SMG Associate Handbook : simplebooklet.com

Dear Sonepar USA Associate,Welcome to the Sonepar USA Management Group! If you are new to Sonepar USA, we are excited to have you as a member of our organization and we hope this handbook will help make your transition as smooth as possible. If you are a current associate, we hope this updated document will serve as a helpful reference tool.This handbook was developed to describe some of the expectations of our associates and outline the policies, programs and benets available to those who are eligible. Associates should familiarize themselves with this handbook, as it will answer many questions you may have about employment at Sonepar USA.At Sonepar USA, our most important asset is our people. We have built our culture around empowering our associates with the tools and information needed to make decisions and the opportunity to make meaningful contributions. We hope you will nd your time here both challenging and rewarding.Welcome to the team.Sincerely,Halsey CookPresident and CEO, Sonepar USAWELCOME

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DSONEPARValues .......................................................................................................1Mission Statement...................................................................................2EMPLOYMENT & RECORDSAmericans with Disabilities Act (ADA) ................................................... 3Background Checks ................................................................................ 3Conﬁdentiality of Information ...............................................................4Emergency Closures ...............................................................................4Employment At Will .................................................................................4Employment Classiﬁcations ................................................................... 5Employment File ......................................................................................5Internal Promotions and Transfers ........................................................5Performance Reviews .............................................................................6Reference Checks ...................................................................................6Rehire Reinstatement ............................................................................6BUSINESS WORKPLACE POLICIESAnti-Harassment......................................................................................8 Business Conduct and Ethics ..............................................................10Compliance Training .............................................................................12Dress Code ............................................................................................13Drug-Free Workplace ............................................................................ 14Employment of Relatives ......................................................................15Equal Employment Opportunity ...........................................................15Internet Usage .......................................................................................16Open Door ..............................................................................................19Social Media...........................................................................................20Solicitation and Distribution .................................................................21Tobacco .................................................................................................22Travel and Entertainment .....................................................................22EMPLOYMENT COMPENSATIONNotiﬁcation of Absence ........................................................................24Pay Period ..............................................................................................24Timekeeping ..........................................................................................24Work Hours ............................................................................................24WHAT’S INSIDE

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ELEAVE OF ABSENCEDisability Insurance ...............................................................................26Elected Ofﬁcial and Public Service Leave ...........................................26Family and Medical Leave of Absence (FMLA) ..................................26Medical Leave ........................................................................................28Military Leave ......................................................................................... 28Personal Leave ......................................................................................28Pregnancy Disability Leave and Lactation Breaks .............................28State Law Leaves ..................................................................................29COMPANY BENEFITSAssociate Beneﬁts ................................................................................30 Bereavement Policy ..............................................................................31ERISA ...................................................................................................... 31Holiday .................................................................................................... 31Jury Duty ................................................................................................32Privacy Complaints ...............................................................................32Privacy of Protected Health Information Under HIPAA .....................32Sick Time Policy ....................................................................................33Sonepar USA Cares ............................................................................... 33Tuition Reimbursement ......................................................................... 33Vacation Policy ......................................................................................34SAFETY IN THE WORKPLACEViolence in the Workplace ....................................................................36Weapons ................................................................................................. 36Workers’ Compensation .......................................................................36Workplace Bullying ................................................................................37SEPARATION FROM EMPLOYMENTBeneﬁts Continuation ...........................................................................38Exit Interview .........................................................................................40Return of Company Property ...............................................................40Termination ............................................................................................40NOTHING IN THIS HANDBOOK, OR IN ANY OF THE COMPANY’S POLICIES, SHALL BE DEEMED TO CONSTITUTE AN EXPRESS OR IMPLIED EMPLOYMENT CONTRACT BETWEEN THIS COMPANY AND ANY OF ITS ASSOCIATES. YOUR EMPLOYMENT WITH THIS COMPANY IS “AT WILL.” THE PROVISIONS OF THIS HANDBOOK ARE NOT CONTRACTUAL AND SHOULD NOT BE CONSTRUED AS A CONTRACT OR ANY GUARANTEE OF CONTINUED EMPLOYMENT.

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1PASSIONOur passion drives an enthusiasm about our products and services, while strengthening our engagement and commitment to our jobs. We strive to continuously innovate and make improvements whenever necessary.RESPECTRespect is the basis of all our relationships. We understand the importance of respect as an attitude where you listen and learn, and as a behavior where you show respect to win respect.PEOPLEWe believe that people are the key to our business growth. They lay at the heart of our business, as they reach both the customer and supplier. We train, motivate and support our co-workers, and we make them proud to represent Sonepar and its operating companies.CUSTOMERSThe customers are the focus of our attention, as we work to identify their needs and organize ourselves to provide them with the utmost satisfaction. We provide strong customer engagement through our advanced technical support, and this customer-service quality offers an added value to our suppliers.PROFITProt is what keeps us free and independent, and it serves as a guarantee for the future to both our suppliers and customers. Our prot reects the results of our hard work and efforts, while allowing us to continuously develop and invest.SYNERGIESSynergy allows us to work as a team throughout all aspects of the organization. We rely on each other to learn, create solutions, make a prot and promote contacts. Through sharing our ideas and experiences, we increase our efciency.FUTUREWhen focusing on the future, we must seize every opportunity to ensure that our organization thrives and survives. We always keep in mind the ongoing goals of Sonepar- protable growth and lasting development.LA RÉFÉRENCELa Référence means being acknowledged by customers, respected by suppliers and imitated by competitors. This notion serves as both a challenge and an incentive for all of us to reach our full potential. With our progress and motivation, we work to be a quality leader in our industry.Our values - Passion, Respect, People, Customers, Synergies, Protability, Future and La Référence - dene what we stand for and the leadership behaviors we want to encourage in each other.These values work together to permeate the everyday lives of our associates to improve our partnerships with our suppliers and customers.VALUES

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2WHO WE ARE Denes our profession, emphasizes our independence due to our family shareholders and explains how our organization is based upon entrepreneurship, both globally and locally.WHAT WE DODenes our goals as a distributor. Our rst goal is to serve customers through a variety of channels with a large growing range of products, services and solutions. Our second goal is to anticipate our customers’ needs in order to facilitate their daily jobs. These two goals help us create value for our stakeholders, which include our customers, associates, suppliers and shareholders.WHAT WE BELIEVE Describes how our growth and profitability are directly based on the confidence and commitment of our stakeholders.WHAT WE WANT Denes our ambition: to lead the market by elevating standards of service. We strongly believe that our success is based on being La Référence in every market.The Sonepar mission statement conrms our dedication to the business and exemplies our commitment to our customers and suppliers. The mission statement consists of four sections, all of which include “we” as a reminder to our customers and associates that “we,” the people of Sonepar, are where our company’s values begin.MISSION STATEMENT

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3EMPLOYMENT & RECORDSAMERICANS WITH DISABILITIES ACT (ADA)The Americans with Disabilities Act (ADA) and the Americans with Disabilities Act Amendments Act, known as the ADAAA, are federal laws that prohibit employers with 15 or more associates from discriminating against applicants and individuals with disabilities. These laws also require employers to provide reasonable accommodations, when needed, to applicants and associates who are qualied for a job so that they may perform the essential job duties of the position.It is the policy of Sonepar USA Management Group (SMG) to comply with all federal and state laws concerning the employment of persons with disabilities and to act in accordance with regulations and guidance issued by the Equal Employment Opportunity Commission (EEOC). Furthermore, it is our company policy not to discriminate against qualied individuals with disabilities in regard to application procedures, hiring, advancement, discharge, compensation, training or other terms, conditions and privileges of employment.The company will reasonably accommodate qualied individuals with a disability so that they can perform the essential functions of a job unless doing so causes a direct threat to these individuals or others in the workplace and the threat cannot be eliminated by reasonable accommodation and/or if the accommodation creates an undue hardship to SMG.Qualied individuals with disabilities are entitled to equal pay and other forms of compensation (or changes in compensation,) as well as in job assignments, classications, organizational structures, position descriptions, lines of progression and seniority lists. Leave of all types will be available to all associates on an equal basis.SMG is also committed to not discriminating against any qualied associates or applicants because they are related to or associated with a person with a disability. SMG will follow any state or local law that provides individuals with disabilities greater protection than the ADA.This policy is neither exhaustive nor exclusive. SMG is committed to taking all other actions necessary to ensure equal employment opportunities for persons with disabilities in accordance with the ADA and all other applicable federal, state and local laws.BACKGROUND CHECKS To ensure that individuals who join SMG are well qualied and to ensure that SMG maintains a safe and productive work environment, it is our policy to conduct pre-employment background checks on all applicants who accept an offer of employment. Background checks may include verication of any information on the applicant’s resume or application form, as well as drug screenings (described further in the Drug-Free Workplace section.)All offers of employment are contingent upon receipt of a background check report that is acceptable to SMG. All background checks are conducted in conformity with the Federal Fair Credit Reporting Act, the Americans with Disabilities Act and applicable state and federal privacy and anti-discrimination laws. Reports are kept condential and are only viewed by individuals involved in the hiring process.If information obtained in a background check would lead SMG to deny employment, the applicant will have the opportunity to dispute the report’s accuracy. Background checks may include a criminal record check, although a criminal conviction does not automatically bar an applicant from employment.Additional checks, such as a motor vehicle report,

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4education report and/or credit report may be made on applicants for particular job categories if appropriate and job related.SMG also reserves the right to conduct a background check for current associates to determine eligibility for promotion, if position requires additional background information, or reassignment in the same manner as described above.CONFIDENTIALITY OF INFORMATION We expect you, as an associate of SMG, to keep company-related information you receive at SMG condential and to not use it for your personal gain.Examples of condential information include, but are not limited to, sales volume, gross margin, EBIT, associate personal information, other nancial or company performance information, product mix, merchandise cost, marketing plans, business plans, pay plans, policies, customer lists and pricing strategies. Condential information must not be discussed outside of SMG. For more information, see the Condentiality and Non-Disclosure Agreement.EMERGENCY CLOSURESWhile it is the policy of SMG to be open each and every working day regardless of weather conditions, emergencies may occur and cause short-term disruptions to your normal work duties. Extreme situations, such as inclement weather, res, power failures, earthquakes, national emergencies, etc., may necessitate the closing of SMG facilities. If inclement weather necessitates a delayed opening or closure of your work location, you will be notied by a method appropriate to your individual location. Methods of notication include radio announcements, weather hotline, voicemail, etc. SMG also utilizes an emergency notication system service, called SendWordNow, that in urgent situations allows SMG to communicate in a rapid, consistent and secure way. If you hear nothing by the designated time, (your location’s regular business hours or a different time determined by your supervisor/manager) you should assume that your location will open as usual.Payment for Delays or ClosuresIf a location has a delayed opening or a closing, associates will be paid their regular rate of pay for any regularly scheduled time that they missed. However, for exempt associates with the ability to work from home, the expectation is that they work from home if their location is delayed or closed. Unless otherwise dictated by state law, hours paid as a result of inclement weather are not counted in a work week for the purpose of calculating overtime hours. Associates in non-exempt positions must actually work more than 40 hours in a work week in order to qualify for overtime pay. If inclement weather conditions are too severe at your home for you to travel safely to and from your work location, but the work location is not affected, you may take paid sick leave or vacation leave in accordance with the sick time & vacation policies. Please let your supervisor/manager know as soon as possible. In this case, we also ask exempt associates to work from home, if they are able, rather than taking time off.EMPLOYMENT AT WILLUnless an associate has a written contract with SMG stating otherwise, each associate’s employment with SMG is at will. The associate and SMG each have the right to terminate the employment relationship at any time, for any reason or no reason, with or without advance notice. Nothing in this handbook is intended to be inconsistent with employment at will, to establish a denite term of employment, or to confer any contractual or other rights to any specic condition or benet of employment, or to establish a denite term of employment and it should not be interpreted as doing so. A written contract that deviates from the at-will employment policy must be signed by both the associate and the President of SUSA.

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5Oral statements, written communications and benets plans are not, and should not be considered, a contract with SMG.EMPLOYMENT CLASSIFICATIONSYou will be classied into one of the following two categories, full-time or part-time.Full-Time AssociateAn associate who regularly works or is expected to work 30 or more hours per week. This classication is eligible for benet coverage.Part-Time AssociateAn associate who regularly works or is expected to work less than 30 hours per week. Eligibility for benets will be determined by the individual benet plan.EMPLOYMENT FILEAn associate’s employment file is maintained for each individual in the company. SMG reserves the right to permit associates the opportunity to review their employment file. The files, however, are the property of the company and may not be removed from the premises.Associates may request an appointment with their Human Resources representative to review their employment file at any time. Employment VeriﬁcationAll employment verication inquiries from current or former associates, governmental agencies or other organizations such as a nancial or lending institution, should be directed to HR Shared Services for an ofcial company response. Compensation information will only be provided with an accompanying signed release from the associate. Under no circumstances is any other associate authorized to provide a written or ofcial employment verication response for the company.INTERNAL PROMOTIONS AND TRANSFERSSMG encourages associates to continually develop their job skills. SMG has a job posting program (Career Connections) that offers associates the opportunity to apply for positions within the company. Associates should check the job posting board on the company intranet to obtain information regarding positions within the company that may be available.Associates with more than 12 months of service may request consideration to transfer to other jobs or operating companies of Sonepar as vacancies become available and will be considered along with other applicants. The company may initiate transfers of associates between departments and facilities to meet specied work requirements and reassignment of work duties.SMG offers associates promotions to higher-level positions when appropriate. Management promotes from within whenever possible and may rst consider current associates with the necessary qualications and skills to ll vacancies unless outside recruitment is considered to be in SMG’s best interest.To be considered, associates must have held their current position for at least 12 months, have a satisfactory performance record and have no disciplinary actions during the last 12 months. Management retains the discretion to make exceptions to this policy.Associates who apply for any open position are asked to inform their supervisor/manager if they haven’t already. Supervisors/managers are expected to fully support the career development of their associates, even in cases when associates apply to positions on other teams. The associate’s skills will be reviewed to determine if they t the requirements of the desired job. All applicants for a position, both within the company and outside, will receive equal consideration for the position.The company encourages associates to discuss their career aspirations with their supervisors/managers or their Human Resources representative at any time.Job Posting ProgramThe goal of SMG’s job posting program is to provide you with the opportunity for advancement or to pursue other positions within SMG without compromising the needs of our business. We

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6want the employment process at SMG to:• Provide each candidate with fair consideration• Ensure that the selection process is conducted in a fair and equitable manner• Act afrmatively in employment decisions.For internal job postings, we commit to posting all full-time and part-time manager level and below positions, unless it is a promotion within the same department.In order to apply for a posted position, you will need to visit the Career Connections website. You must include a resume with your application because it will help the supervisor/manager and Human Resources to better evaluate your qualications.As part of the application process, you need to notify your supervisor/manager to make him/her aware that you are applying for a position and may need time off to interview. This will allow your supervisor/manager to plan effectively for the future of the department. PERFORMANCE REVIEWSMaintaining a high-level of standard performance is critical to the success of our associates, as well as the success of SMG. An open line of communication between supervisors/managers and associates is essential to assuring that the goals of the company are being met. Annually (or more frequently as needed) you and your supervisor/manager will meet and evaluate your performance to date so that you both can set new goals for the next year.REFERENCE CHECKSThe company’s policy is to give dates of employment and job title only. Associates are not authorized to give out information on another associate’s performance. All reference checks must go through the Human Resources department. REHIRE REINSTATEMENT Rehired within 6 months, associates will be credited with:• Benet Continuation• 401(k) Vesting • Years of service determined by original hire date

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8BUSINESS WORKPLACE POLICIES ANTI-HARASSMENT POLICYIt is the goal of SMG to promote a workplace that is free of sexual and other unlawful harassment. The unlawful harassment of associates occurring in the workplace or in other settings in which associates may nd themselves in connection with their employment will not be tolerated by SMG. Further, any retaliation against an individual who has complained about such harassment or retaliation against individuals for cooperating with an investigation of a harassment complaint is similarly unlawful and will not be tolerated. To achieve our goal of providing a workplace free from sexual and other unlawful harassment, the conduct that is described in this policy will not be tolerated and we have provided a procedure by which inappropriate conduct will be dealt with, if encountered by associates. Because SMG takes allegations of harassment seriously, we will respond promptly to complaints of sexual and other unlawful harassment and where it is determined that such inappropriate conduct has occurred, we will act promptly to eliminate the conduct and impose such corrective action as is necessary, including disciplinary action where appropriate. Please note that while this policy sets forth our goals of promoting a workplace that is free of sexual and other unlawful harassment, the policy is not designed or intended to limit our authority to discipline or take remedial action for workplace conduct which we deem unacceptable, regardless of whether that conduct satises the denition of unlawful harassment. Sexual Harassment Sexual harassment is dened as unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature, when (a) Submission to such conduct is made, whether explicitly or implicitly, a term or condition of an individual’s employment; (b) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; or (c) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive work environment. Prohibition of Sexual Favoritism (Quid Pro Quo Harassment) Under the above denition, sexual harassment includes direct or implied requests by a supervisor/manager for sexual favors in exchange for actual or promised job benets, such as favorable reviews, increases in salary or benets, promotions or continued employment. The granting or withholding of employment opportunities and benets including, but not limited to, job assignments, unequal discipline, promotion, evaluation and compensation, also constitutes sexual harassment when it is based on sexual favoritism. Hostile Work Environment Harassment In addition to the above examples, other sexually-oriented conduct, whether it is intended or not, that is unwelcome and has the effect of creating a workplace environment that is hostile, offensive or intimidating to male or female associates may also constitute sexual harassment. While it is not possible to list all those additional circumstances that may constitute sexual harassment, the following are some examples of conduct that, if unwelcome, may constitute sexual harassment, depending upon the totality of the circumstances, including severity of the conduct and its pervasiveness. • Rape, sexual battery, molestation or attempts to commit those offenses; • Physical conduct that is sexual in nature, which may include touching, pinching, patting, grabbing, brushing against another

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9associate’s body, or poking another associate’s body or touching of the clothing covering the immediate area of the complainant’s intimate body parts; • Unwelcome sexual advances, whether they involve physical touching or not; • Sexual epithets, jokes, written or oral references to sexual conduct, gossip regarding one’s sex life, comment on an individual’s body, comments about an individual’s sexual activity, deciencies or prowess; • Unwelcome leering, whistling, sexual gestures, suggestive or insulting comments; • Inquiries into or discussion of one’s sexual experiences or activities; • Continuing to invite an individual to engage in social or sexual activities after being informed that the individual is not interested; • Using demeaning or inappropriate language; • Continuing to touch an individual in a traditionally non-sexual area of the body after being informed that such contact is not welcome; • Displaying sexually suggestive objects, pictures, posters, calendars, cartoons, grafti, promotional materials, reading materials, music or other materials that are sexually suggestive, sexually demeaning or pornographic; • Displaying signs or other materials purporting to segregate an associate by gender in any area of the work place (other than rest rooms and similar semi-private lockers/changing rooms); and • Birthday or farewell parties or other celebrations that feature cards, cakes or other food items, or performances of a sexual nature. Other Unlawful Harassment Unlawful harassment based on one’s membership in any other protected class also undermines the integrity of the employment relationship and is strictly prohibited by SMG. Unlawful harassment is dened as verbal or physical conduct based on race, color, religion, gender, pregnancy, sexual orientation, national origin, age, disability, ancestry, veteran status or any other characteristic protected by applicable federal and state laws, when such conduct has the purpose or effect of: (i) unreasonably interfering with an individual’s work performance, or (ii) creating an intimidating, hostile or offensive work environment. While it is not possible to list all those circumstances that may constitute unlawful harassment, the following are some examples of conduct that, if unwelcome, may constitute prohibited harassment depending upon the totality of the circumstances, including severity of the conduct and its pervasiveness. • Epithets, slurs, insults, or negative stereotyping with regard to race, color, religion, gender, pregnancy, sexual orientation, national origin, age, disability, ancestry, veteran status or any other characteristic protected by applicable federal and state laws; • Acts or jokes that are hostile or demeaning with regard to race, color, religion, gender, pregnancy, sexual orientation, national origin, age, disability, ancestry, veteran status or any other characteristic protected by applicable federal and states laws; • Threatening, intimidating, or hostile acts that relate to race, color, religion, gender, pregnancy, sexual orientation, national origin, age, disability, ancestry, veteran status or any other characteristic protected by applicable federal and state laws; and • Display of written or graphic material that demeans, ridicules, or shows hostility toward an individual or group because of race, color, religion, gender, pregnancy, sexual orientation, national origin, age, disability, ancestry, veteran status or any other characteristic protected by applicable federal and state laws.

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10Complaints of Sexual or Other Unlawful Harassment If any of our associates believes that he or she has been subjected to sexual and/or other unlawful harassment, the associate has the right to le a complaint with our organization. Complaints may be directed to the Senior Vice President, Human Resources, SMG, 4400 Leeds Ave. Charleston, SC 29405, (843)-745-2448 or to the Human Resources representative of the business unit. Human Resources is also available to discuss any concerns you may have and to provide information to you about our policy on sexual and other unlawful harassment and the company’s complaint process. Reprisals or Retaliation No associate should avoid or delay reporting incidents of possible harassment due to fear of retaliation. No associate will be subject to reprisal for having in good faith filed a complaint or cooperated in an investigation. Retaliation by any associate against an individual who has made a complaint about unlawful harassment, or has cooperated with an investigation of a complaint, is prohibited and will not be tolerated by SMG. All associates are hereby notied that any form of retaliation will be grounds for immediate discipline, including termination of employment. Associate Responsibility All associates are prohibited from participating in any conduct which could be construed as unlawful harassment. All associates of SMG should promptly report any instances which they believe violate this policy to Human Resources. This includes both personal complaints and incidents that were witnessed. Failure to cooperate fully in any investigation involving allegations of such prohibited conduct can result in disciplinary action. In addition, making knowingly false statements, by either a complainant, accused or witness, in connection with an investigation into sexual or other unlawful harassment, is not permitted. Should Human Resources determine that any associate has used this mechanism to make knowingly or willfully false statements, Human Resources will consider disciplinary measures. Harassment Investigation When Human Resources receives a complaint, it will promptly investigate the allegation in a fair and expeditious manner. The investigation will be conducted in such a way as to maintain condentiality to the extent practicable under the circumstances. The investigation will include a private interview with the person ling the complaint and with witnesses, if available. Human Resources will also interview the person alleged to have committed the harassment. When Human Resources has completed the investigation, it will, to the extent appropriate, inform the person ling the complaint and the person alleged to have committed the conduct of the results of that investigation. If it is determined that inappropriate conduct has occurred, prompt action will be taken to eliminate the offending conduct and, where it is appropriate, disciplinary action will be imposed. Disciplinary Action If it is determined that inappropriate conduct has been committed by one of our associates, we will take such action as is appropriate under the circumstances. Such action may range from counseling up to, and including, termination from employment, and may include such other forms of disciplinary action as we deem appropriate under the circumstances.BUSINESS CONDUCT AND ETHICS POLICY SMG expects all representatives of the company to act in accordance with the highest standards of personal and professional integrity in all aspects of their activities and to comply with all applicable laws, regulations and company policies. We must never compromise integrity, either for personal benet or for SMG’s purported benet. In accepting a position with SMG, each of us becomes accountable for compliance with the law and with the SUSA Code of Ethics and Busines Conducts (The “Code”) as available on SUSA intranet Site.

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11This code applies to all representatives of SMG, including directors, associates, temporary workers and other independent contractors and consultants. It is your responsibility to read and understand this Code and to comply with it as stated and in spirit. This Code addresses a wide range of business, legal, and ethical matters, but it cannot anticipate every issue that may arise. In many situations, your judgment and common sense will provide sufcient guidance; if something seems unethical or improper, it probably is. But, if you are unsure of what to do in any situation, you should seek additional guidance and information before you act by contacting your supervisor, the Human Resource Department or SUSA Legal.It is also your responsibility to report immediately any actual or suspected violation of a law or regulation, fraud, and any other violation or suspected violation of the Code. You may do so by contacting your supervisor, the Human Resource Department or SUSA Legal.Additionally, associates may choose to report any actual or suspected violation of this Code or the Global Code through Sonepar’s Whistle-Blower Program. Sonepar is dedicated to the application of, and the protections afforded to associates under, the Whistle-Blower Program, and we encourage individuals to use this program when reporting actual or suspected violations. The Whistle-Blower Program has been broadly disseminated within each operational company, is available on internal company websites (please visit www.sonepar-us.com/about.html) and is available through your Human Resources department.To the extent practicable, the identity of any employee who makes reports pursuant to this Code shall not be revealed to anybody in the employee’s department, division or work location. The Company will make good faith efforts to protect the condentiality of employees making reports. However, the Company or its employees and agents shall be permitted to reveal the reporting employee’s identity and condential information to the extent necessary to permit a thorough and effective investigation, or required by law or court proceedings.This policy presumes that you will act in good faith and will not make false accusations when reporting of wrongdoing by the Company’s employees. An employee who knowingly or recklessly makes statements or disclosures that are not in good faith may be subject to discipline, which may include termination.Employees should not conduct their own investigation or interviews into violation of law or fraud. These tasks are deferred to, as appropriate, Human Resources, SUSA Legal, management and/or the Compliance Ofcer.The Company prohibits any retaliatory action against any individual for raising concerns or questions in good faith regarding compliance with this Code or other ethics matters.Breach of the CodeAny breach of the Code (including the Global Code) will give rise to an investigation and, if appropriate, may lead to disciplinary action and prosecution, up to and including dismissal.Waivers and AmendmentsThe Company reserves the right to revise the Code at any time, without advance notice in order to take into account changed circumstances or amendments to laws and regulations.From time to time situations may arise that warrant a formal waiver of a provision of this Code for an individual. Waivers will not be granted except in extraordinary circumstances and will be limited and qualied as needed to protect the Company in the Company’s sole discretion. Waivers of this Code may be made by Sonepar USA Senior Management and/or SUSA Legal as appropriate.

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12Sonepar Group Compliance Ofﬁcer / SUSA LegalSonepar Group Compliance Ofcer (“Compliance Ofcer”):Paul Trudel paul.trudel@sonepar.comSUSA Legal Contact:Peter Bruhn Sonepar USA General Counsel peter.bruhn@sonepar-us.com (843) 745-2481Jason Locklair Sonepar USA Associate General Counsel jason.locklair@sonepar-us.com (843) 872-3522COMPLIANCE TRAININGAll SMG associates must complete a Workplace Harassment course in Training EDU and all other mandatory training. For more information on training, contact the Training Department or your Human Resources representative. Other HarassmentOther harassment includes, but is not limited to, unwelcome verbal, physical or other conduct based on an associate’s color, race, religion, gender, national original, sexual orientation, disability, age, or any other factor as dened by applicable law, when such conduct has the purpose or effect of unreasonably interfering with an associate’s work performance, has the purpose or effect of creating an intimidating, hostile, or offensive work environment or otherwise adversely affects an associate’s employment opportunities.Harassment may include slurs, negative stereotyping, jokes, threatening, intimidating or hostile acts and written or graphic material that denigrates or shows hostility or aversion toward an associate because of color, race, religion, gender, national origin, sexual orientation, disability, age, or any factor protected by state or local law.Examples include, but are not limited to:• Verbal harassment: loud, derogatory or vulgar comments or any reference to a person’s age, race, gender, religion, ethnic heritage, physical appearance, or distribution of written or graphic material having such effects• Physical harassment: hitting, pushing, or other aggressive physical conduct, or threats to take such actionComplaint Procedure If you experience any job-related harassment based on gender, race, national origin, disability, or another factor, you should promptly report the incident to your supervisor/manager. If you believe it would be inappropriate or you are uncomfortable discussing the matter with your manager, you may bypass your supervisor/manager and report it directly to your Human Resources representative, who will undertake an investigation.SMG expects you to assist in any investigation it undertakes. You are expected to provide accurate, honest information regarding any incident(s) or event(s) that may have occurred. You will be asked to keep any information you provide or you hear as a result of the investigation condential. If you violate this condentiality, this can result in disciplinary action, up to and including termination of employment. If SMG determines that an associate has harassed, appropriate disciplinary action will be taken against the offending associate, up to and including termination of employment.SMG prohibits any form of retaliation against an associate for ling a bona de complaint under this policy or for assisting in a complaint investigation. If you believe that you have been retaliated against, you need to follow the same complaint procedure explained above. If, after investigating any complaint of harassment, SMG determines that the complaint is not bona de and was not made in good faith or that an associate has provided false information regarding the complaint, disciplinary action, up

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13to and including termination of employment, may be taken against the individual who led the complaint or who gave the false information.DRESS CODEIt is important for all of us to present a positive and professional image to both internal SMG associates and external customers and vendors who visit our ofces. Visitors to our facilities look to us as representatives of SMG so we ask that associates dress accordingly and use good judgment. If you are unclear as to what to wear please see your manager or your human resources representative. DRUG-FREE WORKPLACESMG is committed to being a drug-free, healthy, and safe workplace. You are required to come to work in a mental and physical condition that will allow you to perform your job satisfactorily. In keeping with this commitment, SMG maintains a zero tolerance for drug and alcohol abuse by associates. SMG recognizes substance abuse as a potential health, safety and security problem. Associates needing help with such problems are encouraged to contact our Employee Assistance Program (EAP), their local supervisor/manager, or their Human Resources representative. Use or Possession of Drugs or Alcohol To ensure a safe, productive work environment at all SMG facilities and to protect all associates and SMG property, Sonepar USA strictly prohibits the use, sale, transfer or possession of alcohol or illegal drugs when on the job, on SMG property, or in a SMG vehicle. A violation of this policy will result in the immediate termination of your employment. In addition, SMG strictly prohibits the presence of prohibited substances including alcohol, illegal drugs and intoxicants (or other substances that could result in an unsafe work environment,) where applicable, in an associate’s system while at work, while on SMG premises or while working on SMG business. Unless your state’s laws permit the use of a specic substance, and you demonstrate the proper usage through medical documentation and only to the extent such use does not cause, or could create, an unsafe working environment for you or others, if you violate this policy, SMG will immediately terminate your employment.If you are taking a drug or other medication, whether or not prescribed by a physician for a medical condition, which is known or advertised as possibly affecting or impairing judgment, coordination or other senses (including dizziness or drowsiness,) or which may adversely affect your ability to perform work in a safe and productive manner, you must notify your supervisor/manager and/or Human Resources representative prior to starting work or entering SMG facilities. The Human Resource representative will decide if you can remain at work or on the premises or work site and what work restrictions, if any, are necessary. Violation of this policy subjects you to disciplinary action, up to and including termination of employment. Testing for Drugs and Alcohol Whenever your observed behavior or your involvement in an on-the-job accident raises a question about your physical condition and/or tness to perform your job, blood and/or urine samples or other medical tests, at SMG’s discretion, will be taken and screened by a medical laboratory for the presence of alcohol, drugs and/or controlled substances. Consent to such medical tests is a condition of both initial and continuing employment and refusal is considered an act of insubordination. If you are involved in a work-related accident that results in loss of work time and/or property damage, you may be tested for alcohol, drugs and/or controlled substances. Refusal to take a drug and/or alcohol test may result in discipline, up to and including termination. Applicants for employment with SMG will be notied of and given a drug and controlled substance screening test as a condition of initial employment. A positive test result for drugs or controlled substances may result in denial of the job. All drug test results will be kept condential.

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15All drug and alcohol testing will be conducted in accordance with applicable local, state and federal laws.EMPLOYMENT OF RELATIVESSMG permits the employment of qualied relatives of associates as long as such employment does not, in the opinion of SMG, create actual or perceived conict of interest. SMG will exercise business judgment in the placement of related associates in accordance with the following guidelines:• Relatives are permitted to work in the same SMG location, provided no direct reporting or supervisory/management relationship exists. That is, no associate is permitted to work within the “chain of command” of a relative such that the one relative could inuence another relative’s work responsibilities, salary or career progress.• Relatives are not permitted to work in the same department or in any other positions in which SMG believes a conict of interest may exist.• Associates who marry while employed are treated in accordance with these guidelines. If, in the opinion of SMG, a conict or an apparent conict arises as a result of the marriage, one of the associates will be transferred, if possible, or asked to terminate employment at the earliest practicable time.• In addition, SMG recognizes that at times, associates and “close friends,” “domestic partners” or “signicant others” may be assigned to positions that create a coworker or manager-subordinate relationship. SMG will review these situations on an individual basis and take whatever action it deems appropriate in order to avoid the creation of a conict or the appearance of a conict of interest, avoid favoritism or the appearance of favoritism.EQUAL EMPLOYMENT OPPORTUNITYSMG is an equal opportunity employer. It is SMG’s goal to provide equal employment opportunities for all individuals and associates, to prevent any unlawful discrimination or harassment of any individual working at or with SMG and to provide a mechanism by which individuals can bring any concerns about discrimination and/or harassment to the attention of management at SMG. Non-Discrimination and Anti-Harassment Policy In order to provide equal employment and advancement opportunities to all qualified individuals and associates, employment decisions at SMG will be made without regard to race, color, religion, gender, pregnancy, sexual orientation, national origin, age, disability, ancestry, veteran status or any other characteristic protected by applicable federal and state laws. SMG intends and desires to provide for equal employment opportunities in wages, benets, promotions and all other aspects of employment. SMG’s commitment to a discriminatory-free work environment also prohibits harassment based on any of the above factors including, but not limited to, sexual harassment. The subject of workplace harassment is covered in a separate policy, entitled “Anti-Harassment Policy.” In addition to a commitment to provide equal employment opportunities to all qualied individuals and associates, SMG has established an afrmative action program to promote opportunities throughout the organization for individuals in certain protected classes. Any associates with questions or concerns about any type of discrimination in the workplace are encouraged to bring these issues to the attention of Human Resources. Associates can raise concerns and make good-faith reports/complaints without fear of reprisal. The procedure for making such reports and/or complaints is covered in a separate policy, entitled Complaints of Sexual or Other Unlawful Harassment. Anyone found to be engaging in any type of unlawful discrimination will be subject to disciplinary action, up to and including termination of employment.

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16INTERNET USAGESMG provides access to a wide range of Information Technology (IT) resources to help you do your job better and faster. These IT resources represent a considerable company investment in telecommunications, hardware, networking, software, storage, phone systems, etc. This IT Policy is designed to help you understand our expectations for the use of those resources, and to help you use those resources wisely.All associates granted IT access with company facilities must read and accept the following statement:“I fully understand the terms of SMG’s Information Technology Usage Policy and agree to abide by them. I realize that SMG may record for management use the internal or external IT resources/sites that I utilize and keep a record of any activity involving company IT resources. I acknowledge that any message I send or receive will be recorded and stored in an archive le for management use. I know that any violation of this policy could lead to dismissal or even criminal prosecution.”While we’ve set forth explicit requirements for IT usage below, we’d like to start by describing our IT usage philosophy. First and foremost, IT for this company is a business tool to be used for business-related purposes (i.e., to communicate with customers and suppliers, to research relevant topics and obtain useful business information.) All associates must conduct themselves honestly and appropriately when using IT, and respect the copyrights, software licensing rules, property rights, privacy and prerogatives of others. All existing company policies apply to your conduct on the Internet, especially (but not exclusively) those that deal with intellectual property protection, privacy, misuse of company resources, sexual harassment, information and data security and condentiality.Unnecessary or unauthorized IT usage causes network and server congestion. It slows other users, takes away from work time, consumes supplies and ties up printers and other shared resources. Unlawful IT usage may also garner negative publicity for the company and expose SMG to signicant legal liabilities.Chats, newsgroups and email give each individual internet user an immense and unprecedented reach to propagate company messages and tell our business story. Because of that power, we must take special care to maintain the clarity, consistency and integrity of the company’s corporate image and posture. Anything any one associate writes in the course of acting for the company on the internet can be taken as representing the company’s corporate posture. That is why we have developed these policies on chat or newsgroup usage as outlined below.While our direct connection to the internet offers a wide range of potential benets, it can also open the door to some signicant risks to our data and systems if we do not follow appropriate security discipline. As presented in greater detail below, that may mean preventing machines with sensitive data or applications from connecting to the internet entirely, or it may mean that certain users must be prevented from using certain internet features like le transfers. The overriding principle is that security is to be everyone’s rst concern. An internet user can be held accountable for any breaches of security or condentiality.Certain terms in this policy should be understood expansively to include related concepts. SMG includes our afliates, subsidiaries and branches. Company means SMG, its afliates, subsidiaries and branches. Document covers any kind of le that can be read on a computer screen as if it were a printed page, including the so-called HTML les read in an internet browser, any le meant to be accessed by a word processing or desk-top publishing program or its viewer, or the les prepared for Adobe Acrobat reader and other electronic publishing tools. Graphics include photographs, pictures, animations, movies or drawings. Display includes monitors, at-panel active or passive matrix displays, monochrome LCDs, projectors and televisions.

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18Detailed Information Technology Usage Policy ProvisionsManagement and Administration1. SMG has software and systems in place that can monitor and record all IT usage. We want you to be aware that our security systems are capable of recording (for each and every user) each World Wide Web site visit, each chat, newsgroup or email message and each le transfer into and out of our internal networks, and we reserve the right to do so at any time. No associate should have any expectation of privacy as to his or her IT usage. Our managers will review IT activity and analyze usage patterns, and they may choose to publicize this data to assure that company IT resources are devoted to maintaining the highest levels of productivity.2. We reserve the right to inspect any and all les stored in private areas of our network in order to assure compliance with policy.3. The display of any kind of sexually explicit image or document on any company system is a violation of our policy on sexual harassment. In addition, sexually explicit material may not be archived, stored, distributed, edited or recorded using our network or computing resources.4. The company uses independently-supplied software and data to identify inappropriate or sexually-explicit internet sites. We may block access from within our networks to all such sites that we know of. If you nd yourself connected incidentally to a site that contains sexually explicit or offensive material, you must disconnect from that site immediately, regardless of whether that site had been previously deemed acceptable by any screening or rating program.5. The company’s IT facilities and computing resources must not be used knowingly to violate the laws and regulations of the United States or any other nation, or the laws and regulations of any state, city, province or other local jurisdiction in any material way. Use of any company resources for illegal activity is grounds for immediate dismissal, and we will cooperate with any legitimate law enforcement activity.6. Any software or les downloaded into the company network become the property of the company. Any such les or software may be used only in ways that are consistent with their licenses or copyrights.7. No associate may use company facilities knowingly to download or distribute pirated software or data.8. No associate may use the company’s IT facilities to deliberately propagate any virus, worm, Trojan horse or trap-door program code.9. No associate may use the company’s IT facilities knowingly to disable or overload any computer system or network, or to circumvent any system intended to protect the privacy or security of another user.10. Each associate using the IT facilities of the company shall identify himself or herself honestly, accurately and completely (including one’s company afliation and function where requested) when participating in internet chats or newsgroups, or when setting up accounts on outside computer systems.11. Only those associates or ofcials who are duly authorized to speak to the media, to analysts or in public gatherings on behalf of the company may speak/write in the name of the company to any newsgroup or chat room. Other associates may participate in newsgroups or chats in the course of business when relevant to their duties, but they do so as individuals speaking only for themselves. Where an individual participant is identied as an associate or agent of this company, the associate must refrain from any unauthorized political advocacy and must refrain from the unauthorized endorsement or appearance of endorsement by the company of any commercial product or service not sold or serviced by this company, its subsidiaries or its afliates. Only those managers and company ofcials who are authorized to speak to the media,

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19to analysts or in public gatherings on behalf of the company may grant such authority to newsgroup or chat room participants.12. The company retains the copyright to any material posted to any forum, newsgroup, chat or World Wide Web page by any associate in the course of his or her duties.13. Associates are reminded that chats and newsgroups are public forums where it is inappropriate to reveal condential company information, customer data, trade secrets and any other material covered by existing company secrecy policies and procedures. Associates releasing protected information via a newsgroup or chat – whether or not the release is inadvertent – will be subject to all penalties under existing data security policies and procedures.14. Use of company IT access facilities to commit infractions such as misuse of company assets or resources, sexual harassment, unauthorized public speaking and misappropriation or theft of intellectual property, are also prohibited by general company policy and will be sanctioned under the relevant provisions of the associate handbook.15. Associates with IT access may not use company IT facilities to download entertainment software or games, or to play games against opponents over the internet.Technical1. User IDs and passwords help maintain individual accountability for IT resource usage. Any associate who obtains a password or ID for an IT resource must keep that password condential. Company policy prohibits the sharing of user IDs or passwords.2. Associates should schedule large-scale online operations, such as le transfers, video downloads, mass emails and the like, for off-peak times.3. Any le that is downloaded must be scanned for viruses before it is run or accessed.4. Video and audio streaming and downloading technologies represent signicant data trafc which can cause local network congestion. Non-business video and audio downloading are prohibited.Security1. The company has installed a variety of rewalls, proxies, internet address screening programs and other security systems to assure the safety and security of the company’s networks. Any associate who attempts to disable, defeat or circumvent any company security facility will be subject to immediate dismissal.2. Computers that use their own modems to create independent data connections sidestep our network security mechanisms. An individual computer’s private connection to any outside computer can be used by an attacker to compromise any company network to which that computer is attached. That is why any computer used for independent dial-up or leased-line connections to any outside computer or network must be physically isolated from company’s internal networks.Only those IT services and functions with documented business purposes for this company will be enabled at the internet rewall.OPEN DOORSMG is rmly committed to an “Open Door” policy for all associates. Our goals can be achieved only through a free ow of suggestions, ideas and comments. For this to exist, your supervisor/manager will be responsive to your desire for discussion by maintaining an “Open Door” policy. This means that management’s doors are open to you when you have a suggestion, problem or concern. SMG expects associates to take their concerns and questions to their supervisor/manager, another supervisor/manager at SMG, or Human Resources.We encourage you to contact your supervisor/manager with any questions or concerns. If you have a problem or a complaint, your supervisor/

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20manager is the rst person you should see. Normally, your supervisor/manager will address your concern within a few working days of your discussion. Candid talks between you and your supervisor/manager are an important and effective way to get your concerns resolved. If you do not feel your concern is resolved or it would be inappropriate to discuss it with your supervisor/manager, you may review the question with your manager’s manager, another supervisor/manager or your Human Resources representative.Human Resources staff members are available to help you and your supervisor/manager facilitate this process. However, this does not replace your supervisor/manager in resolving your question or concern. Because many concerns arise from misunderstandings of actions, programs or policies, your supervisor/manager can almost always clarify the issue for you. If you need further assistance, do not hesitate to contact Human Resources.If your concern is not resolved, the SVP of Human Resources and the person that your supervisor/manager reports into will review your concern to reach a resolution. SOCIAL MEDIAThe use of social media is growing fast, both personally and in business. This offers possibilities and opportunities. However, these are new media channels and there is much we need to be mindful of, particularly when it comes to transparency. Be aware that anything you publish using social media is immediately visible to a large group of people, including all consequences in relation to condentiality and image.What is social media?Social media is a collective term for all Internet applications that allow information to be shared with each other in a user-friendly and often fun way. This includes information in the form of text (news, articles;) sound (podcasts, music;) and images (photography, video) that can be shared via social media websites. Well-known examples of international social media websites are Facebook, YouTube, Linkedin, Twitter, Wikipedia and MySpace.An important difference with the traditional media (newspapers, radio, TV) is that social media involves a high degree of interaction. Groups of people come together on sites to communicate about subjects they consider important.What can you use social media for?You can use social media to:• Build your professional and/or personal networks;• Promote communication (just like mobile phones and e-mail in the past;)• Take part in interesting discussions or to share fun or happy events with others;• Show that you are proud of your work. This can contribute to a better image among customers, colleagues, suppliers, etc. Sharing information and knowledge with groups with whom little communication has traditionally been possible can help give them a better picture of our company and offers us an opportunity to enhance our image.We want to helpAs with the rise of email and internet, the use of social media in organizations prompts new questions. The idea is that social media should make a valuable contribution to our company, as email and internet have done and continue to do. We want to help you optimize your use of social media and avoid undesirable experiences. They relate to your personal activities involving social media- both at work and in your free time. In principle, what you do outside of work time is your own business. Nevertheless, even outside of work time you remain a SMG associate. Social media “blunders” are often a result of a lack of awareness that your action or inaction can (negatively) affect your employer’s image.

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21Do:• If you want to share information and knowledge about SMG, be sure that the information is not condential or potentially harmful to SMG.• Communicate in a personal capacity. When discussing work-related subjects, state the name of the organization and your job title. Always write in the rst person.• You are responsible for the content of the material you publish. Be aware that what you publish will remain in the public domain for a long time, with all the intended consequences for your privacy.• If you publish on a website other than that of SMG on a subject which may be related to the company, make clear that you are doing so in a personal capacity. It may be advisable to add a disclaimer in which you indicate that your personal views do not necessarily correspond with those of the company.• Respect the privacy of others.• If you publish something about someone else, make sure that what you say is factual and accurate and does not discredit anyone.• Try to be the rst to correct your own mistakes. State that you are the one who is changing the message.• Follow responses to your statements and make sure they are as truthful, respectful and lawful as your own.• Use social networks which are hosted by SMG in a way that brings credit to the organization and our business objectives. Whatever you publish must contribute towards helping you, your colleagues, our customers and our suppliers do their work better.• If you have doubts about a publication or how it relates to SMG, it is sensible to discuss it with your manager or the relevant department. Whether you decide to publish something or not is your own responsibility, but it can never hurt to consult.Don’t:• Do not publish condential or other operational information. Before publishing company information, ask permission from your supervisor/manager or the responsible department or person.• Bear copyright in mind. Do not use logos, trademarks, images, music, etc. without prior permission.• Do not quote colleagues or other stakeholders. Do not upload any material without permission from the owner.• Do not provide information about customers, suppliers or partners without their permission. This applies both to information about products and individuals and to information about the company.• Do not tell untruths and do not place ethnically offensive material or crude or threatening material.• Do not “play around” with or alter the Sonepar USA logo. Do not link the logo to inappropriate text or images.• Do not engage in illicit advertising or spamming.SOLICITATION AND DISTRIBUTIONSMG has established rules, applicable to all associates, to govern solicitation and distribution of materials during working time and while associates are entering or leaving a SMG ofce or work area. All associates are expected to comply strictly with these rules. Violations of this policy can lead to disciplinary action, up to and including termination.No associate shall solicit or promote support for any cause or organization during his/her working time. Associates are not permitted to solicit or to distribute written materials for any purpose on SMG property, including restrooms, break rooms and shared work spaces. As used in this policy, “working time” includes all time for which an associate is paid and/or is scheduled to be performing services for SMG; it does

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22not include break periods, meal periods, time before or after work or other periods in which an associate is not, and is not scheduled to be, performing services or work for SMG.SMG maintains various communication systems to communicate company information to associates and to disseminate or post notices required by law. These communication systems (including bulletin boards, email, voicemail, facsimile machines, copiers and personal computers) are for business use only and may not be used for solicitation or distribution of non-SMG literature of any kind. These systems may not be used to promote or solicit participation in gambling activities, including but not limited to wagers, bets or pools.Bulletin boards are for the posting of SMG information and business notices only. All postings must be pre-approved and posted by a supervisor/manager. All items that are not approved will be removed.Violations of this policy should be brought to the attention of senior management or your Human Resources representative, who is responsible for overseeing and enforcing this policy.TOBACCOSMG is committed to preserving the health and wellness of all of our associates. In keeping with that commitment, the use of tobacco products are prohibited at all times within company facilities and company owned, leased, or rented vehicles. For the purposes of this policy, “tobacco” includes cigarettes, cigars, pipes and any other smoking product; dip, chew, snuff, snus and any other smokeless tobacco product; and nicotine delivery devices, such as e-cigarettes. FDA-approved nicotine replacement therapy products used for tobacco cessation are excluded from this denition. When you are a guest at any customer or vendor/ supplier site, you must follow that site’s “no smoking” and “smokeless tobacco” regulations, if applicable.TRAVEL AND ENTERTAINMENTThe corporate card is to be used for all credit card purchases of reimbursable business and travel and entertainment expenses where the corporate card is accepted. The corporate card is a company asset. As such, it is to be used for business purposes only. See separate SMG Corporate Card Policy for more detail.• SMG associates will expense reasonable, necessary and lawful expenditures incurred in connection with authorized business travel and/or business entertainment. The Internal Revenue Code requires reimbursable expenditures to be supported by adequate records which clearly establish that they were (i) ordinary and necessary, (ii) reasonable in amount and (iii) incurred for a valid business purpose.• It is the responsibility of associates to familiarize themselves with the substance of this policy, and of each supervisor/manager to communicate the substance of this policy to his/her subordinates and to monitor their compliance. In the event of unauthorized expenditures, the company maintains the right to seek reimbursement from the associate and to take disciplinary action, up to and including termination of employment. Please refer to Corporate Card Policy for additional policy information.• The contents and administration of this policy are the responsibility of the SMG corporate controller. This policy may be amended, modied or supplemented from time to time by the corporate controller in his/her sole discretion. Furthermore, this policy does not constitute a contract or other legally binding obligation on SMG, Inc. or any of its directors or ofcers or any legally enforceable right on behalf of any associates.

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24NOTIFICATION OF ABSENCEThe company expects associates to report to work promptly. An associate that cannot come to work or will be late should notify their supervisor/manager by a telephone call, text or email as soon as possible, in all instances before their starting time. A return telephone number must be provided upon notication of absence. If you cannot reach your direct supervisor/manager, it is your responsibility to contact another supervisor/manager in your department or location. Failure to notify your supervisor/manager or your Human Resources representative in a timely manner may result in disciplinary action, up to and including termination. PAY PERIODThe pay cycle for SMG is bi-weekly. Associates are paid every other Friday for the prior two weeks. The company offers and encourages you to use direct deposit of your net pay. Your earning statement is available on the HR Self-Service portal via the intranet for your review. If you nd any inconsistencies, report them to HR Shared Services immediately. HR Shared Services will assist you in taking the steps necessary to correct an error. If you have questions about how your check was calculated, you should ask HR Shared Services for assistance. TIMEKEEPING Non-exempt associates are responsible for accurately recording the hours they work. The law requires SMG to keep accurate records of “time worked” in order to correctly calculate associate pay and benets. “Time worked” means all the time that nonexempt associates spend performing their assigned work.If you are an hourly, non-exempt associate, you must accurately record the time you start and stop work, start and end any meal periods and leave the workplace for personal reasons. Hourly associates are required to take at least a one half (1/2) hour unpaid lunch. Before you work any overtime, you must always get advance approval from your supervisor/manager.Although SMG does not encourage non-exempt associates working beyond forty (40) hours, circumstances may create a need to work overtime. If you are in a non-exempt (hourly) position and you work more than 40 hours in any workweek, you will receive overtime pay for any time worked beyond the 40 hours. Only hours worked can be counted in a workweek for the purpose of calculating overtime hours, unless state or federal laws dictate otherwise. Overtime pay is at the rate of one and a half (1.5) times the regular rate of pay. No one (except your supervisor/manager or designated timekeeper) is authorized to record information on your time record for you. It is a violation of company policy for you to allow another associate to “punch” (record time) on your time record. Falsifying time records may result in disciplinary action, up to and including termination of employment for both you and the other person recording time.Each supervisor/manager or designated timekeeper will review and approve the time record within the prescribed time frame before submitting it for payroll processing.WORK HOURS Generally, the corporate ofce is open from 8 AM until 5 PM; however, there are times when this schedule may differ depending on the department needs. The standard workweek is 40 hours per week, although there may be occasions where additional hours are required to complete work necessary for the success of the organization.EMPLOYMENT COMPENSATION

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26DISABILITY INSURANCE SMG provides short-term and long-term disability insurance to all eligible associates at no cost. If you become disabled and cannot work, no benet becomes more important to your nancial security than disability income protection. Associates are required to submit proper documentation to the disability administrator to support their claim.Short-Term DisabilitySMG provides short-term disability for full-time associates, on the 61st day of continuous employment. The plan may pay you a portion of your income earnings as a weekly benet for a period of short-term disability caused by an illness or injury that occurs while your coverage is in effect. Coverage under this plan is non-occupational. Only non-occupational injuries and non-occupational illnesses are covered. Conditions that are related to pregnancy may be covered under this plan.Please refer to the Short-Term Disability Plan Description for more details about your coverage.Long-Term DisabilitySMG provides long-term disability insurance for full-time associates. Long-term disability insurance goes into effect after 26 weeks of continuous disability. The plan may pay to you a portion of your income earnings as a monthly benet for a period of long-term disability caused by an illness or injury that occurs while your coverage is in effect.Coverage under this plan is occupational and non-occupational. Occupational injuries and illnesses and non-occupational injuries and illnesses are covered. Conditions that are related to pregnancy may be covered under this plan.Please refer to the Long-Term Disability Plan Description for more details about your coverage. ELECTED OFFICIAL AND PUBLIC SERVICE LEAVE In accordance with applicable state law, an associate who is elected or appointed to a government ofce or a government board or commission may take leave to perform the duties of the position to which the associate is elected or appointed.To the extent required by applicable state law, associates may also take leave to serve as volunteer reghters, volunteer ambulance personnel and in other capacities as emergency responders, when the governor of the associate’s state declares a state of emergency or under circumstances provided by application state law. FAMILY AND MEDICAL LEAVE OF ABSENCE (FMLA)Under this policy, SMG will grant up to 12 weeks during a 12-month period to eligible associates.EligibilityTo qualify to take family or medical leave under this policy, the associate must meet the following conditions:• The associate must have worked for the company for 12 months or 52 weeks. The 12 months or 52 weeks need not to have been consecutive. Separate periods of employment will be counted, provided that the break in service does not exceed seven years. Separate periods of employment will be counted if the break in service exceeds seven years due to National Guard or Reserve military service obligations or when there is a written agreement. For eligibility purposes, an associate will be considered to have been employed for an entire week, even if the associate was on the payroll for only part of a week or if the associate was on leave during the week.LEAVE OF ABSENCE

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27• The associate must have worked at least 1,250 hours during the 12-month period immediately before the date when the leave is requested to commence. The principles established under the Fair Labor Standards Act (FLSA) determine the number of hours worked by an associate. The FLSA does not include time spent on paid or unpaid leave as hours worked. Consequently, these hours of leave should not be counted in determining the 1,250 hours eligibility test for an associate under FMLA.Amount of LeaveAn eligible associate may take up to 12 weeks of unpaid, job-protected leave for the birth of a child or to care for a newborn child, for the placement of a child for adoption with the associate or to care for a newly placed child, to care for the associate’s serious health condition, or to care for the serious health condition of the associate’s spouse, parent or child during any 12-month period, as described under this policy. The company will measure the 12-month period as a rolling 12-month period measured backward from the date an associate uses any leave under this policy. Each time an associate takes leave, the company will compute the amount of leave the associate has taken under this policy in the last 12 months and subtract it from the 12 weeks of available leave, and the balance remaining is the amount of time the associate is entitled to take at that time.An eligible associate can take up to 26 weeks for FMLA military caregiver leave, as described above, during a single 12-month period. For this military caregiver leave, the company will measure the 12-month period as a rolling 12-month period measured forward. FMLA leave already taken for other FMLA circumstances will be deducted from the total of 26 weeks available.If a husband and wife both work for the company and each wish to take leave for the birth of a child, adoption or placement of a child in foster care, or to care for a parent (but not a parent in-law) with a serious health condition, the husband and wife may only take a combined total of 12 weeks of leave. Associate Status and Beneﬁts during LeaveWhile an associate is on FMLA leave, the company will continue the associate’s health benets during the leave for up to 12 weeks at the same level and under the same conditions as if the associate had continued to work. Associates will remain responsible for paying their benet premiums to maintain coverage. Benet premiums will be deducted from weekly short-term disability checks, with the exception of Flexible Spending Account premiums.Associate Status after LeaveAn associate who takes FMLA leave under this policy may be asked to provide a Fitness for Duty (FFD) clearance from the health care provider.Use of Paid and Unpaid LeaveAll paid vacation and sick leave runs concurrently with FMLA leave. Associates are required to use any available sick or vacation time to cover the two-week elimination period before paid leave benets kick in.Disability leave for the birth of a child and for an associate’s serious health condition, including workers’ compensation leave, to the extent that it qualies, will be designated as FMLA leave and will run concurrently with FMLA.Intermittent Leave or a Reduced Work ScheduleThe associate may take FMLA leave in 12 consecutive weeks, may use the leave intermittently (take a day periodically when needed over the year) or, under certain circumstances, may use the leave to reduce the workweek or workday, resulting in a reduced-hour schedule. In all cases, the leave may not exceed a total of 12 workweeks (or 26 workweeks to care for an injured or ill service member over a 12-month period.)CertiﬁcationCertification for leaves must be submitted to FMLA Administration. Failure to provide

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28a certification may result in denial of continuation of leave.RecertiﬁcationThe company may request recertication for the serious health condition of the associate or the associate’s family member if circumstances have changed signicantly, if the employer receives information casting doubt on the reason given for the absence, or if the associate seeks an extension of his or her leave. Otherwise, the company may request recertication for the serious health condition of the associate or the associate’s family member, in connection with an FMLA absence, no more often than every 30 days or the minimum duration of the associate’s leave as stated in the certication.MEDICAL LEAVEAll associates requesting FMLA leave must provide their supervisor/manager and Human Resource representative with verbal or written notice of the need for the leave. The associate should le a claim with the FMLA administrator. See the Benets Guide for more details.When the need for leave is foreseeable, the associate must provide the employer with at least 30 days notice. When an associate becomes aware of a need for FMLA leave less than 30 days in advance, the associate must provide notice of the need for the leave either the same day or the next business day. When the need for FMLA leave is not foreseeable, the associate must comply with the company’s usual and customary notice and procedural requirements for requesting leave.Intent to Return to Work The company may require an associate on FMLA leave to report periodically on the associate’s status and intent to return to work.MILITARY LEAVE Leaves of absence without pay for military or reserve duty are granted to full-time and part-time associates in accordance with state & federal law. Upon receipt of orders for active or reserve duty, the associate must notify their supervisor/manager, or Human Resources representative as soon as practicable and submit a copy of their orders. Accrued unused sick or vacation leave may be used in lieu of unpaid leave for all or a portion of a military leave of absence, if the associate so chooses. PERSONAL LEAVE Associates with at least 90 calendar days of service may request, in writing, an unpaid personal leave of absence in a situation where a personal need requires an extended absence from work. Personal leaves are reviewed on a case-by-case basis and will be granted at the company’s discretion, unless otherwise required by applicable state law, based upon:• Reason for request;• Length of service;• Performance;• Operating needs of the department and • Length of leave requested.Unpaid personal leaves of absence are not granted until all unused vacation and sick leave have been exhausted.If an associate is out for 30 days or longer on personal leave, benets will end on the 31st day of the absence. The associate will have the option to elect COBRA. Benets will be reinstated upon their return to work.PREGNANCY DISABILITY LEAVE AND LACTATION BREAKS In accordance with applicable state law, eligible associates may take leave for the period of time allowable by state law, that they are sick or disabled due to pregnancy, childbirth or related medical conditions. Where allowed by state law, any such pregnancy disability leave shall run concurrent with leave under the Family Medical Leave Act and any state law equivalents.All associates who are nursing mothers are eligible to take reasonable breaks to express breast milk

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29for up to a year after the birth of the associate’s child or the period prescribed by applicable state law. SMG will provide a time and place, other than a restroom for eligible associates to express breast milk. SMG encourages eligible associates who intend to take lactation breaks to provide their supervisor/manager advance notice of their intent to take such breaks, for example, when they are discussing their return to work following leave related to child birthSTATE LAW LEAVESFive work (not residence) states and Puerto Rico have individual disability programs. They are California, New York, New Jersey, Rhode Island and Hawaii. These benefits provide temporary, non-work related (not worker’s compensation) benefits to associates working in these states. At the time you report your disability claim, the claim intake representative will inform you that you may qualify for disability through your state.Any short-term disability or long-term disability benefits that you receive from SMG that overlap with your statutory benefits will be reduced.

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30Beneﬁt Description Waiting Period Full-Time Part-Time 401(k) 45-60 days X XAssociate Discount Program 60 days X XBereavement Pay None X XCompany Paid Life Insurance 60 days X Dental Insurance 60 days X Associate Assistance Program 60 days X Family Medical Leave Must work 1,250 hours over previous 12 monthsX XFlex Spending Account 60 days X Floating Holiday Pay None X XHealthy Lifestyle Reimbursement 60 days X XHoliday Pay None X XJury Duty Pay None X Medical Insurance 60 days X Military Leave Must work 1,250 hours over previous 12 monthsX XPersonal Leave 90 days X XShort-Term & Long-Term Disability 60 days X Sick Pay None X XSupplemental Life Insurance 60 days X Tuition Reimbursement After one year of service X Vacation Pay 90 days X XVision Insurance 60 days X COMPANY BENEFITSASSOCIATE BENEFITSSMG provides a comprehensive benefit package for its associates. When you become eligible for a benefit, you will be given information concerning the details and associated costs of the benefits for which you are eligible. Benefits represent a significant part of your compensation at SMG. We encourage you to use these programs effectively to meet your needs and maintain a healthy lifestyle. The chart below details eligibility for various benefits by employment classifications. The chart is provided for easy reference and is not intended to detail all the eligibility requirements for the plans. Please refer to the Summary Plan Description on the HR Self-Service Portal for more information.

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31401(k)Associates have the opportunity to participate in the 401(k) plan by saving a portion of their compensation on a pre-tax basis. Whether or not you are prepared for the future depends on the choices you make. Contributions to the plan are pre-tax which means the associate is taxed after the retirement deduction is taken out, resulting in lower taxation on your salary and additional savings. SMG will automatically begin your payroll contribution at 3% as soon as administratively feasible after the automatic enrollment notice period (generally within 45 days) unless you choose to opt out of participation. The company may also make a quarterly, discretionary matching contribution equal to 50% of your contribution up to the rst 6% deferred, but not to exceed 3% of eligible compensation. Details of the plan are described in the 401(k) Summary Plan Description (SPD).BEREAVEMENT POLICYSMG provides both its full and part-time associates with paid leave in the event of a death of an associate’s immediate family member. Full-time associates will be granted up to three (3) days paid leave per individual death for funeral arrangements, travel and attendance at a funeral. Part-time associates will be granted 1.5 days. Immediate family of the associate includes:• Spouse or Partner• Children• Parents• Parents-in-Law• Grandchildren• Grandparents• Siblings• Siblings-in-Law• Legal GuardianAssociates may request leave for funerals of individuals other than immediate family members, however, vacation or sick leave must be used if available. If paid leave is not available unpaid leave may be requested. All requests must be approved by your supervisor/manager.ERISASMG believes that all associates should be made aware of their rights concerning their benets. As a participant in the plans described in the following pages, you may be entitled to certain rights and protection under the Employee Retirement Income Security Act of 1974 (ERISA). A complete statement of ERISA rights is contained in the Summary Plan Description (SPD) for each plan. ERISA provides that all plan participants shall be entitled to examine the plan documents or any plan-related documents, request a copy of any of the information, receive a summary of the plan’s annual nancial report and/or receive a statement of retirement benets.If you have any questions about this statement or about your rights under ERISA, contact your Human Resources representative or the nearest area ofce of the Labor Management Standards Administration of the U.S. Department of Labor.HOLIDAYSSMG offers eight standard holidays and one oating holiday. These are the standard holidays that SMG typically recognizes. We review these each year and make a schedule accordingly, depending upon the day of the week a holiday falls upon. The company will be closed on the following days listed below:• New Year’s Day• Memorial Day• Independence Day• Labor Day• Thanksgiving Day• Friday after Thanksgiving• Christmas Eve• Christmas DayFull-time and part-time associates are eligible for paid holidays. If you are a full-time, hourly or

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32salaried associate, you will receive eight hours of pay for that day at your current base rate of pay. If you are part-time, hourly associate, you will receive four hours at your current base rate of pay. In some cases, you may be asked to work a holiday. If that occurs, your supervisor/manager will give you another day off or may make some other arrangement to compensate you for the loss of the holiday. Holiday pay is not granted while you are on a leave of absence except when the holiday falls during the two-week elimination period. Floating HolidayIn addition, full-time and part-time associates will receive one personal oating holiday for a total of nine paid holidays each calendar year. You may choose to use the oating day (with supervisor/manager approval) for holidays when SMG is not closed, such as President’s Day, Martin Luther King Day, Good Friday, etc. The oating holiday allows you to have additional paid leave to cover absences for personal reasons such as religious observances or to supplement vacation, sick and holiday leave.You may choose to use this day on any regular workday, as long as you and your supervisor/manager agree in advance. You are paid your regular rate of pay for your normally scheduled workday for each of the company scheduled holidays, as well as the oating holiday.JURY DUTYSMG recognizes that it is important for associates to fulll their civic responsibilities to the community. Therefore, associates should serve when called for jury duty.Full-time associates will be paid their regular rate of pay during their active period of jury or witness duty for up to a maximum of 10 working days in any two-year period. If the jury duty service extends past 10 days, associates may choose to utilize accrued vacation or sick day, or take the time off without pay. The associate must present their summons for jury duty to their supervisor/manager or to the Human Resources representative after being notied that they have been chosen to serve. Associates must report to work on any day or part of a day that they are not actively serving jury duty, unless prior arrangements have been made with your supervisor/manager.After serving on the jury, the associate must present a “Certicate of Juror” to their supervisor/manager or to the Human Resources representative. The certicate must list the dates of service. If you are selected to serve on the jury and receive payments from the courts, please provide a copy of the statement to your supervisor/manager or Human Resource representative and your pay will be adjusted accordingly.PRIVACY COMPLAINTSIf you believe that your privacy rights have been violated, you may le a complaint with the carrier, the third party administrators, our plan, as listed on the full policy located online via our HR Self-Service portal, and/or with the Secretary of the Department of Health and Human Services. All complaints to the benet plan must be made in writing and sent to the address indicated in the full policy. We support your right to protect the privacy of your medical information. We will not retaliate in any way if you choose to le a complaint with us, the carriers, the third party administrators, or the Department of Health and Human Services. PRIVACY OF PROTECTED HEALTH INFORMATION UNDER HIPAASMG is required to follow the privacy practices in accordance with federal and state privacy laws enacted to protect your medical information. We are permitted to use or disclose your Protected Health Information (PHI) for the purposes of treatment, payment and health care operations. We may also use or disclose your protected health information in other instances, such

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33as when we are required to do so by law to the plan sponsor, to public health agencies, etc. For a full description of all permitted or required disclosures, please see the full policy online via our HR Self-Service portal. You have the rights to your Protected Health Information that include the right to review or obtain copies of your Protected Health Information records, with some limited exceptions. For a full description of your rights to your Protected Health Information and instructions on making a request to review, obtain or amend your Protected Health Information, please see the full policy online via our HR Self-Service portal. We require our associates to follow SMG’s security policies and procedures that limit access to health information about members to those associates and or entities that need it to perform their job responsibilities. In addition, SMG maintains physical, administrative and technical security measures to safeguard your Protected Health Information. SICK TIME POLICYAll full-time and part-time associates are eligible for ve sick days each calendar year. Sick time is to be used for your own personal illness, doctor’s appointment, dentist appointment, etc. or when you cannot report to work because you must take care of a sick relative. Associates must call their supervisor/manager before the start of the work day if they are going to be out sick. Associates who are out sick for more than three (3) consecutive days, may need to le a Family Medical Leave claim with the current carrier - please refer to the Family Medical Leave Act Policy. Sick days cannot be carried over to subsequent years. Unused sick days are not paid upon termination of employment.SONEPAR USA CARESSonepar USA Cares encompasses our volunteer efforts, the well-being of our associates and their families. It is the passion, drive and local commitment at each location that tie into our overall mission of actively engaging with our associates and being La Référence.The mission and purpose is to integrate, collaborate and make an impact with local charities that will not only improve the lives of others and raise awareness, but also to have a positive effect in the community while representing Sonepar USA and engaging our associates with humanitarian efforts.TUITION REIMBURSEMENTSMG provides nancial assistance for associates to further their education, to strengthen their performance on the job and to increase growth potential within the company.Tuition reimbursement is available to all regular full-time associates who have completed at least one (1) year of service with SMG. An associate’s most recent performance evaluation must be at least “meets requirements” at the time the associate applies for tuition reimbursement, and the associate’s performance must remain at this level during the course of study for which reimbursement is sought. Please let your supervisor/manager know in August/September of your intentions so they can budget accordingly for the following calendar year.The college or university must be accredited by an agency approved by the Council on Postsecondary Accreditation (COPA) or the Secretary of Education of United States. Your supervisor/manager will verify institution eligibility. Courses taken must be directly related to the associate’s present or potential future work with the company. Degree programs may be approved up to and including Masters’ level. Each degree of interest will be reviewed and approved by the associate’s supervisor/manager and Human Resources.Degree programs that are not covered include, without limitation: Allied Health Sciences, Nursing, Physician, Dentistry, Pharmacy, Veterinarian, Music, Dance, Art, Special Education, Early Childhood Education, Religion, Physical Education, English, Law and any other degree programs SMG decides is not relevant to your current or future work with SMG, as determined at the company’s discretion.

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34A supervisor/manager may approve training/educational courses or certications that are not part of a degree program if the courses are related to current or future career potential with the company. These courses would fall under the supervisor/manager’s training budget and would not be covered under the tuition reimbursement policy.The rst step in the tuition reimbursement application process is for the associate to submit a letter and the tuition reimbursement form (available on the HR Self-Service portal) to his or her supervisor/manager requesting the reimbursement for the degree program be approved. The letter should state the relationship of the degree program to the associate’s current job or potential future work with SMG. Once the request is approved by the associate’s supervisor/manager, the letter, the supervisor/manager approved tuition reimbursement form, and a tuition repayment agreement must be forwarded to the Human Resources representative for review and approval.Reimbursement Covered expenses are tuition, required academic and lab fees, College Level Examination Programs (CLEP) and required books. Approved educational expenses are reimbursed after completion of the class and all the policy’s requirements are met. As long as you, the college or university, the courses and the expenses continue to meet the criteria outlined in this policy, you will continue to be approved for reimbursement for expenses related to your primary major, secondary major, and /or your minor. Undergraduate Courses The associate will not be reimbursed for a grade of “D” or lower in an undergraduate course. The associate will be reimbursed for a grade of “C” (2.0 on a 4.0 scale) or above in an undergraduate course. The maximum undergraduate reimbursement available to an associate is up to $5,000 during a calendar year. Graduate CoursesThe associate will not be reimbursed for a grade of “C” or lower in a graduate course. The associate will be reimbursed for a grade of “B” (3.0 on a 4.0 scale) or above in a graduate course. The maximum graduate reimbursement available to an associate is up to $10,000 during a calendar year. Tuition reimbursement may be considered taxable income as regulated by the IRS. Any tuition reimbursement above the annual amount the IRS deems non-taxable, will be taxed accordingly. Annual reimbursement is calculated by calendar year and counts in the calendar year in which the reimbursement was made, not the year in which the course was completed. Associates who voluntarily leave the company less than two years after receiving tuition reimbursement agree to reimburse SMG for education expenses (detailed in the tuition repayment agreement form). Non-reimbursable ExpensesThe following list includes, but is not limited to, costs which are not reimbursable under the policy: Program application fees, late registration fees, interest fees, deferred payment fees, general or student activity fees, equipment fees, pens, pencils, notebooks, parking fees, transportation to and from the school, accident insurance and examinations and certications (e.g., GMAT and CPA.)The application must be approved by the supervisor/manager and Human Resources before the associate begins the course of study. If the associate changes his or her degree program, the request process, including a letter outlining the relationship of the new degree program to the associate’s current job or future work with SMG, must be completed.VACATION POLICYSMG recognizes that time away from work contributes to the overall well-being of its

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35associates. This policy is designed to support the physical, emotional and spiritual needs of its associates by providing paid time away from work. SMG provides full-time and part-time associates with vacation leave benets. Associates will be eligible for vacation time after ninety (90) days of service.Part-time associates must work a minimum of 20 hours per week to be eligible.Vacation entitlement for a given year is granted on January 1st of each year and determined by the associate’s anniversary that occurs during that calendar year. For example, if an associate’s 10th anniversary with the company occurs in June, he or she is eligible for 4 weeks of vacation (20 days) from the beginning of the calendar year.Unused vacation time will not carry over one calendar year to the next, with the exception of prior management approval based on business circumstances.VACATION TIME: ALLOCATION BEGINS ON JANUARY 1 FOR FULL-TIME ASSOCIATESTenure Allotment1-4 Years 10 Days 5-9 Years 15 Days 10+ Years 20 Days VACATION ELIGIBILITY IN THE FIRST YEAR OF EMPLOYMENTHire DateFull-Time AssociatesPart-Time AssociatesJanuary-June 40 Hours 20 Hours July-September 20 Hours 10 Hours October-December 0 Hours 0 HoursVacation requests should be submitted at least one week prior to requested leave. Your immediate supervisor/manager must approve the vacation request. Factors will be considered for approval such as business needs at time of request.Vacation will be paid at the associate’s base rate at the time the leave is taken. Vacation pay is not included in overtime calculation and does not include any special forms of compensation such as incentives, commissions, bonuses or shift differentials. If employment is terminated, earned unused vacation leave through the last full month of active employment will be paid at the associate’s base rate of pay on a pro-rated basis. Note: Prearranged employment agreements supersede this policy and are exempted from this provision. All state laws prevail.

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36VIOLENCE IN THE WORKPLACEAll associates, customers, vendors and business associates must be treated with courtesy and respect at all times. Associates are expected to refrain from conduct that may be dangerous to others.Conduct that threatens or intimidates another associate, customer, vendor or business associate will not be tolerated. SMG resources may not be used to threaten, stalk or harass anyone at the workplace or outside the workplace. SMG treats threats coming from an abusive personal relationship as it does other forms of violence.Indirect or direct threats of violence, incidents of actual violence and suspicious individuals or activities should be reported as soon as possible to a supervisor/manager, Human Resources, or a member of SMG’s Ssenior management team. When reporting a threat or incident of violence, the associate should be as specic and detailed as possible. Associates should not place themselves in peril, nor should they attempt to intercede during an incident.Weapons, including guns, knives, rearms and unauthorized materials, explosives or other objects carried for the apparent purpose of injuring or intimidating another, should never be brought on company premises or carried in vehicles on company business. Associates should promptly inform the Human Resources department of any protective or restraining order that they have obtained that lists the workplace as a protected area. Associates are encouraged to report safety concerns with regard to domestic partner violence. SMG will not retaliate against associates making good-faith reports with regard to domestic partner violence. SMG is committed to supporting victims of domestic partner violence by providing referrals to SMG’s Employee Assistance Program (EAP) and community resources and by providing time off for reasons related to domestic partner violence.SMG will promptly and thoroughly investigate all reports of threats of violence or incidents of actual violence and of suspicious individuals or activities. The identity of the individual making a report will be protected as much as possible. SMG will not retaliate against associates making good-faith reports of violence, threats, suspicious individuals or suspicious activities. In order to maintain workplace safety and the integrity of its investigation, SMG may suspend associates suspected of workplace violence or threats of violence, either with or without pay, pending investigation.Anyone found to be responsible for threats of or actual violence or other conduct that is in violation of these guidelines will be subject to prompt disciplinary action up to and including termination of employment.SMG encourages associates to bring their disputes to the attention of their supervisor/manager or Human Resources before the situation escalates. SMG will not discipline associates for raising such concerns.WEAPONSTo help provide a safe work environment, SMG prohibits all associates who enter the workplace, or who are at company sponsored events or anywhere you are performing your job, from carrying a handgun, rearm or weapon of any kind, regardless of whether or not you are licensed to carry the weapon.WORKERS’ COMPENSATIONSMG and its associates are responsible for taking all measures to ensure safety for themselves and others. Although we hope that you will never experience a workplace illness SAFETY IN THE WORKPLACE

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37or injury, we have set up procedures to follow should such an event occur. They are as follows:• All accidents and illnesses, no matter how small, should be immediately reported to your supervisor/manager.• Your supervisor/manager, along with assistance of your Human Resources representative, will then determine the appropriate medical treatment, which may include:1. On–site rst aid (for minor cuts, scrapes, abrasions, etc.)2. Medical treatment by a physician for non–life threatening injuries. Transportation to the physician’s ofce may be provided for you.3. Emergency medical personnel in life–threatening situations.4. When in doubt, call 911.• Work-related accidents that result in loss of work time and/or property damage, may require post-accident drug, alcohol or controlled substance screening. • Your supervisor/manager will notify your Human Resources representative who will then le an “Employers First Report of Work Injury” with our insurance carrier. The Human Resources contact will need to gather a written account of the details surrounding the illness or injury from you, any witnesses and your supervisor/manager so they may accurately detail the incident in their report. All charges for medical treatment should be forwarded to Human Resources for reimbursement, if warranted.• An injured associate will be paid for the day the injury occurred, even if he/she is not able to return to work.The associate’s absence due to a work–related illness or injury will be handled in accordance with SMG’s Workers’ Compensation Insurance Plan.WORKPLACE BULLYINGSMG denes bullying as “repeated inappropriate behavior, either direct or indirect, whether verbal, physical or otherwise, conducted by one or more persons against another or others, at the place of work and/or in the course of employment.” Such behavior violates the company Code of Ethics, which clearly states that all associates will be treated with dignity and respect.The purpose of this policy is to communicate to all associates, including supervisors, managers and executives, that the company will not tolerate bullying behavior. Associates found in violation of this policy will be disciplined, up to and including termination.Bullying may be intentional or unintentional. However, it must be noted that where an allegation of bullying is made, the intention of the alleged bully is irrelevant. SMG considers the following types of behavior examples of bullying:• Verbal bullying: Slandering, ridiculing or maligning a person or his/her family; persistent name calling that is hurtful, insulting or humiliating; using a person as the butt of jokes; abusive and offensive remarks.• Physical bullying: Pushing, shoving, kicking, poking, tripping, assault or threat of physical assault; damage to a person’s work area or property.• Gesture bullying: Nonverbal threatening gestures or glances that convey threatening messages.• Exclusion: Socially or physically excluding or disregarding a person in work-related activities.

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38BENEFITS CONTINUATION In the event of your departure from SMG, associates are eligible to continue some benets at their own expense. These benets are limited to those in force at the time of termination/employment status change and may include medical, dental, vision, Flexible Spending Account (FSA) and supplemental life insurance. Associates are also eligible for certain options regarding their 401(k), if applicable.Medical, Dental and Vision InsuranceFor associates participating in medical, dental and/or vision coverage at the time of the employment status change, applicable coverage will end at midnight on the last day of the month of which the associate was actively employed. Thereafter, associates may continue their coverage by enrolling in COBRA. Associates will receive a packet containing all the necessary information to enroll directly from the plan administrator directly to their home address typically 2-3 weeks after their employment status change. For this reason, if an associate changes their mailing address, they should let SMG know. If benets are elected and premiums are paid, coverage is reinstated to the rst day of the month following active employment and any denied claims will be reprocessed. You have 60 days to sign up or you lose the option to do so.Flexible Spending AccountAssociates will still be able to request reimbursement for qualifying dependent care expenses from the balance remaining in their dependent care account at the time of termination of employment. Associates must submit claims within 90 days of the end of the plan year in which they terminate. Upon termination of employment, associates’ participation in the medical Flexible Spending Account will cease, and no further salary redirection contributions will be contributed on their behalf. However, associates will be able to submit claims for health care expenses that were incurred before the end of the period for which payments to the medical Flexible Spending Account have already been made. Retirement Account(s) 401(k)Once an associate’s change of employment status is supplied to and updated within the retirement record keeper’s platform (which may take 1-3 weeks, dependent upon timing of payroll or le feed timing) the associate will receive a package from the plan administrator mailed directly to their home address. This will provide detailed information specic to the associate and their account(s) with options for managing their funds moving forward, as well as repayment options for any outstanding loan if applicable. Any additional eligible compensation owed to the associate after their last date of service will continue to have their deduction(s) applied.Supplemental LifeSupplemental life will end effective upon the actual date of the associate’s employment change status. Associates may be eligible to continue their supplemental life insurance coverage for direct billing. Associates will receive information directly from plan administrator for continuation of their policy via portability or conversion (for life coverage only). COBRAThe Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provides you with the right to continue your benets as summarized below.Federal law requires continuation of health benet coverage for a specied period of time for associates and dependents when qualifying events occur. A qualifying event is any event that causes you, your spouse, and/SEPARATION FROM EMPLOYMENT

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40or dependent child(ren) to lose coverage under any of the company’s health plans. Qualifying events include termination (except for cases of gross misconduct;) reduction of work hours; a covered associate’s death; a covered associate’s divorce or legal separation from the spouse; a qualied disability; and/or a covered child’s loss of dependent status under the plan.EXIT INTERVIEWWe would appreciate associates taking the time to participate in an exit interview to answer a list of questions as honestly as possible.We believe that the information is of vital importance and will assist in analyzing our associate retention and turnover. We ask that associates schedule an exit interview with their Human Resource representative before their departure. RETURN OF COMPANY PROPERTYIf you are ending your employment with SMG, you must return all of the items that were supplied for your use during your employment with SMG. Here is a list of some of the items you may need to return. You should return these items to your supervisor/manager directly. This list is not all-inclusive.• Travel and Entertainment Credit Card (if applicable)• Building/Ofce/Key Fobs• Pass Codes/Alarm Passes• ID Badges• Training Materials• Cell/Mobile Phones• Laptop Computers• Tools & Equipment• Samples• Any company reports, information or documents that are deemed condentialDuring your exit interview with your Human Resources representative, you should review the list and make sure you have returned everything.TERMINATIONAssociates of SMG are employed on an at-will basis and the company retains the right to terminate an associate at any time. ResignationYour employment with SMG is at will which means that you or the company may terminate the employment relationship at any time for any reason. We sincerely desire that our associates will want to continue working for our organization, but sometimes situations must change. In the event that you would leave us, we request that you provide adequate notication to your supervisor/manager.RetirementAssociates who wish to retire are required to notify their department manager and Human Resources in writing at least one (1) month before the planned retirement date. Job AbandonmentAssociates who fail to report to work or contact their supervisor/manager for three (3) consecutive workdays shall be considered to have abandoned the job without notice, effective at the end of their normal workday on the third day. The supervisor/manager shall notify Human Resources at the expiration of the third workday and initiate the paperwork to terminate the associate. Associates who are separated due to job abandonment are ineligible to receive accrued benets and ineligible for rehire.

SMG Associate Handbook

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