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EMPLOYEE HANDBOOK January 2022

EMPLOYEE HANDBOOK

January 1, 2022

I UNDERSTAND AND AGREE THAT THIS HANDBOOK AND THE PROVISIONS CONTAINED IN IT DO NOT CREATE AN EXPRESSED OR IMPLIED CONTRACT OF EMPLOYMENT. I ALSO UNDERSTAND AND AGREE THAT MY EMPLOYMENT WITH THE COMPANY IS AT WILL AND THAT BOTH THE COMPANY AND I HAVE THE RIGHT TO TERMINATE MY EMPLOYMENT AT ANY TIME, WITH OR WITHOUT CAUSE. ANY AGREEMENT CONTRARY TO THIS STATEMENT OR TO ANY PROVISION IN THIS HANDBOOK MUST BE IN WRITING AND SIGNED BY THE COMPANY’S VICE PRESIDENT OF HUMAN RESOURCES.

PRINT NAME ________________________________

DATE

________________________________

EMPLOYEE SIGNATURE _________________________________

Leave Intentionally Blank

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CONTENTS

Welcome to AURIA

Forward

Employment/Work Environment A. Our Mission Statement B. Environmental Policy C. Occupational Health & Safety Policy D. Quality Policy E. Equal Employment Opportunity Policy F. Harassment Free Workplace Policy G. Open Door Policy H. Employee Status I. Code of Conduct J. Performance Evaluations K. Job Opportunities and Transfers A. Disciplinary Policy B. Personal Conduct and Work Rules C. Attendance D. Comprehensive Substance Abuse Policy E. Search, Inspection, Investigation F. Electronic Communication Policy G. Information Technology / Internet Policy H. Information Security I. Dress Code J. Workplace Violence and Weapons Policy K. Personal Property L. Plant Visitation M. Solicitation N. Tobacco Use O. Bulletin Boards A. Bereavement Leave (Funeral) B. Holidays C. Vacation D. Jury Duty E. Family Medical Leave Act Policy (FMLA) F. Military Leave (USERRA) G. Medical Leave H. Health and Welfare i. Medical/Dental/Vision Benefits, Compensation and Time Off On the Job

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I.

Page 13

II.

Page 25

III.

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ii. Income Protection iii. Life Insurance iv. Flexible Spending Account v. Tax Savings vi. Benefits on a Reduce Work Schedule vii. Change in Status

I. Employee Assistance Plan J. 401k K. Legal Plan L. Workers Compensation M. Tuition Reimbursement Policy N. Hours and Pay i. Employee Status

ii. Hours of Work iii. Overtime Pay iv. Emergency Callback Pay v. Direct Deposit

Safe Workplace

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IV.

A. General Safety Rules B. Reporting of Injury C. Powered Industrial Trucks D. ID Badges E. Personal Electronic Devices Leaving the Company A. Resignation B. Benefits Continuation

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V.

Appendix A

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VI.

A. Code of Business Conduct and Ethics B. Complaint Reporting Form

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WELCOME TO AURIA SOLUTIONS

Auria is a leading global supplier of automotive acoustical and textile solutions. Formed in 2017 as a joint venture between Shanghai Shenda Co., Ltd., and International Automotive Components (IAC) Group, Auria is built on a 150-year transportation industry heritage. Our product line includes highly engineered acoustical solutions for interior noise reduction, textile-based and compression-molded flooring products and other interior soft trim products, including package trays, trunk trim and wheel arch liners. Auria operates 25 manufacturing and 10 commercial, engineering and testing and tooling facilities in 10 countries and has nearly 5,000 employees worldwide. We are committed to making an effort to provide our employees with a safe work environment, competitive benefits and open communication between employees and management. In return, we ask that you put forth your best effort. This guide has been prepared to provide you with a better understanding of what you may expect from the Company, and also to give you an overview of what the Company will expect from you. It covers a number of subjects that apply to your employment, as well as services and benefits with which you should become familiar.

We are glad you are part of our team. We look forward to a mutually beneficial and productive relationship with you.

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FORWARD

T his Employee Handbook is designed to serve as a guide only. It is not intended or written to include all Company policies, procedures, or practices. Employment with AURIA (Company) is “at-will”, meaning either the employer or the employee can terminate the relationship at any time and for any reason, with or without prior notice. Statements made by management or supervisors, especially those that contradict the employee’s at-will status, are not binding on the Company. This Employee Handbook is not intended nor does it constitute an express or implied contract of any kind in favor of employees nor shall any employee or applicant for employment have contracted rights, claims or privileges against the Company by virtue of this Employee Handbook. Moreover, nothing in this Employee Handbook is intended to create any type of agreement for employment or continued employment or guarantee of hours of work. While this manual may be added to or changed as needed by the Company without prior notice to employees, the Company’s adherence to its policy of employment-at-will shall not be modified in any case. The Company reserves the right to establish and interpret Company policy for any occurrence, either contained or not contained, within this handbook. The Company further reserves the right to change its policies, or to vary their application in particular cases, as the Company deems appropriate. Your continued employment with the Company is acceptance of its policies and procedures. This Employee Handbook is not all-inclusive and does not address in detail the Company’s insurance or other benefit plans. Any questions regarding these policies or any benefits offered by the Company should be directed to the local Human Resources department. Questions or concerns regarding the Company’s insurance and other company benefits will be determined by reference to the actual benefit plan documents and policies rather than any summaries contained in this Employee Handbook. The Company reserves the right to alter, amend, or suspend the terms of this handbook at its sole discretion. Any agreement contrary to any statement or any policy in this Handbook must be in writing and signed by AURIA’s Vice President of Human Resources. The personnel policies described within this handbook supersede all previous handbooks and are effective immediately.

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I. EMPLOYMENT / WORK ENVIRONMENT

A. OUR MISSION STATEMENT

Building on a One Company – One Voice communication philosophy, our goals are to:

 Implement internal and external communication strategies and tactics designed to support our overall European and global business objectives in a planned and controlled process, fostering consistent messaging across all target groups,  Identify and bridge common messaging between regions that can be used to build ONE informed global Auria community,  Seek unique regional product/solution stories that can be shared with stakeholders to reinforce Auria’s global and regional business objectives,  Identify best practices from a single Auria location that can be shared with Auria employees around the world in order to achieve world-class status.

B. ENVIRONMENTAL POLICY

Auria, its subsidiaries and affiliates, is committed to environmental protection, regulatory compliance, and pollution prevention through a strategy of continuous improvement and teamwork.

The foundation of our commitment is:

 The prevention of pollution by maintaining environmental management as a core value.  Leadership for environmental performance through management example, employee involvement, and employee empowerment.  Developing and utilizing environmentally acceptable, safe, and efficient production methods.  Identifying and complying with all legal and other requirements.  Continuous improvement by analyzing our commitment through the use of Key Performance Indicators.

C. OCCUPATIONAL HEALTH & SAFETY POLICY

Auria, its subsidiaries and affiliates, is committed to plan and perform all operations in a manner that is safe and efficient for its employees and the public. We believe that leadership is a critical element in sustaining a compliant, safety conscious work environment. Auria management is responsible for keeping safety at the forefront of its business planning and execution to continuously improve operational discipline and our safety culture.

The commitment is based on:

 A comprehensive understanding of worker expectations and requirements.  Compliance to statutory, regulatory, and other legal requirements.

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 Demonstrating employee safety leadership in all our processes, striving always for world class performance. • Continual improvement by analyzing this commitment through the use of Key Performance Indicators and OH&S objectives. Worker health and safety is a shared responsibility where the company and its employees each have a role in ensuring the safety of those affected by our work, eliminating hazards, and reducing OH&S risks. To foster our shared responsibility, Auria is committed to the consultation and participation of our employees; and where they exist, our employees’ representatives.

D. QUALITY POLICY

Auria is dedicated to delivering the highest level of quality and customer satisfaction through the never-ending pursuit of excellence in all our products, services, and relationships.

The fundamentals for achieving our commitment to total customer satisfaction are:

 A comprehensive understanding of customer expectations, requirements, and compliance to statutory, regulatory, and industry requirements.  Demonstrating quality leadership in all our processes, striving always for world class performance.  Continual improvement of the Quality Management System by analyzing process efficiency through the use of Customer and Internal Key Performance Indicators.  Dedication to quality excellence by all our associates worldwide.

E. EQUAL EMPLOYMENT OPPORTUNITY POLICY

Auria is committed to providing a professional work environment free of all forms of illegal discrimination and harassment. This commitment continues Auria’s long-standing policy to offer fair and equal employment opportunity to every person regardless of race, color, religion, gender, national origin, age, physical or mental disability, sexual orientation, genetic information, status as a covered veteran, or other legally protected status. It is Auria’s policy to comply with federal, state and local laws governing unlawful discrimination in employment in each locality where Auria has employees. Auria values diversity in its workforce and strongly opposes any attempts to restrict the development of the productive potential of any individual. The commitment to provide equal employment opportunity places an obligation and responsibility not only on Auria, but also on each employee, irrespective of organizational level or position. Every employee is expected to ensure that all decisions related to our business are made on the basis of merit and the facts that are available, and not on unlawful discriminatory factors.

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Auria will provide qualified individuals with a disability with reasonable accommodations as required by law that do not result in undue hardship for Auria. If you are an employee with a disability who needs a reasonable accommodation to perform the essential functions of your job, you should notify your facility Human Resources Manager. If you feel you are being denied equal employment opportunity or are otherwise aware of any unlawful discrimination, or if you have any questions, problems or complaints concerning equal employment opportunities or discrimination, you should inform your facility Human Resources Manager or Human Resources Representative. Auria does not tolerate unlawful discrimination of any kind, nor does it tolerate retaliation against anyone who makes a bona fide complaint of unlawful discrimination or who assist or cooperates in the investigation of a complaint. Auria will take disciplinary action, up to and including dismissal, of anyone who engages in unlawful discrimination or retaliation.

F. HARASSMENT-FREE WORKPLACE POLICY

1. Statement

Auria Solutions USA, Inc. (“Auria”) is committed to maintaining a workplace in which individuals are treated with respect and dignity. Nothing detracts from the work environment more than harassment of employees, for any reason. Each individual has the right to work in an environment which promotes equal employment opportunities and is free of unlawful discrimination in any form, including harassment. Harassment on the basis of innate or personal characteristics, such as race, gender, color, veteran status, national origin, religion, physical or mental disability, age, sexual orientation, genetic information and any other legally protected status, no matter the form or intention, is totally inappropriate behavior, unlawful and violation of Auria policy. To further the goal in maintaining a professional and respectful work environment, Auria has adopted this Harassment-Free Workplace Policy. This Policy applies to all persons who are employed by, or conduct business with Auria, whether as managers, non-supervisory employees or third parties. Pursuant to this Harassment-Free Workplace Policy, Auria expressly prohibits and will not tolerate any form of unlawful discrimination or harassment. Employees who violate this Policy will be subject to disciplinary action, up to and including termination of employment.

2. Definitions and Examples

Federal and state laws prohibit any form of harassment on the basis of race, gender, color, veteran status, national origin, religion, physical or mental disability, age, sexual orientation, genetic information and any other status protected by applicable federal and state, or local law. Unreasonable interference with an individual’s work performance or creation of a hostile, intimidating or offensive working environment will not be tolerated. Such offensive behavior may take a variety of forms, including, but not limited to:

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 Epithets, derogatory comments, comments involving sexual innuendo jokes or slurs involving or based on a protected status.  Derogatory or offensive posters, cards, objects, symbols, calendars, cartoons, graffiti, drawings, or gestures involving or based on a protected status.  Assaults, blocking normal movement, inappropriate touching, or interfering with work.  Retaliation for having reported or threatened to report unlawful harassment. Federal and state laws define sexual harassment as unwelcome sexual advances, requests for sexual favors, and other visual, verbal, or physical contact of sexual nature when:  Submission to such conduct is made either explicitly or implicitly a term or condition of employment; or  Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; or  Such conduct has the purpose or effect of unreasonably interfering with an employee’s work performance or creating an intimidating, hostile or offensive working environment. Each Auria employee must be sensitive to the way that words and actions can be perceived by others. If your words or actions could reasonably be perceived as offensive and unwelcome , this can be unlawful harassment. The following are some examples of conduct which, if unwelcome, may constitute sexual harassment depending upon the totality of the circumstances, including the severity of the conduct and its pervasiveness:  Sexual advances – whether they involve physical touching or not.  Direct or implied requests by a supervisor for sexual favors in exchange for actual or promised job benefits such as favorable reviews, wage/salary increases, promotions, increased benefits, or continued employment.  Sexual epithets, innuendos, jokes, written or oral references to sexual conduct, gossip regarding one’s sex life, comments on an individual’s body, comments about an individual’s sexual activity, deficiencies, or prowess.  Displaying sexually suggestive objects, pictures, cartoons.  Unwelcome leering, whistling, brushing against the body, touching, sexual gestures, suggestive or insulting comments.

 Inquiries into one’s sexual experience.  Discussion of one’s sexual activities.

Regardless of its form, unlawful harassment of employees occurring in the workplace or in other settings in which employees perform their work is unlawful and will not be

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tolerated by Auria. Further, any retaliation against an individual who, in good faith, has complained about unlawful workplace discrimination, retaliation or harassment, or who has cooperated with Auria’s investigation of such matters, is similarly unlawful and will not be tolerated.

3. Complaints of Unlawful Workplace Harassment

Employees who have experienced conduct they believe is contrary to this Policy have an obligation to use this complaint procedure.

Each employee must help keep the workplace free of unlawful harassment. If an employee experiences conduct that violates this Policy, the employee should tell the harasser to stop if the employee feels comfortable doing so. Employees who have experienced or witnessed job-related conduct by employees, clients, or other third parties that they believe is unlawful harassment, or who believe that they have been treated in an unlawful, discriminatory manner, must promptly report the incident or concern to their supervisor. If they are not comfortable reporting to the supervisor, you may contact the Human Resources Manager. Complaints may be made verbally or in writing. Auria forbids retaliation against anyone who reports harassment or cooperates in an investigation of harassment. Auria strongly urges the reporting of all incidents of unlawful harassment, discrimination, or retaliation regardless of the offender’s identity or position. All complaints will be promptly and thoroughly investigated. Auria will maintain confidentiality throughout the investigatory process to the extent consistent with a fair and proper investigation. All employees involved in an investigation must also observe this confidentiality obligation. If it is determined that conduct in violation of this Policy has occurred, Auria will act promptly to eliminate the offending conduct and will take such other corrective action as it deems necessary to prevent the inappropriate conduct from reoccurring. Such action may include discipline up to and including termination of employment.

G. OPEN DOOR POLICY

1. Overview

AURIA has established an Open Door Policy for use by all employees. This procedure has been established to provide each employee with a readily accessible method of asking questions, making suggestions, and resolving issues and complaints on a mutually satisfactory basis.

2. Procedure

The employee should follow the normal chain of command when using the Open Door procedure. This means:  The employee should begin by discussing the issue with their immediate supervisor.  If the issue involves the immediate supervisor, the employee should consult with the next level of supervision.

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 Any employee may see the Human Resources Manager or their designee at any time by request.  If an employee is not satisfied after discussing an issue with appropriate supervision and/or the Human Resources Manager, they may request that the Human Resources Manager arrange an interview with the Location/Plant Manager. The Open Door Policy is actively supported by management and utilized by all employees. This procedure is for use “at will” by all employees and should be used without fear of reprisal.

All employees should be informed about the Open Door Policy and procedure through employee orientation and this handbook.

H. EMPLOYEE STATUS

1. All newly hired AURIA employees are subject to a ninety (90) day Introductory Period to ensure that they are qualified to perform the job into which they have been hired. This period is designed to foster mutual understanding of expectations, work rules and performance objectives. Successful completion of the introductory period does not alter the at-will nature of employment.

2. An employee on leave of absence for more than twenty-six (26) weeks shall be terminated and if rehired will have the status of a new hire.

I. CODE OF CONDUCT

The AURIA Code of Business Conduct and Ethics (the "Code of Conduct") is a critical component of the Company’s overall Compliance Program. The Code was developed to ensure AURIA meets the highest ethical standards and comply with applicable laws and regulations wherever it does business. This Code provides guidance to all AURIA employees and assists them in carrying out their daily activities within appropriate ethical and legal standards. These obligations apply to relationships with suppliers, subcontractors, independent contractors, vendors, consultants, and one another. AURIA’s mission and value statements clearly commit the Company and its employees to treating these and all individuals with respect and dignity. The AURIA Code is the code by which the Company puts those values into practice. AURIA encourages all its employees to read this Code (it can be found in full in Appendix A at the end of this handbook), then read it again, and remember that as our Company evolves, the AURIA Code will evolve as well. Each AURIA employee has a personal responsibility to incorporate, and to encourage others to incorporate these principles into how we conduct our business. Please go to your Human Resources Department if you would like a copy of the Code of Conduct or need assistance in understanding and utilizing the complaint procedure included in the Code.

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J. PERFORMANCE EVALUATIONS

One of the keys to our success is the communication between the supervisor and employee. One communication tool we use is the performance evaluation. The purpose of the performance evaluation is to provide feedback to the employee on their work performance over a period of time and to then set objectives for the employee to work towards. Areas such as productivity, quality, dependability, job knowledge, safety and employee involvement can be covered in the evaluation. In addition, AURIA feels that the evaluation is a component in determining suitability for job advancement and progression as new opportunities become available. Employees should talk with their supervisor or the Human Resources Department if they have any questions about the performance evaluation process.

K. JOB OPPORTUNITIES AND TRANSFERS

Job vacancies are created by the expansion of the work force (production personnel), by the departure of an employee from the Company or by the creation of a new position. The Company reserves the right not to fill a position left vacant by a departing employee. Whenever possible, current qualified employees will be promoted from within. The Company reserves the right, in its discretion, to hire new employees as required.

When vacancies are to be filled from within the existing workforce, the following procedure will be utilized:

1. Vacancies will be posted on Company bulletin boards. Contact your Human Resources Department for the procedure on how to apply for the open position.

2. Temporary employees and employees who have not completed the 90 day introductory period are ineligible to apply for posted vacancies. The company reserves the right to amend this policy based on business needs.

3. Only employees who have placed their name on the list stating the job opportunity will qualify for consideration for the posted job opportunity.

4. Vacancies will be filled with the most qualified candidate. Qualifications include, but are not limited to; job knowledge, experience, quantity and quality of work, attendance, disciplinary record, and skill as related to the vacancy. Should no one within the Company sign up for consideration or should no one who did sign up possess the necessary skills and abilities to perform the job, the Company may fill the position by hiring from the outside. 5. In the event two or more candidates are relatively equal in job knowledge, experience, quantity and quality of work, attendance, disciplinary record, and skill, preference will be given to the individual with the longest continuous Company service.

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6. Employees who are selected for the new job opportunity under this procedure are ineligible to sign up for another job opportunity for at least six months. The company has the right to amend this policy based on business needs.

II. ON THE JOB

A. DISCIPLINARY POLICY

Our Company maintains and administers the necessary regulations and disciplinary policies in a fair and consistent manner. It is the obligation and responsibility of all employees to conform to those rules and regulations that are applicable to their work assignment. The Company uses a “progressive discipline” system where a less severe type of discipline is usually administered before more severe disciplinary procedures are used. However, the Company reserves the right to begin the disciplinary actions at any step listed below depending on past practice and/or on the nature and seriousness of the offense committed. 1. Documented Counseling (Verbal) – a written notice issued to an employee indicating seriousness of offense and warning that more severe discipline up to termination of employment may result if the problem is not corrected or continues to occur. 2. Written Warning - a formal written notice issued to an employee indicating seriousness of offense and warning that more severe discipline up to termination of employment may result if the problem is not corrected or continues to occur. 3. Final Written Warning - a formal notice to employee indicating that termination of employment may occur if the problem is not corrected or continues to occur. Suspension may be used in conjunction with the Final Written Warning. 4. Termination of Employment

B. PERSONAL CONDUCT AND WORK RULES

It is the intention of the Company to openly communicate to all employees its expectations regarding workplace conduct. Employees are urged to use reasonable judgment at all times and to seek supervisory advice in any doubtful situation. The examples of unacceptable conduct listed below are to provide employees with guidelines as to the type of misconduct that could lead to disciplinary action. This list should not be considered as all-inclusive. Should instances of unacceptable conduct arise that are not included in the following examples, the Company reserves the right to initiate disciplinary action.

Violation of any of the following rules may lead to documented disciplinary action up to and including termination.

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1. Falsifying work time records, personnel records, production records or other Company documents.

2. Refusal to carry out work assignments relating to the work of the Company and/or refusal to accept routine changes in department assignment.

3. Theft of any kind is prohibited.

4. Deliberate waste, damage, defacing or attempting to damage, deface or destroy company property or a fellow employee’s property including materials, supplies products, equipment, and/or computers. This includes graffiti anywhere on Company property.

5. The use of any kind of tobacco related product – including e-cigarettes – in any area other than the designated “smoking area” outside the main buildings.

6. Obtaining materials or tools from the assigned place under fraudulent orders or misrepresentations.

7. Fighting or provocations leading to fighting on Company premises or at authorized Company functions.

8. Being absent from work on three (3) consecutive days without calling in within the allotted time as stated in the Attendance Policy. This will be considered a voluntary quit. 9. Reporting for work or working under the influence of alcohol (.06% blood alcohol concentration or above) or drugs. Possessing or drinking of any alcoholic beverages while on the Company premises. Possessing or taking any controlled or illicit drugs while on Company premises. This does not apply to those drugs prescribed by a physician, or any over the counter drugs. An employee whose ability to work safely is impaired by a drug prescribed for the employee by a physician and used by the employee as prescribed, must report such use to their supervisor and/or Human Resources, prior to the start of their workday, so that appropriate action may be taken, including transfer, reassignment and/or leave of absence. 11.Taking photographs, making sketches or writing descriptions of any Company property, products, or employees without permission. This is to include making videos of company property or products without permission from management. 12.The company expects that all employees work together harmoniously and not subject any employee(s) or contractors to harassment based on their sex, race, national origin, disability, age, or sexual orientation. In addition, threatening, harassing, intimidating. Or coercive behavior towards any employee or contractor will not be 10.Refusal to submit to drug, substance, or alcohol testing.

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tolerated. This includes the communication and posting of offensive jokes, pictures and/or other materials in the workplace.

13. Immoral, indecent, or improper conduct on Company property or at a Company sponsored event. This include immoral, indecent, offensive, or improper music.

14.Any violation of the company Code of Conduct Policy.

15.Defacing Company bulletin boards or the materials posted on them. Posting or removing notices of any kind on the bulletin boards or Company property.

16.Coercing, bribing, inciting or otherwise inducing employees to engage in any practice in violation of Company rules.

17. Insubordination or using abusive, rude, or disrespectful language or threats to Company employees, supervisors, managers, or customers.

18. Leaving Company premises during working hours without permission from the supervisor or an authorized Company representative. When an employee leaves the plant during working hours with permission, their timecard must be swiped out and must be swiped in upon returning to the plant.

19.Sleeping while on duty.

20.Violation of any Company, State or Federal law, rule or regulation not covered in this policy.

21.Carrying firearms or other weapons on Company property, inside any Company facility or at any Company sponsored event.

22.Recording meetings and/or conversations on Company premises without permission.

23.Creating or contributing to unsanitary conditions, including failure to maintain appropriate personal hygiene.

24.Engaging in horseplay or any verbal/physical activity that would cause inattention or disruption to duties.

25.Stopping work before the end of a shift, not being ready to begin work at the start of a shift, working overtime without permission of a supervisor, or returning late from lunch or breaks.

26. Leaving the work area without permission from the supervisor.

27.Handling personal affairs during working time without receiving permission from the supervisor.

28. Inefficiency, lack of initiative on the job, or unsatisfactory work performance.

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29.The unauthorized use of personal cell phones or other personal electronic devices during working hours. This includes the use of all electronic devices for personal reasons in areas other than break rooms, offices, or outside the facility.

30.Failure to cooperate fully in any company investigation.

31.Employees will not engage in any activity that would result in distracted driving while operating a company vehicle. This would include the use of any electronic device.

32.The tampering with locks or lockers or removal of any materials, products, or equipment, including salvage items from the plant premises without the written permission of management.

33.Excessive absenteeism in violation of the Attendance Policy.

34.Entering company property at times other than the scheduled work hours without permission from management.

35.Driving company vehicles without permission or without being licensed is prohibited.

36.Product tampering or unauthorized alteration of any kind to company products or materials is prohibited.

C. ATTENDANCE

The success of AURIA is dependent on employees being at work every day when scheduled. It is understood that on occasion, illness or other important reasons might prevent an employee from attending work or cause them to be late for work. Please see your local Human Resources Department for details on how the attendance policy works.

D. COMPREHENSIVE SUBSTANCE ABUSE POLICY

1. Overview It is the policy of Auria Solutions USA, Inc. (“Auria” or the "Company”) that our workplace should be free from drug and alcohol abuse. Our employees cannot work safely and productively if they report for work or work while they are impaired by alcohol or drugs.

Violation of the following work rules is grounds for immediate discipline up to and including discharge:

 Possession, use, adulteration, sale, attempted sale, purchase, attempted purchase, conveyance, distribution, transfer, cultivation, and/or manufacture of any alcoholic beverage on Company property, including the parking lot and driveway, and in Company vehicles, at any time, including during breaks or lunch. Reporting for work while impaired by alcohol.

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 Possession, use, adulteration, sale, attempted sale, purchase, attempted purchase, conveyance, distribution, transfer, cultivation, and/or manufacture of any controlled or illicit drug, including marijuana, on Company property, including the parking lot and driveway, and in Company vehicles, at any time, including breaks or lunch. Reporting for work or working while impaired by any controlled or illicit substance, including marijuana, except a drug prescribed for the employee by a physician. An employee whose ability to work safely is impaired by a drug prescribed for the employee by a physician and used by the employee as prescribed, must report such use to their supervisor and/or Human Resources, so that appropriate action may be taken, including transfer, reassignment, and/or a leave of absence. The Company may search an employee's purse, locker, lunch box, car, or other personal property on Company premises, or may ask an employee to empty his or her pockets where there is a reasonable belief that an employee has violated this Policy. A refusal to be searched is insubordination, which is subject to discipline, up to and including discharge. Employees who are not actually on Company property, but are performing work for the Company, are also subject to this Policy. Failure by any employee to comply with these rules while on Company business off site will be treated the same as if the employee were on Company property. 2. Pre-Employment Drug Testing All applicants for employment who receive conditional offers of employment will be tested for drugs at the Company's expense. A qualification for employment by the Company is to pass the pre-employment drug test. The conditional offer of employment may be withdrawn if the applicant receives a non-negative test result or refuses to take the pre-employment drug test or to sign the consent form for the test. 3. Reasonable Suspicion Alcohol and Drug Testing The Company will usually require an employee reasonably suspected of being impaired by alcohol and/or drugs to be tested for alcohol and/or drugs at Company expense at a certified laboratory. The Company will only require an employee to be tested for alcohol and/or drugs if two supervisors reasonably suspect the employee to be impaired by alcohol and/or drugs based on their observations of the employee's job performance, personal behavior, or any other evidence of alcohol or drug abuse. If, however, a second supervisor is not available or able to observe the employee, the Company may rely on the observations of one supervisor. 4. Post-Accident or On-the-Job Injury Alcohol and Drug Testing An employee who is involved in an on-the-job accident or injury may be tested for alcohol and drugs at the Company's expense at a certified laboratory, as part of the Company's investigation into the cause of the accident or injury.

The Company may require the alcohol and drug testing of any employee:

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 Involved in an on-the-job accident resulting, in the Company's opinion, significant damage to personnel, materials, equipment, vehicles, or product.  Driving any Company car, truck, hi-lo, or other vehicle, and is involved in an accident.  Whose on-the-job injury warrants medical treatment at a medical facility.

5. Discipline

A refusal by any employee to take an alcohol or drug test is insubordination and will result in immediate discipline up to and including discharge. An employee who receives a positive test result will be subject to discipline up to and including discharge.

It is the right of the company to suspend any employee until test results are confirmed. If negative, back pay for time missed will be awarded to the employee.

For purposes of this policy, the cut-off level for a positive alcohol test is a blood alcohol content of .06% or above.

E. SEARCH, INSPECTION, AND INVESTIGATION

The Company reserves the right, when deemed necessary by management, for authorized persons to search and inspect both Company property, Company lockers and personal items, including vehicles on Company property. Such a search would normally be requested as part of an investigation for theft, unauthorized/illegal substances, weapons, or other items that might interfere with the safety and/or security of company personnel or property. Refusal to cooperate in a search, inspection, or investigation could result in disciplinary action up to and including termination.

F. ELECTRONIC COMMUNICATIONS POLICY

Electronic communications include communicating or posting information or content of any sort through email, text messaging, video posting, blogging, message boards and social media sites such as Twitter, LinkedIn, Facebook, YouTube, etc., that exist now or may come into existence in the future. Notwithstanding any other Company policy, this policy applies to your electronic communications regardless of form and concerning the Company, an individual, a customer, or a supplier, and whether made at the office or out of the office. The Company reserves and will exercise the right to access, intercept, inspect, monitor, record and disclose any and all electronic communications regardless of the form generated, transmitted, received, stored, or otherwise communicated using the Company’s electronic equipment. For the purposes of this policy, “electronic equipment” includes the Company’s software and business equipment, including telephones and cell phones (including but not limited to personal cell phones and other electronic devices that access the Company’s network) facsimile machines, computers, electronic mail system, Internet access, scanners, and copy machines. Employees have no right or expectation of privacy

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in using the Company’s electronic equipment or in communications made through its email system or network.

If you choose to create or participate in any type of Internet communication or other form of online posting/publishing, or social media discussion, you should be aware of the following Company guidelines pertaining to such activity: 1. If you are communicating about Company-related matters, you must make it clear that you speak for yourself and not for the Company. The easiest way to ensure that you are not in violation of this obligation is to refrain from mentioning the Company by name. If you do publish a blog or post online related to the work you do, or subjects associated with the Company, it is best to use a disclaimer such as “The postings on this site are my own and do not necessarily reflect the views of Auria.” 2. Be mindful that what you post/publish not only travels fast, but also will more than likely be transferred to others and will stay in the public domain forever. Understand further, that you are personally accountable for what you post/publish or send. Before creating content, consider some of the risks and rewards that are involved. Keep in mind that any of your conduct that adversely affects your job performance, the performance of fellow employees or otherwise adversely affects customers, suppliers, or people who work on behalf of the Company or the Company’s legitimate business interests may result in disciplinary action up to and including termination. Revised: 11/12/2019 3. You must comply with all Company policies, including but not limited to, the Code of Business Conduct and Ethics, policies concerning confidentiality, prohibiting workplace discrimination and harassment, and the Code of Conduct. Inappropriate postings that may include discriminatory remarks, harassment, and threats of violence or similar inappropriate or unlawful conduct will not be tolerated and may subject you to disciplinary action up to and including termination. 4. You should use good judgment about what you share. Maintain the confidentiality of the Company’s trade secrets and private or confidential information of the Company or its customers and suppliers. Trade secrets may include information regarding the development of systems, processes, products, know-how, and technology. Do not post internal reports, policies, procedures, or other internal business-related confidential communications. Remember the Company’s confidentiality applies to information shared through social media. Do not create a link from your blog, website, or other social networking site to a Company website without identifying yourself as a Company employee. 5. You should take care to be honest and accurate in your communications. If you make a mistake, correct it quickly. Never post any information or rumors that you know to be false about the Company, fellow employees, customers, suppliers, stockholders, or people working on behalf of the Company or its competitors.

6. Do not use a Company email address to register on social media sites, blogs, or other online tools for personal use.

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Violations of this policy can result in discipline, up to and including termination of employment. Note that Auria is aware of its obligations in regard to protected concerted activity under the National Labor Relations Act, and none of the prohibitions contained in this policy are intended, nor will have the actual effect of, infringing upon those rights.

G. Information Technology / Internet Policy

This policy outlines the obligation of all AURIA sites regarding Internet connections. An internet connection is defined as a communications service provided through companies or individuals supplying internet browsing, http, html, email or any other internet service through direct wired (wide area network, cable), dial up wireless or any other means of communications. This policy states expectations regarding internet related services usage and security. 1. Applicability This applies to all AURIA departments, business unites, office and locations. This policy may also apply to joint venture, start up and business partner sites as necessary or requested. 2. Scope of Policy This policy governs the obligation of the applicable sites, as described above, to follow these regulations with a collective goal of providing protection from unauthorized internet access into AURIA’s confidential, proprietary and trade secret information located on central computer systems, individual personal computers (both desktop and laptop) and any other computer or network equipment in use by the Company. Proper security and anti-virus protection is required as a safeguard against imminent internet related threats. Required internet access will be provided to AURIA sites under the direction of Corporate Information Technology (CIT) as a secured service, and will include firewall, proxy, anti- virus, and other security services as required. 3. Policy All access points between AURIA sites and the internet, whether direct or indirect, will be approved and managed by CIT. Internet access points not meeting these criteria are in violation of this policy and will be disabled immediately. The Company further expects that all known access points between AURIA sites and the internet that have not been reviewed and approved by CIT be immediately reported to the CIT network manager. These access points will be addressed on a case-by-cade basis and modified as needed to ensure optimal security is present in all connections between AURIA networks and the internet. CIT will be using software tools to monitor the number and types of internet access points, and therefore, compliance with this policy and/or failure to abide by this policy will result in disciplinary actions up to and including termination.

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H. INFORMATION SECURITY

Information is a valuable corporate asset. The preservation of its integrity, confidentiality, and availability is essential to the success of AURIA. Measures must be taken to protect information and information processing systems against unauthorized use, modification, disclosure and destruction, whether accidental or intentional. The method used to protect corporate information resources must be consistent with the value of those resources. The Information Security Policy states the requirements for protecting information resources at AURIA. The Information Security and the standards that it contains have been developed to control business risks and ensure that AURIA maintains its standard of excellence. The standards address the following information security concerns:

 User accountability including password guidelines  Electronic Mail

 Internet access and usage  Software licensing and use  Virus Protection  Laptop Security  Telecommunication  Data back up and recovery

Company policies prohibiting sexual or other harassment (race, national origin, religion, age, etc.) are applicable to the internet, e-mail, and voice-mail systems. Messages that contain off- color, inappropriate, or offensive language or depictions, whether textual or pictorial, or those containing racial or ethnic slurs, or sexual innuendo, are prohibited. Failure to comply may result in disciplinary action up to and including termination of employment or contractual relationships. The Company, at its discretion, may also pursue civil remedies or criminal prosecution. There is no privacy or expectation of privacy in the use of any corporate information systems or technologies. Users are prohibited from using programs or devices to bypass or disable any security measures anywhere on the network. In addition to the system hardware and software, all electronic files and electronic messages are the property of the Company, whether composed, received, or sent by the employee. E- mail messages and other electronic files are business records belonging to the Company. All e-mail and voice-mail messages are the property of the Company. Employees do not have any right to privacy with regard to use of any of the Company’s communications or information systems or technologies. They should not expect use of e-mail, telephone, and voice-mail systems, including messages, is private. In addition, employees should be aware that deleted messages and files may be retrieved and read by the Company. The Company has the right to retrieve, monitor, or review Internet use and any messages in the system and may disclose such use and messages for any purpose without notice to the employee and without seeking permission of the employee.

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Passwords must be disclosed to the appropriate officer upon request. Users are prohibited from using programs or devices to bypass or disable any security measures anywhere on the network.

Refer to AURIA’s Information Security Policy which pertains to all employees with access to computers and the expectation that all employees must comply with this policy.

I. DRESS CODE POLICY

As a manufacturing facility, Auria understands the need for its employees to have a dress code that incorporates flexibility, is appropriate to the employees work-station and supports employee safety. Employees are expected, at all times, to present a professional, businesslike image to customers (whether internal or external), prospects and the public. Acceptable personal appearance is an ongoing requirement of employment with the Company. Offensive slogans or designs on clothing are not permitted. Questions concerning the specific requirements of the dress code policy should be directed to a Supervisor, facility Human Resources Manager. A detailed Dress Code Policy can be obtained from the local Human Resources department. 1. Policy Statement It is the policy of AURIA Solutions Group North America, Inc. ("AURIA" or the "Company") to provide a working environment that is free from violent acts or threats of violence. Violence in the workplace may occur between one employee and another, or between a member of the public and an employee. Such acts or threats of violence by physical acts, words, gestures, or symbols are entirely unacceptable and violate the Company’s policy. Every employee is required to report acts or threats of violence of which they are aware. Notwithstanding any state or federal mandates in the state in which your facility is located, the Company adopts a zero-tolerance policy for weapons, violence, and threats of violence in the workplace. This means that employees are prohibited from carrying weapons and engaging in or threatening acts of violence in the course of their employment. 2. Definitions A “weapon” includes, but is not limited to, any of the following: a firearm, including a BB gun, whether loaded or unloaded; any knife, including a switchblade or other knife having an automatic spring release device with a blade length greater than 3 inches; any police type baton or night stick; any martial arts weapon; and any electronic defense weapon. “Threats or acts of violence” are defined as any threatening behavior, acts of violence or any related conduct which disrupts another’s work performance or the organization’s business purpose. J. WORKPLACE VIOLENCE AND WEAPONS POLICY

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