POLICIES
Inclement Weather Policy When the Company is open for business, Team Members are expected to report as scheduled. Any absence will require that PTO be used. If there is no unused accrued PTO, the Team Member will not be paid. If a dealership or other facility is closed due to inclement weather, the facility will communicate whether Team Members will need to use PTO time in order to be paid. Team Members should call their Manager before their scheduled time to report to work to determine if their location will be closed due to inclement weather. Insider Trading Policy Team Members are subject to the Company’s Insider Trading Policy. Under this Policy, Team Members are prohibited from trading in Asbury securities if aware of material, non-public information. Information is considered “material” if it could affect the price of the Asbury stock; information is deemed “non-public” if Asbury has not announced it in a press release or a quarterly filing with the SEC. Examples of material, non-public information includes: • Company financial results not publicly released. • Significant mergers or acquisitions by or involving the Company. You may not use non-public information about Asbury obtained as the result of your employment for personal profit or as the basis of a “tip” to someone to buy or sell Asbury stock. If you are a GM, Regional Controller or corporate Team Member of the Company, before you trade in Asbury securities, you must be pre-cleared to trade by the Chief Legal Officer or Chief Audit and Risk Executive. In addition, Team Members may only trade when the trading window is open. Team Members will receive e-mail notification of the closing or opening of the trading window. However, if at any time you have knowledge of material, non-public information concerning Asbury, you may not trade in Asbury securities even if the trading window is open. • Threatened litigation involving the Company. • Other significant facts about the Company. Penalties for illegal insider trading, along with other violations of the U.S. federal securities laws, are severe, and may include both civil and criminal penalties and incarceration. As such, please remember that when trading in Asbury securities, you trade at your own risk. It is your responsibility to ensure that you are in compliance with the SEC’s rules and the Company’s Insider Trading Policy. Please make certain that you have reviewed the Company’s Insider Trading Policy in its entirety. Any questions about the Company’s Insider Trading Policy should be directed to the Company’s Legal Department at (770) 418-8200.
35 No policy should be construed to confer any express or implied contractual relationship or rights to any Team Member. The Company reserves the right to modify any policy as necessary, in its sole discretion, to the extent permitted by law. Violation of any Company policies or procedures can result in disciplinary action up to and including termination of employment. If you have any questions about this handbook or Company policies, please feel free to discuss with your Manager or HR.
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