MWF Employee Handbook

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. 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.

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. 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.

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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