunity to reach the
standards expected of them. Oswego Creative will provide an employee the opportunity to defend themselves
before management takes further action.

Note: If employees have a disability that requires reasonable adjustments to be made to the workplace or job to
allow you to work safely and productively, they should raise this with their manager. Oswego Creative will only
refuse such requests on reasonable business grounds.

1. Oswego Creative will advise the employee of any shortfall in their performance and give them an
opportunity to respond.

2. Once they respond, the manager will consider their response and decide if performance improvement
action should be taken. Oswego Creative will provide support such as training where appropriate.

3. If the employee is given a verbal warning, the manager should make a note of it, date it and sign it.
4. The manager will advise the employee in clear terms what they see as the performance problem or

the unacceptable conduct. To highlight the deficiency, they should use specific examples, and refer to
the correct policy or procedure.
5. The manager will allow the employee to respond before making a decision and consider the employee's
responses. The employee may have a support person present at such meetings.
6. The manager will decide if more action is needed.
7. If a written warning is to follow, the manager is to: document it and give the employee a copy, give the
employee the opportunity (and their support person the opportunity) to sign the warning, and keep a
copy on file.

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8. The warning must clearly define: the deficiency, a clear explanation of the expected standard, by when the
employee needs to achieve it, how the business will help the employee achieve the improvement
required and the consequences of failing to improve.

9. The manager concerned will keep a record of all meetings, training and/or coaching given and a summary of
discussions and put a copy on the employee's personnel file. This should include date, location and time
of discussion.

10. They will continue to support the employee and note the support they give, for example, training or
counseling.

11. If the employee's performance or conduct doesn't improve, the manager will give the employee a final
written warning and follow steps 4-10 above. This document needs to warn the employee in clear terms
Oswego Creative will terminate their employment if there is not enough improvement, and sustained
improvement in, their performance.

Note: some circumstances justify going straight to a second or final warning.

GRIEVANCE COMPLAINTS

Oswego Creative supports the right of every employee to lodge a grievance with their manager if they believe a
decision, behavior or action affecting their employment is unfair. An employee may raise a grievance about any
performance improvement action taken against them.

We aim to resolve problems and grievances promptly and as close to the source as possible.

Managers will do their utmost to action grievances objectively, discreetly and promptly. Be aware that grievances that
are misconceived, vexatious, and lacking substance may result in disciplinary action being taken against the
employee lodging the grievance.

CONFLICT OF INTEREST

Conflict of interest arises whenever the personal, professional or business interests of an employee are potentially
at odds with the best interests of Oswego Creative.

All employees are required to act in good faith towards Oswego Creative. Employees need to be aware of the
potential for a conflict of interest to arise and should always act in the best interests of Oswego Creative.

As individuals, employees may have private interests that from time-to-time conflict, or appear to conflict, with
their employment with Oswego Creative. Employees should aim to avoid being put in a situation where there may
be a conflict between the interests of Oswego Creative and their own personal or professional interests, or those
of relatives or friends. Where such a conflict occurs (or is perceived to occur), the interests of Oswego Creative will
be balanced against the interests of the staff member and, unless exceptional circumstances exist, resolved in favor
of Oswego Creative.

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It is impossible to define all potential areas of conflict of interest. If an employee is in doubt if a conflict exists, they
should raise the matter with their manager. If an employee declares such an interest, Oswego Creative will review
the potential areas of conflict with the employee and mutually agree on practical arrangements to resolve the
situation.
Employees must not set up or engage in private business or undertake other employment in direct or indirect
competition with Oswego Creative using knowledge and/or materials gained during the course of employment with
Oswego Creative. Engaging in other business interests during work hours will result in strong performance
improvement action.
Commission Policy
Oswego Creative encourages current employees to bring business opportunities that fall within the scope of
Oswego Creative's products and services and will financially compensate the employee if the lead they bring in
becomes Oswego Creative business. New business is defined as any work for a company or business that Oswego
Creative has not done business with in the last 24-months. If an employee brings a work opportunity to Oswego
Creative and Oswego Creative earns that business, the employee who brought in the opportunity will be
compensated with a 20% commission on the net profit for that project. All commissions will be allocated after
Oswego Creative has been compensated for the work from the client. Upon the final date of employment due to
either voluntary or forced dismissal, all commissions due are null and void.

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NON-COMPETE POLICY

If upon voluntary or forced dismissal an employee chooses to start their own business or join a competitor that
attempts to poach or steal current Oswego Creative clients or utilize Oswego Creative intellectual property, process
or products will be in violation of this non-compete policy. Failure to comply with this policy may result in Oswego
Creative pursuing monetary damages or other remedies.

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