Cares PROGRAM MANUAL JANUARY – DECEMBER 2024
CREA CARES PROGRAM
Purpose of The CREA Cares Program CREA Cares is a our charitable giving and volunteer program created for the benefit of CREA employees and the communities in which we work and live. Top Highlights of the Program All employees who give to charities can request a 100% match of those dollars up to a total of $250 annually. Employees are eligible for up 24 hours per year of paid time to volunteer at a charity of their choice. CREA Cares will host designated volunteer days on annual basis for employees within each CREA office to volunteer as a team. Eligible Charities CREA will match funding for any qualified organization under section 501(c)3 of the U.S. Internal Revenue Code Who’s Eligible? Full-time employees, part-time employees, employees on leave and interns are eligible to participate in the CREA Cares program.
For questions regarding the CREA Cares Programs, please contact:
Arvetta Jideonwo, MHA, CFRE Executive Director , CREA Foundation, Inc. Head of Social Impact , CREA, LLC
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TABLE OF CONTENTS
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I. Matching Gifts Program
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II. Volunteer Program
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III. Employee Referral Bonus Charitable Program
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IV. Monthly Cause Awareness
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V. Employee Driven Causes
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VI. Inclusion Advisory Council
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VII. Employee Resource Groups
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VIII. CREA Foundation
IX. CREA Foundation Annual Employee Pledge Drive
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Social Impact Model
• Student scholarships • Student Wraparound Services • Employee Giving
• Partnerships with Non-Profit Partners • Employee Volunteerism • CREA Cares
Volunteer
Philanthropy
Employee & Community Engagement
• Employee Driven Causes • Monthly Cause Awareness • Employee Matching Gifts • Employee Referral Bonus
• Employee Resource Groups • Monthly Awareness • Speaker Series • Community Engagements
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I. Matching Gifts Program
Overview The CREA Cares matching gifts program was created for the benefit of CREA employees and the communities in which we work, live and play. All employees who give to charities can request a 100% match of those dollars up to a total of $250 annually (up to two transactions per year).
Who’s Eligible? For eligibility, please refer to the CREA Cares Program overview.
Eligible Charities The list of charities that CREA will match funding for is extensive. Please note that the charitable organizations must meet the following criteria: • Qualify as a tax-exempt organization in the jurisdiction in which the organization is located (in the U.S., the organization would have to qualify under section 501(c)3 of the U.S. Internal Revenue Code) • Do not otherwise violate or conflict with CREA Cares Code of Conduct • Do not discriminate on the basis of race, color, religion or gender • Do not and will not give rise to a conflict of interest • Organizations in compliance with applicable laws • Will not negatively impact CREA Cares reputation • Demonstrate a need for support & sound financial management
Please forward all questions to Arvetta Jideonwo, ajideonwo@creallc.com or Monica Johnson, mjohnson@creallc.com for assistance.
Eligible Donations & Processing Guidelines Employee Guidelines 1. Made from your personal funds 2. Given to a qualified organization (see prior). 3. Paid in full and not pledged and does not exceed $250 per year. 4. Submit match request form with an electronic receipt within 90 days of the date of your donation. 5. The donation must be made to a registered 501(c)(3) charity located in the U.S.
6. Employees must upload an official gift receipt for the donation for which they are requesting a CREA match via the portal. The official gift receipt must include the charity’s logo and contact information. 7. CREA reserves the right to not match donations made without proper documentation of the gift. Processing Guidelines 1. Notification - Employee notified of match request approval via a direct email from the social impact team. 2. Verification - Social impact reviews and approves the application and non-profit, then verifies the employee has not maxed out their $250 per year matching requirement. 3. Payment - Social impact will notify accounting/finance by sending an email to process the donation. 4. Payment Notification - Accounting/finance will pay CREA match after notification is made by social impact and confirms by sending an email. 5. Final Approval - Employee notified of match request payment via a direct email from social impact team.
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II. Volunteer Program
Overview CREA employees are eligible for up to 24 hours per year of volunteer time off (VTO). The hours will be tracked via Paylocity. CREA will host two company- wide volunteer activities per year ( Days of Caring ) in each regional office. The company will engage in a formal partnership with a local, regional or national non-profit to facilitate company-wide volunteer activities. It is anticipated that the two activities will comprise of up to 16 hours. The remaining eight hours can be utilized by employees to volunteer at a non- profit of their choice. What is Eligible for Volunteer Time Tracking? • Participation as a volunteer board member for non-profit organizations. • Charity “a-thon” events are great fund- and friend-raisers for a non- profit. While time spent fundraising or training cannot be counted as volunteer time, the time you spend participating on the day of the event (including walking and running time) can be. • While on-site contributions of food, coats, school supplies, etc. are very much appreciated, only the organizers of the drive can track volunteer hours for their time spent planning and running the event. • Participation in a blood drive may count as a volunteer activity. If you are not being financially compensated, and the organization to whom you are donating is a registered non-profit, you are eligible to track your time. • For longer volunteer activities, travel and sleep time does not count as volunteer time. Only time spent participating in the service activity can be used for volunteer time. Ineligible Volunteer Activities • Travel time • Overnight trips • Time spent coaching sports, directing plays, or other recreational activities that do not benefit a registered 501(c)(3)
Looking for More Information? Contact: Arvetta Jideonwo, ajideonwo@creallc.com
Overview The Employee Referral Bonus Program encourages CREA employees to refer qualified candidates to CREA for any of the company’s current job openings. If the employee’s referral is successfully hired, the employee is eligible to receive a $2,500 referral fee. Effective November 1, 2021, the second layer of the referral program includes a $1,000 contribution to any qualified organization under section 501(c)3 of the U.S. Internal Revenue Code. The contribution will be considered an unrestricted gift to the organization for general operations. • In addition to the $2,500 referral bonus, you are eligible to request a $1,000 donation for your favorite non-profit organization (which could of course include the CREA Foundation) • The referred employee will have successfully on-boarded and been with CREA for 90 days. • Requests for the contribution will be made via a link through the SharePoint Culture page. Who’s Eligible? For eligibility, please refer to the CREA Cares Program overview. Eligible Charities The list of charities that CREA will match funding for is extensive but please note the charitable organizations must meet the following criteria: • Qualify as a tax-exempt organization in the jurisdiction in which the organization is located (in the United States, the organization would have to qualify under section 501(c)3 of the U.S. Internal Revenue Code) • Do not otherwise violate or conflict with CREA Cares Code of Conduct • Do not discriminate on the basis of race, color, religion or gender • Do not and will not give rise to a conflict of interest. • Organizations in compliance with applicable laws • Will not negatively impact CREA Cares reputation • Demonstrate a need for support and have sound financial management Non-Eligible Charities Please refer to the subheading of the same name within Sections I in regard to organizations and causes that CREA will not provide charitable support to III. Employee Referral Bonus Charitable Program
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for more information. The non-eligible charities listed in those sections apply in full to non-eligible charities as they pertain to Section III.
IV. Monthly Cause Awareness Program
Overview At CREA, we strive to be a supporter of causes external to the company’s focus as a resident of the world, our goal is to share our culture of good with the causes that our employees are most passionate about. Each year, CREA will select a cause to recognize on a monthly basis. The monthly cause awareness areas of focus are selected by the Head of Social Impact and Senior Vice President of Marketing and approved by CREA leadership. The cause will be identified and recognized on all internal/external communication platforms including adding an identifying ribbon (if applicable) to the email signature lines of each employee. The monthly cause will also be highlighted on internal platforms including CREA’s SharePoint site. The company will also make a $500 contribution to non-profit organizations working to address the monthly cause(s) for that month. The selected causes for 2024 are: January – Poverty Awareness February – Black History (Special Recognition – American Heart Month) March – Disability Awareness (Women’s History) April – National Donate Life May – Mental Health Awareness June – Pride & Juneteenth July – Wealth Inequality August – Immunization Awareness September – Hispanic Heritage October – Breast Cancer
November – Diabetes December – HIV/AIDS
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V. Employee Driven Causes Employee-Drive Causes Program support 12 monthly causes that CREA employees are passionate about while building a culture of philanthropy by also encouraging you to support your colleagues and the causes that are near and dear to their hearts. Our goal is to plant the seed of giving and encourage you to also support your CREA family members. We will also provide an opportunity for YOU to contribute to the non-profit of choice through providing information on how to donate. Remember, CREA will provide a 1:1 match for all employee donations up to $250 this year. Employee- driven causes are selected by the Social Impact Sub-Working Group as apart of the Inclusion Advisory Council. Applications are submitted in November, reviewed in December, and announced in January. The following non-profits will be supported in 2024 with a $500 contribution. (in no specific order):
• The Harry Thompson Center (Dee Bauer) • Pancreatic Cancer Network (Ben Riesmeyer) • The Indianapolis Public Schools Foundation (Will Pritchard) • Project Will (Neil Snorten) • JDRF Indiana and Kentucky (Kelli Ozdemir) • Vera Bradley Foundation for Breast Cancer (Joe Hanger) • Donate Life Indiana (Nancy Havlin)
• CARH Scholarship Foundation (Mike Regan) • Ethiopian Adoptees Foundation (Daniel Gerber) • East Bay Sanctuary Covenant (John Clevenger) • 100 Black Men of Indianapolis (Arvetta Jideonwo)
VI. Inclusion Advisory Council
Mission: CREA’s Inclusion Advisory Council (IAC) welcomes and advocates for everyone by fostering a culture of belonging, acknowledging unique but equal perspectives, and respecting differences to better serve and support employees, clients and communities. The IAC leads the way through open discussion, education and action opportunities that drive and support social impact programming, recruitment strategy, and diversity and inclusion goals.
Vision: An organization where everyone belongs.
Values: Advocacy / Community / Culture / Leadership / Respect
Overview Inclusion Advisory Council consists of 10 employees, two co-chairs and an executive sponsor who are dedicated to sharing insights and perceptions of what it personally feels like to work at CREA, how current initiatives are progressing from their viewpoint, and what they think would be good for your workplace to prioritize for internal and external initiatives. They generate ideas, share their lived experience, evangelize DEI initiatives and conversations within the broader company, and can run DEI programming. Each member must sit on at least one working group, which include: Social Impact, Representation & Brand, Engagement & Belonging, and Business Impact. The working groups were originated based on key goals and objectives to ensure CREA is growing and developing in creating a culture where employees feel they are:
• Respected • Supported • Safe • Belong • Heard
Meetings Twice monthly (45 minutes) One Annual In-Person Retreat One Virtual Annual Retreat
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Term of Appointment Inclusion Advisory Council members serve from August 1 – May 31 of each year. Each member has a term limit of two years. Members may reapply after not serving for two consecutive years. Potential candidates applying to be apart of the council must apply by the spring of each year. Compensation Inclusion Advisory Council members receive a small compensation for their time on an annual basis. Other Roles & Responsibilities Co-Chairs The Chairs will be the main points of contact into the council and are responsible for taking in the insights from the council to help define what is in the realm of the possibility and for the company. The Chairs will coordinate the activities sponsored by the Council, assigning and delegating specific responsibilities to the Council members. Co-chairs operate under term limits. Executive Sponsor The Executive Sponsor is a member of the CREA leadership team who will provide leadership team accountability, bring learnings from the council to leadership in day-to-day activities and be an advocate for the council.
VII. Employee Resource Groups
About: CREA’s Employee Resource Groups (ERGs) serve as a means for employees to engage in meaningful dialogue that promotes inclusion and belonging while allowing them to align within CREA values, principles, and corporate direction. ERGs are employee-led and consist of individuals that share common characteristics, traits, background or are allies for any individual group. Membership: All employees are eligible to attend and participate in Employee Resource Groups (ERGs). ERGs are inclusive of all employees including those that do not match the demographic background that each individual ERG is centered. Membership is not based on employee role or salary. Employees are encouraged to participate in ERGs during work hours. ERG membership will consist of the following roles: • Social Impact Liaison – A staff member from the Social Impact Department. • Lead(s ) – An employee responsible for providing leadership and guiding the direction of the ERG. • Member – An individual employee who participates in the ERG and matches the demographic background in which the ERG is centered around. • Ally – An individual employee who participates in the ERG. They do not match the demographic background in which the ERG is centered, however, they support members and engage in ERG efforts. Structure: CREA’s ERGs are a function of CREA’s Social Impact Department and are strategically aligned with as a part of the Inclusion Advisory Council. All annual plans will be reviewed by the IAC. Any recommendations for improvement in CREA’s culture will be provided to the IAC. The groups operational activities are supported by the Social Impact and Marketing Department while being employee-led and driven and in alignment with CREA’s mission, vision, and values. Social Impact Liaison The Social Impact Liaison is an employee from the Social Impact Department that is charged with the following tasks: • Facilitating the creation of ERGs
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• Providing support to ERG leadership • Approving financial requests (budgets) and annual plan made by ERGs. • Approving events proposed by ERGs. • Approving company-wide marketing and communication (in collaboration with Marketing) • Approval of ERG related travel • Approval of fundraising • Outside event sponsorship authorization • CREA ERG formal attendance at outside events • Acting as a liaison between ERGs and company leadership • Facilitation of bi-annual ERG survey Lead & Co-Leads ERG Leads and Co-Leads are individuals formally identified as the leader(s) of the ERGs. There is a recommendation of at least two individuals identified to lead each ERG to share the responsibility of providing direction for each group. Terms - The roles of ERG Lead and Co-Leads are bound by terms limits. No individual shall serve in this role indefinitely. This individual will serve in the leadership role for a term of 1 year and will be charged with the following tasks: • Provide structure for ERG meetings, including agendas for monthly and quarterly ally meetings. • Provide meeting content in collaboration with identifying needs from the group. • Identify needs for ERGs and advocating for those needs both within the group and with Social Impact Department • Provide content for CREA SharePoint Culture page on an ongoing basis. • Seek approval for the following internal activities: events, company- wide communication, ERG-related travel, fundraising, marketing, event sponsorship, attendance at outside events. • Represent the ERG for internal purposes within the company. • Inform ERG annual plan and budget seeking approval from Head of Social Impact • Work with the Social Impact Liaison to address additional concerns as the arise.
Members ERG members who match the demographic background in which the ERG is centered, do not hold any obligatory status within the ERG. Members are allowed to join or disjoin the ERG at any time without notice. Members are however bound to the following: • Respecting the confidentiality of all ERG group members • Engaging in respectfully in all dialogue and interactions with other members of the group • Actively participate and engage during ERG meetings Allies Allies who do not match the demographic background in which the ERG is centered, do not hold any obligatory status within the ERG. Allies are allowed to join or disjoin the ERG at any time without notice. Allies are however bound to the following: • Respecting the confidentiality of all ERG group members • Engaging in respectfully in all dialogue and interactions with other members of the group • Only attending meetings in which allies are invited New Group Formation When starting a new Employee Resource Group, the Social Impact Department will collaborate with interested individuals to assess interest in said group. If there is interest in said group, together they will establish the groups leadership and structure. Individuals interested in forming an ERG should contact the Social Impact Liaison.
Employee Resource Group Guidelines Philanthropy and Giving for External Non-Profit Organizations:
While philanthropic giving is not a requirement of CREA Employee Resource Groups, CREA encourages opportunities for alignment within its current Philanthropy & Giving among its Social Impact Work. If ERGs decide to engage with external non-profit organizations, the following guidelines will be applied: • External non-profit organizations in which employees support must be in alignment with CREA’s values. • ERG Leads and Co-Leads must seek approval from the Head of Social Impact for external non-profit organizations that are promoted to employees to make donations only directly to the non-profit. • Donations made by employees to the non-profit could be eligible to be matched by CREA. (See Funds to Support ERG Operations).
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• CREA employees will be able to still claim contributions to non-profits on their taxes. • CREA has the right to disapprove non-profits that are not aligned with its core values and philanthropic giving as outlined in the CREA Cares Manual. • All employee donations made directly to the non-profit must be positioned as voluntary. The following procedures must be followed to gain approval for the official support of ERG related fundraisers for external non-profit organizations: Approval Process: 1. The ERG must come to a consensus regarding the external non-profit organization. 2. ERG Leads must request approval for the cause in writing. The request should be sent to the Head of Social Impact. The request must include. a. The name of the organization b. How the funds will be collected directly by the non-profit? c. How this endeavor aligns with CREA and the company values d. To whom are you seeking to collect money from (full staff, ERG members only, etc.) e. What is the plan for internally soliciting donations? 3. The Head of Social Impact will have seven (7) business days to respond to the request. 4. If approval is received, the ERG Leads are free to begin the campaign. Budget to Support ERG Operations Employee Resource Groups may require funds to fully engage participants and support ERGs operational activities throughout the year. CREA supports such activities and events in alignment with its core values and encourages them to increase awareness and education among its employees. The following are guidelines on how ERGs are to be funded within CREA: Guidelines: • ERGs are given a specified budget each year to support operational activities, which should be outlined its annual plan. • ERGs can elect to self-fund activities by members in the group through an optional assessment. However, the assessments should not be factored into member requirements to be a part of the ERG.
• ERGs are not permitted to fundraise by selling goods of any kind; apparel, baked goods, crafts, etc. to CREA employees.
Marketing and Communications Employee Resource Groups may find a need for marketing, logo development, and company-wide communication. CREA believes it is important to share information about your activities and events with the entire company to provide inclusive opportunity for attendance to maximize participation. The following guidelines should be utilized regarding marketing: Email: • ERGs can send emails and Microsoft Teams messages to ERG members freely and without approval. • ERG Leads and Co-Leads can send company-wide internal emails, but those messages will need to be authorized and approved by the SVP of Marketing and Communication and Head of Social Impact prior to being sent to the company. • There will be no external emails. Approval Process: 1. The ERG Lead will contact the Head of Social Impact and SVP of Marketing and Communication requesting authorization to send an internal company-wide email. 2. Either the Head of Social Impact and SVP of Marketing and Communication will review the request and respond with approval within 3 business days. In case of escalation, the time-frame may be Employee Resource Group Name: • CREA respects and acknowledges ERGs and their ownership of group names. Once a consensus has been made regarding a name or name options by the group, the name(s) must be submitted to the Head of Social Impact and SVP of Marketing and Communications for approval. • Groups names can be used in combination with CREA (stated as a whole), but the CREA name itself cannot be altered. • Noted examples: “ALAANA at CREA; Women at CREA; United at CREA.” Approval Process: 1. The ERG Lead(s) will contact both the Head of Social Impact and the SVP of Marketing and Communication in writing to seek approval for their extended. If this is the case, the ERG Lead will be notified. 3. If approved, communication can be sent immediately.
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created ERG name. 2. A meeting including the ERG Leads could be scheduled to discuss the proposed names or alternative name options. 3. Once received, the Head of Social Impact and the SVP of Marketing and Communication have 14 days to respond to the request. 4. Once the ERG name has been approved, members of the ERG are able to begin freely using the name. Logo: • We encourage ERGs to work with Marketing and Communications to create their logo. • For branding purposes, the logo alone must not be similar in structure to the CREA company logo but can be utilized in combination with the whole CREA logo. • To ensure continuity of design and CREA brand guidelines, all ERG logos will be created by the Marketing and Communications and options will be presented to the ERG for review and discussion. Approval Process: 1. Once submitted, a member of the marketing department will begin working with the group to develop their ERG logo. 2. The logo will then be sent to the SVP of Marketing and Communication for approval. 3. Once approved by Marketing, the Head of Social Impact will review and approve on the use of the ERG logo. 4. 4Logos are available for immediate use upon approval. 5. All logo usage. will be informed by the ERG but posted by Marketing and Communications via internal platforms including SharePoint, Outlook, etc. External Marketing (Including Social Media): In alignment with the ERG’s annual plan, Marketing and Communications will promote that we have ERGs in alignment with CREA values. Due to confidentiality of ERG members, individual members are NOT to post and tag CREA.
Events CREA encourages Employee Resource Groups to engage in events to engage and increase participation among groups, which creates an environment of belonging and connection for CREA employees. The structured events should be included as a part of the ERG’s annual plan to ensure CREA can fully support activities through having advanced knowledge. The following are guidelines for hosting internal and external events: Internal Events: • All internal events must be authorized and approved by the Social Impact Department and aligned with CREA values and notification should be outlined in the ERGs annual plan to ensure proper notification to the entire company. • Marketing will make every effort to provide photography during the event, providing that proper notice is given, and event is included in the group’s annual plan. • All internal events must be inclusive of all CREA staff both demographically and geographically with an attempt to involve all offices centered members and allies. Approval Process: 1. A written request should be made to the social impact liaison. 2. After the request is made, the Social Impact Department has 14 days to respond with either an approval or denial of the event. 3. Planning for the event can begin upon approval being granted. External Group Events: • All external ERG sanctioned events for group members during work hours must be authorized and approved by both the Social Impact and Marketing Departments should be outlined in the ERGs annual plan to ensure proper notification to the entire company. • All ERG sanctioned events should be in alignment with CREA values. • All external events must be inclusive of all CREA staff both demographically geographically with an attempt to involve all offices centered members and allies. centered members and allies. • Marketing will make every effort to provide photography during the event, providing that proper notice is given, and event is included in the group’s annual plan. • External events occurring after work hours or on the employee’s own time are not subject to this process.
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Approval Process: 1. A written request should be made to the Head of Social Impact and the SVP of Marketing. If seeking to be paid during this time, human resources and the employee’s supervisor also need to be made aware of the request and must give their approval of the event. 2. After the request is made, the Social Impact and Marketing departments have 14 days to respond with either approval or denial of the event. 3. Planning for the event can begin upon approval being granted. Travel • ERG meetings are to be held virtually/in-person to be inclusive and to provide all employees to participate and engage. • ERG meet-ups taking place during CREA sanctioned company-wide events, conferences, and meetings where all employees are invited are permitted. (i.e., CREA Live) • Travel is not authorized for the purpose of ERG events only. We encourage employees to combine business travel with ERG activities to engage and connect with employees beyond a specific ERG. • If extenuating circumstances arise and travel is thought to be necessary specifically for the ERG, authorization will need to be sought from the Head of Social Impact, immediate supervisor, and Directors. Approval Process: 1. If travel is thought to be necessary, ERG members must notify their immediate supervisor and Head of Social Impact directly in writing prior to booking any travel. 2. Once notified, the Head of Social Impact will seek the approval of CREA directors. 3. Once received, the Head of Social Impact will have 14 days to respond. 4. When approval is received, travel can then be booked.
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Mission Through strategic partnerships, CREA Foundation seeks to improve the lives of youth and young adults facing financial barriers to success in the communities we serve by creating opportunities to further their learning, development and education. Vision For all youth and young adults living within CREA’s affordable housing communities to have the opportunity to successfully earn a college degree. Equity Statement CREA Foundation is committed to being a trusted and equitable resource for youth and young adults to find support in aspiring to diverse goals. We also aim to be a resource our charitable partners and other local corporate supporters can count on to understand, participate in and contribute to societal solutions. CREA Foundation bolsters the strength and efficiencies needed for nonprofits to make progress on complex issues within our communities. In pursuit of our vision, we are committed to addressing the historic, emerging, dynamic and collective imbalances of power in order to suppress racial injustice and provide opportunity for all.
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CREA Foundation Board of Directors
Arvetta Jideonwo Executive Director and Member
Jeff Whiting Chairman and Member
Charles Anderson Member
Tony Bertoldi Member
Stefanie Brown Member
Kyle Malone Member
Pam McIntyre Member
Katy McShane Member
Laurie Levitt Schoenburg Member
Roger Shank Member
Brian Villa Member
IX. CREA Foundation Annual Employee Pledge Drive
Overview CREA offers employees the opportunity to contribute to CREA Foundation through payroll deduction and direct donations. The annual pledge drive will be from November 15th – December 1st of each year. CREA Foundation allocates funds through two primary vehicles, financial scholarships to students pursuing post-secondary education pathways; and grants to support college prep, access and success to non-profit organizations. Employees can elect to give via payroll deduction by signing up during Open Enrollment (November 15th – December 1st) or make a direct donation. Employees can also elect to make a one-time contribution to CREA Foundation during the bonus payroll in March of each year. The opportunity to make a contribution will be shared via Paylocity in advance of the bonus payroll date, which typically occurs during the first pay period of March. How does your contribution make a difference? Your gift can make a significant difference in creating opportunities for students experiencing challenges accessing post-secondary education. By working collaboratively together as a team or one big family, we change lives and give students the opportunity to break the cycle of poverty by providing access to education and supporting causes to ensure students complete their degree programs. Additionally, your gift helps us raise funds. When we can go to an investor partner and tell them that our employees support us 100% financially, it makes a strong statement. Every gift count towards meeting our participation goal. Join us in making a difference! Our scholarship per student is $5,000 per year. We currently have 30 CREA scholars at Indiana University Indianapolis and California State University, Northridge. We thank you in advance of your support for CREA Foundation in meeting our mission to break the cycle of poverty among students from affordable housing communities.
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People are the very heart of what we do. CREA’s shared commitment to going out of the office and into communities to provide direct support sets up apart. This mission our greatest distinction.
Jeffrey Whiting CHAIRMAN & CEO
CREALLC.COM
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