EMPLOYEE HANDBOOK
Midwest Fastener Corp. 9031 Shaver Road Kalamazoo, MI 49024 800-444-7313 fastenerconnection.com
2025
Table of Contents
SECTION 1 Introduction............................ 1 1.1 Welcome to Midwest Fastener Corp. . . . . .... 1 1.2 Employee Handbook . . . . . . . . . . ........... 1 1.3 Changes in Policy . . . . . . . . . . . ............ 1 1.4 Employment-At-Will . . . . . . . . . . . ........... 2 1.5 Arbitration Policy . . . . . . . . . . . . ............ 2 1.6 Employment Applications. . . . . . . . . ......... 2 1.7 Employment Reference Checks. . . . . . ....... 2 SECTION 2 EmploymentPolicies.................... 3 2.1 Employee Classifications . . . . . . . . ......... 4 ExemptEmployees....................... 4 NonexemptEmployees.................... 4 Non-exempt Salaried/Regular Employee . . . . . . 4 Non-exempt Hourly/Regular Employee.. . . . . . . 4 Full-Time................................ 4 Part-Time............................... 4 TemporaryEmployees..................... 4 Independent Contractor or Consultant.. . . . . . . . 5 2.2 Definition of Credited Hours. . . . . . . ........ 5 2.3 Introductory Period . . . . . . . . . . . ........... 5 2.4 Equal Employment Opportunity & Americans with Disabilities Act . . . . . ..... 6 2.5 Criminal Background Checks & Drug Screens . . 6 2.6 Fraud, Dishonesty & Misrepresentation. . . .... 7 2.7 Conflict of Interest & Outside Employment . . .. 7
2.14 Religious Accommodation . . . . . . . ........ 11 2.15 Political Neutrality. . . . . . . . . . . ............ 11 2.16 Internet, Email, & Computer Use. . . . . ...... 11 SocialMedia............................ 12 Employee Rights & Responsibilities.. . . . . . . . . . 12 Guidelines When Engaging in Social Media. . . . 12 Security................................ 13 UseWhileDriving......................... 14 2.17 Cell Phone . . . . . . . . . . . . . . .............. 14 Personal Electronic Devices.. . . . . . . . . . . . . . . . 14 2.18 Expense Reimbursement. . . . . . . . ......... 15 2.19 Use of Company Equipment/Postage . . . .... 15 Use of Company Equipment/Phones . . . . . . . . . 15 2.20 Gifts. . . . . . . . . . . . . . . . . ................. 16 GiftsfromCustomers...................... 16 GiftstoEmployees........................ 16 Charitable Contributions in Lieu of Gifts . . . . . . . 16 Business Entertainment & Meals.. . . . . . . . . . . . 16 ProductsfromInventory.. . . . . . . . . . . . . . . . . . . 16 ExceptionstoPolicy....................... 16 2.21 Bulletin Boards. . . . . . . . . . . . ............. 16 SECTION 3 Hours of Work and Payroll Practices.. . . . . . . 17 3.1 Pay Periods & Paydays. . . . . . . . . . .......... 18 3.2 Overtime. . . . . . . . . . . . . . . ................ 18 3.3 Rest & Meal Periods. . . . . . . . . . . ........... 18 3.4 Time Cards . . . . . . . . . . . . . . .............. 18 Timekeeping. . . . . . . . . . . . . . . . . . . . . . . . . . . . .18 RecordKeeping.......................... 18 3.5 Payroll Deductions. . . . . . . . . . . ............ 19 3.6 Wage Garnishment. . . . . . . . . . . ............ 19 3.7 Direct Deposit. . . . . . . . . . . . . .............. 19 3.8 Rehire, Layoffs, & Recalls. . . . . . . . . ......... 19 Rehire.................................. 19 Layoffs&Recalls......................... 19 3.9 Resignation. . . . . . . . . . . . . . ............... 20 Procedure for Resignation.. . . . . . . . . . . . . . . . . 20 3.10 Dismissal. . . . . . . . . . . . . . . ............... 20 3.11 Post-Resignation & Termination. . . . . . ...... 20
General................................ 7 Outside Employment .. . . . . . . . . . . . . . . . . . . . . 8 Work Product/Patent Ownership. . . . . . . . . . . . . 8 Reporting Potential Conflicts. . . . . . . . . . . . . . . . 8
2.8 Confidentiality . . . . . . . . . . . . . ............. 9 2.9 Employment of Minors . . . . . . . . . . .......... 9 2.10 Employment of Relatives . . . . . . . . ......... 9 2.11 Personnel Records & Verification of Employment . . . . . . . ........ 10 2.12 Privacy . . . . . . . . . . . . . . . ................ 10 2.13 Immigration Law Compliance. . . . . . . ....... 10
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SECTION 4 Standards of Conduct & Employee Performance .. . 21 4.1 Anti-Harassment & Discrimination. . . . . ...... 22 Non-Discrimination........................ 22 Harassment, Including Sexual Harassment.. . . . 22 Definitions of Harassment.. . . . . . . . . . . . . . . . . 23 Important Notice to All Employees.. . . . . . . . . . . 24 ProhibitedConduct....................... 24 ComplaintProcedure...................... 25 Reporting & Investigation Procedures. . . . . . . . . 25 Confidentiality. . . . . . . . . . . . . . . . . . . . . . . . . . . .25 Discipline............................... 25 Retaliation.............................. 25 WorkplaceMonitoring.. . . . . . . . . . . . . . . . . . . . 25 4.2 Attendance. . . . . . . . . . . . . . ............... 26 Deficiency Point System for Nonexempt Hourly Employees .. . . . . . . . . . . . . 26 4.3 Inclement Weather/ Emergency Closings. . ... 28 4.4 Standards of Professionalism . . . . . . . ....... 29 4.5 Dress Code. . . . . . . . . . . . . . ............... 29 Office.................................. 29 CasualFridays........................... 30 Warehouse/Factory Personnel.. . . . . . . . . . . . . . 30 4.6 Employee Badges. . . . . . . . . . . . ............ 30 Facilities with a Badge System . . . . . . . . . . . . . . 30 4.7 Visitors in the Workplace. . . . . . . . . ......... 30 4.8 Parking. . . . . . . . . . . . . . . . ................ 31 4.9 Workplace Behavior, Conduct & Discipline. . .. 31 Standards of Conduct and Discipline .. . . . . . . . 31 Progressive Disciplinary Action. . . . . . . . . . . . . . 32 Performance Improvement.. . . . . . . . . . . . . . . . . 32 4.10 Workplace Violence. . . . . . . . . . ........... 33 4.11 Workplace Searches. . . . . . . . . . .......... 33 4.12 Safety . . . . . . . . . . . . . . . . ................ 34 EmployeeSafety......................... 34 Emergency Medical Treatment.. . . . . . . . . . . . . . 35 Hazard Communications Program.. . . . . . . . . . . 35 MiscellaneousTools....................... 35 Personal Protective Equipment . . . . . . . . . . . . . . 35 FireProcedures.......................... 35 Off-Duty Social & Recreational Activities. . . . . . . 36 4.13 Injuries . . . . . . . . . . . . . . . ................ 36 Health-RelatedIssues.. . . . . . . . . . . . . . . . . . . . 36 Employee Requiring Medical Attention . . . . . . . . 36 4.14 Return to Work after Serious Injury or Illness. . . 36 4.15 Substance and Abuse. . . . . . . . . .......... 37 ProhibitedBehavior....................... 37 Medically Authorized (Prescription) Medications, Over-the-Counter Medications & Alcohol.. . . . . . 38 Drug&AlcoholTesting.. . . . . . . . . . . . . . . . . . . 38 Applicants for Employment . . . . . . . . . . . . . . . . . 38 Random................................ 38 Suspicion............................... 38 PostAccidents.......................... 39 TestingProcedures....................... 39 Penalties for Violating Policy . . . . . . . . . . . . . . . . 39 4.16 Tobacco Products . . . . . . . . . . . ........... 40 4.17 Suggestion Program. . . . . . . . . . ........... 40 4.18 Internal Complaint Resolution Procedure. . .. 40 4.19 Employee of the Month . . . . . . . . . ......... 40 4.20 Performance Evaluations. . . . . . . . ......... 40
SECTION 5 Employee Benefits & Services . . . . . . . . . . . . 41 5.1 General. . . . . . . . . . . . . . . . ................ 42 5.2 Group Health Insurance. . . . . . . . . .......... 42 HealthInsurance......................... 42 5.3 Supplementary Insurance . . . . . . . . ......... 42 Supplimental Insurance.. . . . . . . . . . . . . . . . . . . 42 5.4 401(k) Plan. . . . . . . . . . . . . . ............... 42 5.5 COBRA . . . . . . . . . . . . . . . ................ 43 CobraBenefits........................... 43 5.6 Worker's Compensation . . . . . . . . . ......... 43 5.7 Social Security Benefits (FICA). . . . . . ....... 44 Social Security/Medicare.. . . . . . . . . . . . . . . . . . 44 5.8 Unemployment Insurance. . . . . . . . . ......... 44 SECTION 6 Employee Leaves of Absence and Time Off . . 45 6.1 General. . . . . . . . . . . . . . . . ................ 46 6.2 Paid Time Off . . . . . . . . . . . . . .............. 46 Accrual&Allocation....................... 46 Salaried Exempt/Salaried Nonexempt Pro-Rated PTO.. . . . . . . . . . . . . . . . 47 Hourly Non-Exempt Pro-Rated PTO.. . . . . . . . . . 47 6.3 Holidays . . . . . . . . . . . . . . . ................ 47 Midwest Fastener Corp. observes the following paid holidays.. . . . . . . . . . . . . . . . . 47 The exceptions to this policy include.. . . . . . . . . 48 The following criteria are used in determining holiday pay.. . . . . . . . . . . . . . . . . 48 6.4 Pregnancy-Disability Leave . . . . . . . . ........ 48 6.5 Family and Medical Leave. . . . . . . . ......... 49 Job Benefits and Protection.. . . . . . . . . . . . . . . . 49 Unlawful Acts by Employers.. . . . . . . . . . . . . . . . 49 Enforcement............................. 49 For Additional Information. . . . . . . . . . . . . . . . . . 49 6.6 Workers' Compensation Leave . . . . . . ....... 49 6.7 Bereavement Leave . . . . . . . . . . . ........... 49 Immediate Family Includes . . . . . . . . . . . . . . . . . 49 6.8 Jury Duty. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 6.9 Military Leave USERRA. . . . . . . . . .......... 50 6.10 Military Family Leave . . . . . . . . . . .......... 50
GUIDINGPRINCIPLES.................... 51
At-Will Employment Agreement & Acknowledgment of Receipt ofEmployeeHandbook.. . . . . . . . . . . . . . . . . 52
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Section 1
INTRODUCTION
1.1 Welcome to Midwest Fastener Corp. We’re thrilled to have you as part of our team. At Midwest, we believe in fostering a culture of innovation, collaboration, and excellence. Our mission is to Exceed Expectations – One Hardware Destination at a time, and every team member plays a crucial role in making that vision a reality. This handbook is designed to guide you through our Company values, policies, and expectations, ensuring you have everything you need to thrive in your role. We encourage
open communication, continuous learning, and a strong sense of teamwork. Welcome aboard—we’re excited to embark on this journey together!
1.2 Employee Handbook The Employee Handbook serves as a
1.3 Changes in Policy The Company expressly reserves the right to revise, modify, delete, or add to any policies, procedures, work rules, or benefits stated in this handbook or in any other document, except for the policy of at-will employment as described below. Nothing in this employee handbook or any other document, including benefit plan descriptions, creates or is intended to create a promise or representation of continued employment for any employee. Any changes to your at-will employment status, described below, must be in writing and must be signed by the Company. For all other changes to Company policies, notification will be in digital or written form. No oral statements or representations can in any way alter the provisions of this Handbook. Changes will be effective on dates determined by Midwest Fastener Corp," and you may not rely on policies that have been superseded.
comprehensive guide to Midwest’s policies, expectations, and workplace culture. It is designed to provide employees with essential information regarding Company values, code of conduct, benefits, procedures, and rights. This handbook is a valuable resource to help you navigate your journey with Midwest, ensuring clarity on workplace standards and fostering a positive and productive environment. While it outlines important guidelines, it is not an exhaustive contract but rather a reference for mutual understanding and success within the organization. This handbook supersedes all previous employment policies, written or oral, expressed or implied. The Company reserves the right to interpret the policies in this Handbook and to deviate from them when, at its discretion, it determines it is appropriate. For any questions or clarifications, employees are encouraged to reach out to their manager or the Human Resources Department.
If you are uncertain about any policy or procedure, please check with your manager or Human Resources.
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1.4 Employment-At-Will Employment with the Company is on an at-will basis unless otherwise specified in a written employment agreement. You are free to resign at any time, for any reason, with or without notice. Similarly, the Company is free to conclude the employment relationship at any time for any lawful reason, with or without cause, and with or without notice. Nothing in this Handbook will limit the right of either party to terminate an at-will employment. No section of this Handbook is meant to be construed, nor should it be construed, as establishing anything other than an employment-at-will relationship. This Handbook does not limit management's discretion to make personnel decisions such as reassignment, change of wages and benefits, demotion, etc. No person other than the President has the authority to enter into an agreement for employment for any specified period of time or to make an agreement for employment other than at-will terms. Only the President of the Company has the authority to make any such agreement, which is only binding if it is in writing and signed by the President of the Company. 1.5 Arbitration Policy In consideration of your employment with Midwest Fastener Corp., its promise to arbitrate all employment-related disputes, and your receipt of the compensation, pay raises, and other benefits paid to you by the Company, at present and in the future, you agree that any and all controversies, claims, or disputes with anyone (including the Company and any employee, officer, director, or benefit plan of the Company, in their capacity as such or otherwise), whether brought on an individual, group, or class basis, arising out of, relating to, or resulting from your employment with Midwest Fastener Corp. or the termination of your employment with the Company, including any breach of this agreement, shall be subject to binding arbitration under the terms and
conditions set forth in the at-will employment, confidential information, invention assignment, and arbitration agreement between you and Midwest Fastener Corp. (or such other confidentiality agreement between you and the Company, each the "confidentiality agreement"). In the event the confidentiality agreement between you and Midwest Fastener Corp. does not contain an arbitration provision, then you nevertheless agree to arbitrate any and all claims set forth above in a neutral, mutually agreeable forum according to the applicable minimum standards for arbitration. 1.6 Employment Applications Midwest Fastener Corp. relies upon the accuracy of information contained in the employment application and the accuracy of other data presented throughout the hiring process and employment. Any misrepresentations, falsifications, or material omissions in any of this information or data may result in the exclusion of the individual from further consideration for employment or, if the person has been hired, termination of employment. 1.7 Employment Reference Checks To ensure individuals who join Midwest Fastener Corp. are well qualified and have a strong potential to be productive and successful, it is the policy of Midwest Fastener Corp. to check the employment references of all applicants. Human Resources will respond in writing only to those reference check inquiries that are submitted in writing to Midwest Fastener Corp. Responses to such inquiries will confirm only dates of employment, wage rates, and position(s) held. No employment data will be released without a written authorization and release signed by the individual who is the subject of inquiry. Temporary agency employees must contact the agency for reference checks.
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EMPLOYMENT POLICIES Section 2
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2.1 Employee Classifications The following terms are used to describe employees and their employment status: Exempt Employees An exempt employee is a classification under the Fair Labor Standards Act (FLSA) that refers to employees who are not entitled to overtime pay regardless of the number of hours worked beyond the standard 40-hour workweek. Exempt employees are typically salaried and must meet specific criteria related to job duties, salary level, and salary basis.
Non-exempt Hourly/Regular Employee Employees who are hired to work on a regular schedule. Such employees can be either full-time or part-time. The distinction between full-time and part-time depends upon the number of hours that an employee works. Full-Time Employees who are not temporary employees, independent contractors, or independent consultants, and who are regularly scheduled to work a schedule of 37.5 hours per work week. These employees generally have a predictable and structured schedule. They also may qualify for Company-sponsored benefits. Part-Time Employees who are not temporary employees, independent contractors, or independent consultants and who are regularly scheduled to work less than 37.5 hours per work week but a minimum of 20 hours per week. Regular Part-Time employees, including seasonal employees, are eligible for limited benefits from Midwest Fastener Corp. The benefits include 401(K), paid time off (PTO), and unpaid personal time (UTO). Temporary Employees Employees who are hired as interim replacements to supplement the workforce or to assist in the completion of a specific project. Employment assignments in this category are of limited duration, and the temporary employee can be let go before the end of the defined period. Short-term assignments are periods of six (6) months or less, however, such assignments may be extended. All temporary employees are at-will, regardless of the anticipated duration of the assignment (see Employment-at-Will Policy). Temporary employees retain that status unless and until notified in writing of a change.
To qualify as exempt, an employee must generally
• Be paid on a salary basis rather than hourly. • Earn a minimum salary that meets or exceeds the FLSA threshold. • Perform executive, administrative, professional, computer, or outside sales job duties as defined by federal regulations.
Because exempt employees do not receive overtime compensation, they are expected to complete their job responsibilities regardless of the time required. Nonexempt Employees Employees whose positions do not meet specific tests established by the FLSA and state law. All employees who are covered by the federal or state minimum wage and overtime laws are considered nonexempt. Employees working in nonexempt jobs are entitled to be paid at least the minimum wage per hour and a premium for overtime. Non-exempt Salaried/Regular Employee Employees who receive overtime pay in accordance with Company overtime policy. In addition to their standard salary, their wage will include a calculated
hourly overtime rate benefit for any additional hours over 40 per week.
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MWF LC#250401
2.3 Introductory Period The introductory period at Midwest Fastener Corp. typically lasts for the first 90 calendar days after hire, allowing new or rehired employees to demonstrate their performance and assess fit. During this time, either the employee or the company can end the employment relationship at will, with or without cause or notice. This period is used to evaluate employees’ capabilities, work habits, and overall performance. Significant absences will extend the introductory period, to allow for more evaluation time. Employees promoted or transferred within the company must complete a secondary introductory period of the same length. If an employee is not successful in the new position, they may return to their former or a comparable job, depending on availability and company needs. Upon satisfactory completion of the initial period, employees working 40 hours per week will be considered full-time. The at-will employment status remains unaffected, meaning termination can occur at any time. During the introductory period, employees are eligible for legally required benefits and may also qualify
Independent Contractor or Consultant These individuals are not employees of the Company and are self-employed. An independent contractor or consultant is engaged to perform a task according to their own methods and is subject to control and direction only as to the results to be accomplished. Independent contractors or consultants are not entitled to benefits. Each employee will be advised of their status at the time of hire and any change in status. Regardless of the employee's status, the employee is employed at-will, and the employment relationship can be terminated by the Company or the employee at any time, with or without cause. *New York, New Jersey, and Michigan Part- Time, Seasonal, and Temporary employees are eligible for paid sick time. **Seasonal Employees are excluded from paid time off unless state/local laws require. *All employees with average credited hours of 30 or above are eligible for healthcare insurance 2.2 Definition of Credited Hours Credited hours are defined as the actual time an employee is paid for work at Midwest Fastener Corp., as well as the time an employee is not working for the following reasons: • Scheduled paid time off and unpaid time off (PTO, UTO) • Midwest Fastener Corp. recognized holidays (Hol, Unpaid Holiday) • Jury Duty; as required by state and federal law (JD) • Funeral days: up to three days for immediate family (BRV) • Work Shortage (WS) • FMLA (FML) • Workers’ Compensation (WCO, WCI, WCP) • Planned shutdown; up to 2 weeks • Short term layoff; up to 2 weeks
for other company-provided benefits, subject to specific program terms.
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2.4 Equal Employment
that employees with life-threatening illnesses, including but not limited to cancer, heart disease, and AIDS, may wish to continue engaging in as many of their normal pursuits as their condition allows, including work. If these employees are able to meet acceptable performance standards, with or without reasonable accommodation, and medical evidence indicates that their work does not present a substantial threat to themselves or others, they will be permitted to do so. 2.5 Criminal Background Checks & Drug Screens As a condition of employment, all candidates will be required to submit to a criminal background check as well as a drug screen before employment. Although a disqualification is possible, in accordance with federal and state laws, a previous conviction does not automatically disqualify you from consideration for employment with Midwest Fastener Corp. Depending on a variety of factors (i.e., the nature of the position, the nature of the conviction, age of the candidate when the illegal activity occurred), the candidate may still be eligible for employment with Midwest Fastener Corp. However, if a candidate attempts to withhold information or falsify information pertaining to previous convictions, the candidate will be disqualified from further employment consideration in any position with Midwest Fastener Corp. due to falsification of an application. A positive result on a drug screen after going through the Medical Review process will result in the disqualification of the candidate from the position offered. A contingent offer of employment may be extended to a candidate prior to the completion of the criminal background check and drug screen. However, the satisfactory completion of the criminal background check, drug screen,
Opportunity & Americans with Disabilities Act It is the policy of the Company to provide equal employment opportunities to all employees and employment applicants without regard to unlawful considerations of race, religion, creed, color, national origin, sex, sexual orientation, gender identity, age, ancestry, physical or mental disability, medical condition including medical characteristics, marital status or any other classification protected by applicable local, state or federal laws. This policy prohibits unlawful discrimination based on the perception that anyone has any of those characteristics or is associated with a person who has or is perceived as having any of those characteristics. This policy applies to all aspects of employment, including, but not limited to, hiring, job assignment, working conditions, compensation, promotion, benefits, scheduling, training, discipline, and termination. Reasonable accommodation is available for qualified individuals with disabilities upon request. The Company expects all employees to support our equal employment opportunity policy and to take all steps necessary to maintain a workplace free from unlawful discrimination and harassment. In compliance with the Americans with Disabilities Act (ADA), the Company provides accommodation to the disabled to the full extent required by law. The Company may require medical certification of both the disability and the need for accommodation. The Company can only seek to accommodate the known physical or mental limitations of an otherwise qualified disabled individual. Therefore, it is your responsibility to come forward if you need accommodation. The Company will engage in an interactive process with the employee to identify possible accommodation, if any, that will help the applicant or employee perform the job. Midwest Fastener Corp. further recognizes
and reference check must be complete upon the candidate’s first day of work.
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2.7 Conflict of Interest & Outside Employment General
Background and reference checks may include verification of any information on the applicant’s resume or application form. All background checks are conducted in conformity with the Federal Fair Credit Reporting Act, the Americans with Disabilities Act, and state and federal privacy and antidiscrimination laws. Reports are kept confidential and are only viewed by individuals involved in the hiring process. Additional checks such as a driving record or credit report may be made on applicants for particular job categories if appropriate and job related.
Midwest Fastener Corp. expects its employees to conduct business according to the highest ethical standards of conduct. Employees are expected to devote their best efforts to the interests of the Company. Business dealings appearing to create a conflict between the interests of the Company and an employee are unacceptable. The Company recognizes the right of employees to engage in activities outside of their employment that are of a private nature and unrelated to the business. However, the employee must disclose any possible conflicts so that the Company may assess and prevent potential conflicts of interest from arising. A potential or actual conflict of interest occurs whenever an employee can influence a decision that may result in personal gain for the employee or an immediate family member (i.e., spouse or significant other, children, parents, siblings) as a result of the Company’s business dealings. Employees must refrain from any activity or have a financial interest inconsistent with the Company’s best interest and from activities, investments, or associations that compete with the Company or interfere with one’s judgment concerning the Company’s best interest. Although it is not possible to specify every action that might create a conflict of interest, this policy sets forth the ones that most frequently present problems. If an employee has any question whether an action or proposed course of conduct would create a conflict of interest, they should immediately contact the Human Resources Department to obtain advice on the issue before engaging in any such activity. The purpose of this policy is to protect employees from any conflict of interest that may arise. Nothing in this policy is intended to or shall be construed to prohibit employees from engaging in lawful, concerted protected activity within the meaning of the National Labor Relations Act. A violation of this policy will result in
2.6 Fraud, Dishonesty & Misrepresentation
No employee or candidate may ever falsify any application, medical history record, paperwork, investigative questionnaires, or any other document. Any employee found to have engaged in resume fraud or who made material representations or omissions on any Company documents will be subject to disciplinary action, including immediate termination of employment. If you observe any such violations, please report them to your supervisor or the Human Resources Department.
immediate and appropriate discipline up to and including immediate termination.
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Outside Employment Employees are permitted to engage in outside work or to hold other jobs, subject to certain restrictions as outlined below.
Work Product/Patent Ownership All Midwest Fastener Corp. employees must be aware that the Company retains ownership of the product of their work. No work product or patents issued while employed by Midwest Fastener Corp. can be claimed, construed, or presented as property of the individual, even after employment by Midwest Fastener Corp. has been terminated or the relevant project completed. This includes written and electronic documents, audio and video recordings, system code, and any concepts, ideas, or other intellectual property developed for Midwest Fastener Corp., regardless of whether the intellectual property is used by Midwest Fastener Corp. Although it is acceptable for an employee to display and/or discuss a portion or the whole of a certain work product/patent as an example in certain situations (e.g., on a resume, in a freelancer’s meeting with a prospective client), one must bear in mind the information classified as confidential must remain so even after the end of employment, and supplying certain other entities with certain types of information may constitute a conflict of interest. Reporting Potential Conflicts An employee must promptly disclose actual or potential conflicts of interest, in writing, to the Human Resources Department. Approval of a waiver of a conflict of interest will not be given unless the relationship will not interfere with the employee’s duties and will not adversely affect the Company, in the Company’s sole judgment.
Outside work activities are not allowed when they
• Pevent the employee from fully performing work for which they are employed at the Company, including overtime assignments. • Involve organizations doing or seeking to do business with the
Company, including actual or potential vendors or customers. • Involve the performance of any services for customers on nonworking time that are normally performed by the Company (such prohibition extends to the unauthorized use of any of the Company’s tools, equipment and/or confidential information); or • Violate provisions of law or the Company’s policies or rules. Midwest Fastener Corp. employees may be required to work beyond their normally scheduled hours. Employees must perform this work when requested. In cases of conflict with any outside activity, the employee’s obligations to the Company must be given priority. Employees are hired and continue in Midwest Fastener Corp.’s employment with the understanding that Midwest Fastener Corp. is their primary employer and that other employment or commercial involvement that conflicts with the business interests of Midwest Fastener Corp. is strictly prohibited. Employees are cautioned to carefully consider the demands that additional work activity will create before accepting outside employment. Outside employment will not be considered an excuse for poor job performance, absenteeism, tardiness, leaving early, refusal to travel or refusal to work overtime or different hours. If the Company determines that an employee’s outside work interferes with performance, the employee may be asked to terminate the outside employment.
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2.8 Confidentiality All Midwest Fastener Corp. records, documents and information related to Midwest Fastener Corp. and its customers, suppliers, products, intellectual property, business, services, activities, technology, operations, strategies, programs, systems, inventions, formulas, computer programs, databases, software, forecasts, pricing, marketing, sales, financial information, drawings, prototypes, test data and other proprietary records, documents and information that are not otherwise available to persons or firms outside the Company are considered confidential and employees must, therefore, refrain from misuse of unauthorized disclosure of such confidential information. No Midwest Fastener Corp. confidential information may be removed from Midwest Fastener Corp.’s premises without permission from the Company. Additionally, the contents of Midwest Fastener Corp.’s confidential information may not be disclosed to anyone except where required for a business purpose. Employees who are unsure about the confidential nature of specific information must ask their supervisor for clarification. Employees will be subject to appropriate disciplinary action, up to and including termination, for knowingly or unknowingly revealing information of a confidential nature.
2.9 Employment of Minors The Company strictly adheres to the FLSA regarding the employment of minors. The FLSA sets the minimum age for employment (14 years for non-agricultural jobs), restricts the hours youth under the age of 16 may work, and prohibits youth under the age of 18 from being employed in hazardous occupations. In addition, the FLSA establishes subminimum wage standards for certain employees who are less than 20 years of age, full-time students, student learners, apprentices, and workers with disabilities. Employers must have authorization from the U.S. Department of Labor's Wage and Hour Division (WHD) to pay sub-minimum wage rates. The FLSA's child labor provisions are designed to protect the educational opportunities of youth and prohibit their employment in jobs that are detrimental to their health and safety. 2.10 Employment of Relatives The Company recognizes the employment of relatives in certain circumstances, such as when they will work in the same department, supervise or manage the other, or have access to confidential or sensitive information regarding the other, can cause problems related to supervision, safety, security or morale, or create conflicts of interest that materially and substantially disrupt the Company's operations. When the Company determines any of these problems may be present, it will assess on an individual basis/circumstance prior to extending an offer or hiring an individual to work in the same department as an existing employee. Relatives subject to this policy include father, mother, sister, brother, current spouse or domestic partner, child (natural, foster, or adopted), current mother-in-law, current father-in-law, grandparent, or grandchild. If present employees become relatives during employment, the Company should be notified so Midwest Fastener Corp. may determine whether a problem involving supervision, safety,
As a condition of employment with the Company, all employees must sign a Non-Disclosure Agreement.
Nothing in this policy is intended to or shall be construed to prohibit employees from engaging in lawful, concerted protected activity within the meaning of the National Labor Relations Act.
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2.12 Privacy The Company is respectful of employee privacy. All work areas on Company property (including an employee’s desk, computer system, appointment calendar, computer disks, employee’s files, etc.) remain fully accessible by the Company. As such, any area is subject to inspection from time to time. All employee demographic and personal information will be shared only as required in the normal course of business. Healthcare enrollment information is kept in a separate folder from other human resources forms. Workers' Compensation information is not considered private healthcare information; however, this information will be released only on a need-to-know basis. The Company does not make or receive any private healthcare information through the course of normal work. If any employee voluntarily shares private healthcare information with a member of management, this information will be kept confidential. If applicable, the Company will set up guidelines for employees and management to follow to ensure that Company employees conform to the requirements of the Health Insurance Portability and Accountability Act (HIPAA). 2.13 Immigration Law Compliance In compliance with the Immigration Reform and Control Act of 1986, each new employee, as a condition of employment, must complete the Employment Eligibility Verification Form I-9 on day one of employment and present documentation establishing identity and employment eligibility within three business days of the employee’s first day of employment. Former employees who are rehired must also complete an I-9 form if they have not completed an I-9 form with the Company within the past three years, or if their previous I-9 form is no longer retained or valid. You may raise questions or complaints about immigration law compliance without fear of reprisal.
security, or morale, or a conflict of interest would materially and substantially disrupt the Company's operations. If the Company determines such a problem exists, the Company will take appropriate steps to resolve the problem, which may include the reassignment of one relative (if feasible) or asking for the resignation of one of the employees. Verification of Employment The Company maintains a personnel file and payroll records for each employee as required by law. Personnel files and payroll records are the property of the Company and may not be removed from Company premises without written authorization. Because personnel files and payroll records are confidential, access to the records is restricted. Only those who have a legitimate reason to review information in an employee's file are allowed to do so. Disclosure of personnel information to outside sources will be limited. However, the Company will cooperate with requests from authorized law enforcement or local, state, or federal agencies conducting official investigations and as otherwise legally required. Employees may contact a Human Resources representative to request time to review their 2.11 Personnel Records & payroll records and/or personnel files. With reasonable advance notice, an employee may review their records in the Company's offices during regular business hours and in the presence of an individual appointed by the Company to maintain the records. Employees also have the right to obtain a copy of their personnel files, after paying the nominal fees required for any such copies. You may add your comments to any disputed item in the file. By policy, the Company will provide only the former or present employee's dates of employment and position(s) held with the Company and eligibility for rehire, if asked. Compensation information may also be verified if written authorization is provided by the employee.
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2.14 Religious Accommodation The Company will make reasonable accommodations for employees' observance of religious holidays and practices unless the accommodation causes undue hardship on the Company's operations. If you desire religious accommodation, you are required to request it in writing to your manager as far in advance as possible. 2.15 Political Neutrality The maintenance of individual freedom and our political institutions necessitates broad-scale participation by citizens concerning the selection, nomination, and election of our public officeholders. The Company will not discriminate against any employee because of identification with and support of any lawful political activity. The Company will not discriminate against employees based on their lawful political activity engaged in outside of work. If you are engaging in political activity, however, you should always make it clear that your actions and opinions are your own and not those of the Company and that you are not representing the Company. 2.16 Internet, Email, & Computer Use Successful business operations demand the security of Company information, systems, and intellectual property, and they are dependent on each employee’s good judgment and exercise of common sense, work ethics, and professional conduct. Midwest Fastener Corp.’s various online systems (internal network, email, internet, and other online services, systems, or resources) are vital business resources in providing efficient communication and information exchange. The expectation is that easy access to information assists the achievement of work-related goals and objectives.
Midwest Fastener Corp.’s employees are expected to spend their work time and the use of Midwest Fastener Corp.’s property and resources in pursuit of legitimate Company business interests. Midwest Fastener Corp. strictly prohibits the viewing, posting, downloading, printing, or distribution of any illegal information, or material it deems obscene, profane, abusive, or otherwise offensive. This policy includes any such activity occurring on Company property, at any Company-sponsored or business-related event/activity, or using any Company computer system, equipment, or property. Forgery or tampering with Midwest Fastener Corp. online systems is also a violation of Company policy. Examples include • Intentionally impersonating someone else and/or misrepresenting yourself. • Modifying a message and forwarding it without noting changes (i.e., deletions, removal of recipients, content modifications, etc.) • Fabricating a message mechanisms of the email system in a malicious or unauthorized manner. This policy extends to Midwest Fastener Corp.’s corporate network, related online systems and interconnections to other networks and information systems of which Midwest Fastener Corp. has management and control. All and/or sender of a message. • Bypassing the user-security protection standards are equally applicable to digital data, hard copy, video images and sound generated from the physical resources of the network. The corporate network, all its components and contents, as well as any other data stored on or transmitted by Midwest Fastener Corp. equipment, are the property of Midwest Fastener Corp.
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Social Media Social media includes any form of electronic communication where individuals can share information, messages, ideas, and content. Examples are Facebook, Twitter, LinkedIn, comments made on/into blog sites and news articles online, etc. Due to the public-facing nature of these types of communication vehicles, social media use may create potential risks to Midwest Fastener Corp.’s legitimate business interests. Most of these risks can be avoided by exercising common sense and by following the guidelines below. It is the duty of the employee to know their rights and responsibilities, as described below, before using social media. Employee Rights & Responsibilities 1. Employees are responsible for their personal communications using social media outlets. Midwest Fastener Corp. will not be responsible for or liable for any content, errors, omissions, losses, or damage claims incurred because of an employee’s personal communications. Midwest Fastener Corp. networks deny access to social media outlets (unless authorized by management). 2. Employees are not authorized to post content on behalf of Midwest Fastener Corp. (i.e., identifying themselves as someone who is speaking for the Company), without seeking and obtaining prior written approval from the Company. 3. Nothing in this policy should be read to prohibit employees from exercising their rights under the National Labor Relations Act or similar local regulations. 4. Employees are solely responsible for what they post online. Before creating
Guidelines When Engaging in Social Media 1. Follow Midwest Fastener Corp.’s Code of Conduct and all applicable policies and laws. All employees are subject to the Code of Conduct and are responsible for upholding Midwest Fastener Corp.’s reputation for the integrity of its products in all online activities, whether internal or external. 2. Avoid posting statements that reasonably could be viewed as malicious, obscene, threatening, or intimidating, that disparage other people, or that might constitute harassment or bullying. Examples of such conduct might include offensive posts meant to intentionally harm someone’s reputation or posts contributing to a hostile work environment based on race, sex, disability, religion or any other status protected by law or Company policy. 3. Personal social media activities should not interfere with Midwest Fastener Corp.’s work responsibilities and should not be conducted using your Midwest Fastener Corp. email account. 4. Prior management approval is required for the following: • Responding to a business or consumer post or communication regarding Midwest Fastener Corp. products. • Downloading or installing software or other files from social media sites on Midwest Fastener Corp.’s equipment or networks. • Reposting information from other sites. 5. Midwest Fastener Corp.’s protection, as well as the protection of the employee(s), it is critical to show proper respect for the laws governing copyright, fair use of copyrighted material owned by others, trademarks and other intellectual property, including Midwest Fastener Corp.’s own logos, tagline, copyrights, trademarks and other intellectual property.
online content, consider some of the risks and rewards involved.
If there are questions about the proper use of Midwest Fastener’s intellectual property, contact management.
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6. Employees are not authorized to act on behalf of Midwest Fastener Corp. without prior approval, make sure to indicate in any Midwest Fastener Corp.-related post the views expressed are personal views and not those of Midwest Fastener Corp. 7. Midwest Fastener Corp. employees should avoid making claims or personal testimonials about the Company’s products or competitors’ products. Employees should immediately report any allegations of adverse effects involving Midwest Fastener Corp. products once they become aware of allegations to human resources and/or management. 8. Do not discuss or disclose legal proceedings associated with Midwest Fastener Corp.’s products and business lines, attorney-client privileged information, the Company’s trade secrets, or any other Company confidential or proprietary information. 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. Respect financial disclosure laws and do not disclose Company financial information or provide information that may constitute insider trading. Also, do not use Midwest Fastener Corp.'s assigned username and password for an external social media site. 9. Managers and executives of Midwest Fastener Corp. are prohibited from posting reference information (positive or negative) on current or former employees. Managers and executives must take special care when posting to social media sites (i.e., a reference on LinkedIn) related to current or former employees since, due to the nature of their positions, personal postings may be interpreted as the views and options of Midwest Fastener Corp., even when disclaimer language is used.
Subject to applicable laws and regulations, Midwest Fastener Corp. retains the right to monitor all files and messages stored on and transmitted through a Midwest Fastener Corp. computer or any other Company-owned/licensed electronic devices or networks. Employees have no reasonable expectation of privacy on social media accessed through a Midwest Fastener Corp. computer or other Company-owned/ licensed electronic device or network, even if you use a personal social media account. If an employee has any questions or concerns regarding these guidelines, please reach out to your supervisor, management, or human resources. If an employee believes these guidelines have been violated, are being violated, or may be violated, promptly advise • Your supervisor, management, or human resources. • An employee may also submit an anonymous report using the suggestion box. Security Employees using home or mobile devices and related software for network and data access will, without exception, use secure data management procedures. A strong password must protect all devices, and all data stored on the device must be encrypted. Employees agree to never disclose their passwords to anyone, including family members, when business work is conducted from home.
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2.17 Cell Phone The use of personal cell phones at work is discouraged because it can interfere with work and be disruptive to others. Employees who bring personal cell phones to work are required to keep the ringer shut off or on vibrate mode when they are working and to keep cell phone use confined to breaks and meal periods. Conversations should be had away from areas where other employees are working. When cell phone use interferes with the satisfactory performance of an employee's duties or disturbs others, the privilege of using a personal cell phone at work may be removed, and other disciplinary action, up to and including termination, may be imposed. The Company may provide cell phone allowances to employees in certain positions to improve efficiency and effectiveness. When cell phones are used for Company business, employees must comply with all Company policies governing conduct, including our policies prohibiting discrimination, harassment, and violence in the workplace. When using the cell phone in a public place, please remember to maintain the confidentiality of any private or confidential business information. As a courtesy to others, please shut cell phones off or place them on vibrate mode during meetings. Personal Electronic Devices The use of cell phones or any electronic device is restricted to break and lunch periods unless otherwise approved by management.
Use While Driving It is the responsibility of the employee to understand and obey all local, state, and federal laws about the use of any mobile device while driving a vehicle. Additionally, employees using Company devices are forbidden from sending text or email messages while driving. Employees whose job responsibilities include regular or occasional driving and who are issued a Company mobile phone are expected to refrain from using their phone whenever possible while driving. Employees are encouraged to pull off to the side of the road and stop their vehicle before placing or accepting a call. In situations where job responsibilities include regular driving and accepting business calls, hands-free equipment must be used. All employees are advised that the Company may access any such data as needed without further notice. Accordingly, the privacy of email, voicemail, voice email, and similar data should not be presumed. Employees’ use of the network and access to its contents are authorized for legitimate business purposes only. It is the responsibility of all authorized users to ensure the information and/or data that they create or that is entrusted to their care is protected using any physical and logical security controls that are provided, authorized, and supported by the Company. In addition, all authorized users of the Midwest Fastener Corp. corporate network are responsible for protecting the information it contains from unauthorized disclosure, destruction, alteration or modification. Violations of the above policy are subject to immediate suspension of the user’s account, disciplinary action, up to and including termination and/or legal action. Please see the Internet, Email, and Computer Use Policy for full policy details.
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