NEWPORT VINEYARDS

EMPLOYEE HANDBOOK

January 1 , 2016

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Table of Contents WELCOME .................................................................................................................................................... 3

OUR VISION: .................................................................................................................................................. 3

OUR MISSION: ............................................................................................................................................... 3

OUR VALUES:................................................................................................................................................. 3 EMPLOYEES: ................................................................................................................................................. 4 FLEXIBILITY: .................................................................................................................................................. 4 TEAMWORK: ................................................................................................................................................. 4 REWARDS: .................................................................................................................................................... 4 PURPOSE ...................................................................................................................................................... 4

EMPLOYMENT ............................................................................................................................................... 5 EQUAL EMPLOYMENT OPPORTUNITY STATEMENT ............................................................................................... 5 AT-WILL EMPLOYMENT NOTICE ....................................................................................................................... 5 NEW HIRE ORIENTATION ................................................................................................................................ 5 BACKGROUND CHECK ..................................................................................................................................... 6 EMPLOYMENT CLASSIFICATION CATEGORIES ...................................................................................................... 6 PERSONNEL RECORDS..................................................................................................................................... 7 COMPLAINT PROCESS ..................................................................................................................................... 8 WORKPLACE BULLYING ................................................................................................................................. 12 SAFETY, SECURITY AND VIOLENCE IN THE WORKPLACE ....................................................................................... 12 SEPARATION OF EMPLOYMENT ...................................................................................................................... 13

WORKPLACE SAFETY ................................................................................................................................... 14 ACCIDENTS/INJURIES .................................................................................................................................... 14 WORKERS’ COMPENSATION .......................................................................................................................... 14 SMOKE-FREE WORKPLACE ............................................................................................................................ 14 DRUGS AND ALCOHOL .................................................................................................................................. 15

WORKPLACE EXPECTATIONS ....................................................................................................................... 16 CONFIDENTIALITY ........................................................................................................................................ 16 OUTSIDE ACTIVITIES ..................................................................................................................................... 18 ELECTRONIC ASSETS USAGE ........................................................................................................................... 18 INFORMATION SECURITY & USE OF TECHNOLOGY RESOURCES ............................................................................ 22 USE OF PERSONAL COMPUTING DEVICES ......................................................................................................... 23 USE/STORAGE OF NON-BUSINESS RELATED AUDIO/VIDEO FILES ......................................................................... 23 PHONE USAGE ............................................................................................................................................ 23 PERSONAL PROPERTY ................................................................................................................................... 23 ATTENDANCE/TARDINESS ............................................................................................................................. 23 ATTIRE AND GROOMING ............................................................................................................................... 24 BUSINESS GIFTS........................................................................................................................................... 24

COMPENSATION ......................................................................................................................................... 25 HOURS OF WORK ........................................................................................................................................ 25

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SCHEDULES .................................................................................................................................................. 25 PAY PERIODS .............................................................................................................................................. 25 PAY ADJUSTMENTS ...................................................................................................................................... 25 OVERTIME .................................................................................................................................................. 26 DEDUCTIONS .............................................................................................................................................. 26 COMPENSATION .......................................................................................................................................... 26 PERFORMANCE EVALUATION ......................................................................................................................... 26 PROMOTIONS ............................................................................................................................................. 27 WORK ASSIGNMENTS ................................................................................................................................... 27 MANDATORY MEAL PERIOD .......................................................................................................................... 27 EMPLOYEE MEALS ....................................................................................................................................... 28

TIME OFF/LEAVES OF ABSENCE .................................................................................................................. 28 HOLIDAYS ................................................................................................................................................... 28 VACATION .................................................................................................................................................. 28 MILITARY LEAVE .......................................................................................................................................... 29 FAMILY MEDICAL LEAVE (FMLA) ................................................................................................................... 30 WITNESS LEAVE .......................................................................................................................................... 33 BEREAVEMENT LEAVE ................................................................................................................................... 33

BENEFITS ..................................................................................................................................................... 34 MEDICAL AND DENTAL INSURANCE ................................................................................................................. 34

CONTINUATION OF BENEFITS (COBRA) ...................................................................................................... 34

EMPLOYEE HANDBOOK ACKNOWLEDGEMENT ......................................................................................... 36

ANTI-HARASSMENT POLICY ACKNOWLEDGEMENT .................................................................................... 37

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Welcome Newport Vineyards is dedicated to delivering an extraordinary product with a customer service focus. Established in 1977, our brief history reflects our entrepreneurial spirit:

• In 1977, retired naval captain, Richard Alexander, planted the first grapes on the Hopelands Estate overlooking Rhode Island Sound.

• In 1988, a partnership between Captain Alexander and the Nunes family established Vineland Wine Cellars.

• In 1995, Paul and John Nunes acquired the winery from Captain Alexander and established Newport Vineyards.

• In 1998, Newport Vineyards acquired Perry Farm next to the winery on Route 138. • In 2002, Newport Vineyards acquired the Nunes Farm located on Wyatt Road. • Now situated on sixty (60) acres of farmland which has been in the Nunes family since 1918, we

are one of the largest producers of wine grapes in New England and bottle over 20,000 cases of wine annually. We grow 17 different varieties of grapes which allow us to make 30 styles of wine, as well as, hard apple cider made from apples sourced from local orchards. Aquidneck Island is blessed with an extraordinary micro-climate, created by a combination of the warm waters of the Gulf Stream to the south and the moderating effects of Narragansett Bay. These conditions provide a long, cool growing season which is ideal for developing complex flavors in wine.

• In 2015, Newport Vineyards celebrates the 20th Anniversary and a multi-million dollar renovation. The Company continues to expand venue facilities, to grow public and private events, and to develop live music opportunities.

You have joined an organization that takes great pride in the quality of our food and beverages. Our high standards can only be achieved and maintained through people like you who share our values and desire to do the very best job for our guests. We hope you too, will find satisfaction and take pride in your work here. Welcome!

OUR VISION: An honest approach to wine and culinary operations with a focus on exceptional service.

OUR MISSION: To take pride in the quality of the food and beverages produced and delivered with friendly; and professional service, and to offer a distinctive experience to all guests.

OUR VALUES: We will achieve our vision by staying true to the following core values:

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Employees: We are committed to treating our employees as our greatest asset by providing competitive wages and benefits, responsive management, and training. Flexibility: As we strive to serve and satisfy the needs of our customers, our exceptional team accepts that change is a key factor to staying ahead of the curve. Teamwork: A culture of respect, communication, and high standards produces excellent employee hires and retention. With a strong cultivation mentality, Newport Vineyards believes that a good idea deserves to be heard, regardless of title or position. We take pride in our work and are proud of the top-tier team of professionals moving us forward. Rewards: Competitive wages, comprehensive benefits and a service-centered culture is the bonus for being part of the Newport Vineyard Team.

Purpose This Employee Handbook is presented as a matter of information and contains guidelines about Newport Vineyard’s philosophy, employment practices, policies, the benefits provided, and the conduct expected from you. This Handbook is not intended to be a contract of employment and does not constitute one. Except for the at-will employment provisions, the Handbook can be amended at any time.

This Employee Handbook will not answer every question you may have, and we do not want to restrict the normal question and answer interchange among us. It is in our person-to-person conversations that we can better know each other, express our views, and work together in a harmonious relationship.

We hope this guide will help you feel comfortable with us. We depend on you – your success is our success. Please don’t hesitate to ask questions. We will gladly answer them. We believe you will enjoy your work and your fellow employees here. We also believe you will find Newport Vineyard is a great place to work.

No one other than authorized management may alter or modify any of the policies in this Employee Handbook. No statement or promise by anyone other than Newport Vineyards is to be interpreted as a change in policy, nor will it constitute an agreement with an employee.

Should any provision in this Employee Handbook be found to be unenforceable and invalid, such finding does not invalidate the entire Employee Handbook, but only the subject provision.

We ask that you read this guide carefully, become familiar with Newport Vineyards and our policies, and refer to it whenever questions arise.

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Employment

Equal Employment Opportunity Statement Newport Vineyards does not discriminate in the employment of staff, including the hiring, promotion and termination of employment, benefits, and terms and conditions of employment on the basis of a person’s race or color, religion, sex, disability, age, sexual orientation, gender identity or expression, genetic information and any other status protected by law, or national origin. Newport Vineyards expects its staff to fully support its Equal Opportunity policies.

At-Will Employment Notice Your employment is "at-will." All Newport Vineyard employees are at-will, which means they may be terminated at any time and for any reason, with or without advance notice. Employees are also free to leave at any time. Any employment relationship other than at-will must be set out in writing and signed by the employee and an owner of Newport Vineyards.

New Hire Orientation Newport Vineyards provides an orientation program which must be attended by all new employees. The purpose of this program is to familiarize new employees with company policies, procedures, and benefits. To insure successful orientation, each new employee is urged to ask questions to allow a better understanding of company policies, procedures, and benefits. Generally, all employees will, as part of orientation, be provided a checklist, which they will be asked to sign, which verifies that they have been oriented to all items on the checklist. This checklist will be placed in the employee’s personnel file. Americans with Disabilities Act (ADA) It is Newport Vineyards’ policy that we will not discriminate against qualified individuals with disabilities with regard to any aspect of their employment. Newport Vineyards is committed to complying with the ADA Amendments Act of 2008, the Americans with Disabilities Act of 1990 and its related Section 504 of the Rehabilitation Act of 1973, as applicable. Newport Vineyards recognizes that some individuals with disabilities may require accommodations at work. If you are currently disabled or become disabled during your employment, you should contact Human Resources to discuss reasonable accommodations that may enable you to perform the essential functions of your job. We are not required to provide an accommodation that could cause the business an undue hardship as defined by law. The Americans with Disabilities Act defines "disability" as: (1) a physical or mental impairment that substantially limits one or more of the major life activities of such individual; (2) a record of such an impairment; or (3) being regarded as having such an impairment. "Major life activities" include caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, and working. Work Eligibility Records The federal government requires that within three business days of your first day of work, you must complete an employment eligibility verification form (I-9 Form), and show us documentation proving your identity and your eligibility to work in the United States.

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If you have previously worked for this Company, you need only provide this information if it has been more than three years since you last completed an I-9 Form for us or if your current I-9 Form is no longer valid. I-9 Forms are maintained separately from other personnel records and are treated as confidential to the extent possible. If you need additional information about the I-9 Form, please contact Human Resources.

Background Check Employees who have falsified information on their employment applications will be disciplined, which could include termination. Applicants who have provided false information may be eliminated from further consideration for employment. All inquiries regarding a current or former employee must be referred to Human Resources. Should an employee receive a written request for a reference, he/she should refer the request to Human Resources for handling. No employee may issue a reference letter to any current or former employee without the permission of Human Resources. Under no circumstances should any employee release any information about any current or former employee over the telephone. All telephone inquiries regarding any current or former employee must be referred to the Human Resources. In response to an outside request for information regarding a current or former employee, Human Resources will furnish or verify only an employee's name, dates of employment, job title and department. No other data or information regarding any current or former employee, or his/her employment with the company, will be furnished unless the employee authorizes the company to furnish this information in a writing that also releases the company from liability in connection with the furnishing of this information or the company is required by law to furnish any information.

Employment Classification Categories Newport Vineyards has established the following Employee Classifications for compensation and benefit purposes only. Management will inform you of your classification, status, and responsibilities at the time of hire, rehire, promotion, or at any time a change in status occurs. These classifications do not alter your at-will employment status.

• Regular Full-Time Employee: An employee who is scheduled to work thirty (30) hours or more

in a workweek and has worked at least 1,560 hours per year from the first day of the month following the date of hire . The employee may be exempt or non-exempt and is eligible for all employment benefits offered by Newport Vineyards.

• Regular Part-Time Employee: An employee who is scheduled to work less than 30 hours in a workweek. They are ineligible for employment benefits.

• Temporary Employee: An employee who is scheduled to work on a specific need for Newport

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Vineyards for a temporary duration of time. The employee will not receive any benefits unless specifically authorized in writing. The employee is non-exempt and is compensated on an hourly basis. Temporary employees retain their temporary status until notified otherwise, in writing, regardless of the number of hours worked.

• Exempt: Employees whose positions meet specific tests established by the Fair Labor Standards Act (FLSA) and applicable state law and who are exempt from overtime pay or compensatory time off requirements. The basic premise of exempt status is that the exempt employee is to work the hours required to meet his/her work responsibilities.

• Non-exempt: Employees whose positions do not meet FLSA and state exemption tests and who are paid a multiple of their regular rate of pay for overtime hours worked, Sunday hours worked, or holidays observed by the State of Rhode Island labor laws.

Personnel Records An employee's personnel file consists of an employee's employment application, withholding forms, reference checks, emergency information and any performance appraisals, benefits data and other appropriate employment-related documents. If you experience a change in address, telephone number, name, marital status, dependents, and/or other relevant personal data, it is requested that you notify Human Resources immediately. This will ensure that the status of your benefits and tax records remain current and accurate. When a change in number of dependents or marital status occurs, the employee must complete a new W-4 form. Newport Vineyards will not be responsible for any consequences due to the employee’s failure to make notice of information changes. You may be dismissed for misrepresenting any fact on your application or in your personnel file. Personnel records are considered company property and have restricted access. Up to three times a year, you may review and request that specific documents be copied from your record in the Human Resources office after giving adequate notice. In the event that you wish to review your personnel file, you must do so in the presence of management or designee at a reasonable time. Management reserves the right to require that you provide seven (7) days advance notice, holidays, Saturdays and Sundays excluded, and at any reasonable time other than your scheduled work hours and upon written request , prior to reviewing your file. Newport Vineyards may charge a fee reasonably related to the cost of supplying copies of requested documents. The written request will become a permanent part of your file. Access to personnel records does not apply to records of an employee relating to the investigation of a possible criminal offense or records prepared for use in any civil, criminal, or grievance proceedings, any letter of reference, recommendations, managerial records kept or used only by the employer, confidential reports from previous employers, and managerial planning records. Conduct Standards & Discipline

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Newport Vineyards expects every employee to adhere to the highest standards of job performance and of personal conduct, including individual involvement with Company personnel and outside business contacts, vendors and patients. The Company reserves the right to discipline or discharge any employee for violating any Company policy, practice or rule of conduct. The following list is intended to give you notice of our expectations and standards. However, it does not include every type of unacceptable behavior that can or will result in disciplinary action. Be aware that Newport Vineyards retains the discretion to determine the nature and extent of any discipline based upon the circumstances of each individual case. Employees may be disciplined or terminated for poor job performance, including, but not limited to the following:

• Unsatisfactory quality or quantity of work • Repeated unexcused absences or lateness • Failing to follow instructions or Company procedures • Failing to follow established safety regulations • Falsifying an employment application or any other company records or documents • Failing to record working time accurately or recording a co-worker's timesheet • Using vulgar, profane or obscene language, including any communication or action that violates

our policy against harassment and other unlawful forms of discrimination • Disorderly conduct, fighting or other acts of violence • Misusing, destroying or stealing company property or another person's property • Possessing, entering with or using weapons on company property • Possessing, selling, using or reporting to work with alcohol, controlled substances or illegal drugs

present in the employee's system, on company property or on company time • Violating conflict of interest rules • Violating the Company's computer or software use policies, and • Being convicted of a crime that indicates unfitness for a job or presents a threat to the Company

or its employees in any way • Lying or engaging in misrepresentation or fraud • Written or verbal expression of personal beliefs that are considered inappropriate, offensive,

discriminatory or derogatory while working and representing the Company

Every employee has the duty and the responsibility to be aware of and abide by existing rules and policies. Employees also have the responsibility to perform his/her duties to the best of his/her ability and to the standards as set forth in his/her job description or as otherwise established.

Complaint Process Newport Vineyards recognizes that a peaceful working environment facilitates productivity, and will continue to take the necessary steps to create a harmonious working environment. In the event that a misunderstanding or conflict arises, every effort should be made to resolve the situation in a timely manner. Should the situation persist, you are encouraged to bring the complaint to the attention of management by following the process below:

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Discuss the situation with your immediate supervisor. If this is not sufficient or appropriate, then meet with a department manager or a member of your human resources department, who may proceed to conduct an investigation into the situation and find possible remedies.

Note: Complaints alleging violations of the Company’s discrimination/harassment policy should be handled in accordance with the policy entitled “Policy Prohibiting Harassment and Discrimination.”

Policy Prohibiting Harassment and Discrimination Newport Vineyards prohibits the harassment of any employee or customer of Newport Vineyards on the basis of his or her:

• Race or color; • Religion; • Sex; • Disability; • Age; • Sexual Orientation; • Gender Identity or Expression; • National Origin; or • Genetic Information • Any other status protected by Law

Newport Vineyards will not tolerate unlawful harassment by or toward any employee or customer of Newport Vineyards. Incidents of this nature are considered a serious offense by the Company. This policy applies to all persons involved in the operation of Newport Vineyards, including management and staff, as well as, supervisors and co-workers. Newport Vineyards will also take all reasonable steps to prevent or eliminate harassment by or toward non-employees, including customers/patients, vendors, suppliers, and anyone else who may have job-related contact with our employees. Sexual Harassment Defined Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, or other verbal, written or physical conduct of a sexual nature or related to a person’s sex when:

• submission to such conduct is made explicitly or implicitly a term or condition of an individual’s employment standing or opportunities; or

• submission to or rejection of such conduct by an individual is used as the basis for employment-

related decisions affecting that individual; or

• such conduct has the purpose or effect of unreasonably interfering with an individual’s performance or creating a hostile, intimidating, humiliating or offensive environment.

Such behavior may involve pressure from a person of either sex, against a person of the opposite sex or same sex, regardless of sexual behavior. Examples of Sexual Harassment

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While it is not possible to list all circumstances that constitute sexual harassment, the following are examples of conduct which, if unwelcome, may constitute sexual harassment, depending upon the severity of the conduct and its pervasiveness:

• Unwelcome and unwanted sexual jokes, language, epithets, advances or propositions; • Written or oral abuse of a sexual nature, sexually degrading or vulgar words to describe an

individual; • Display of sexually suggestive objects, pictures, posters or cartoons; • Unwelcome and unwanted comments about an individual's body, sexual prowess or sexual

deficiencies; • Asking questions about sexual conduct; • Harassment consistently targeted at only one sex, even if the content of the verbal abuse is not

sexual; • Unwelcome touching, leering, whistling, or suggestive, insulting or obscene comments or

gestures; • Demanding sexual favors in exchange for favorable reviews, assignments, promotions,

continued employment or promises of the same; • Assault or coerced sexual acts.

Other Forms of Harassment Newport Vineyards similarly prohibits all offensive behavior directed at a person's race, ethnicity, religion, age, sex, sexual orientation, gender identity or expression, disability or genetic information (“protected status”). Racial, ethnic or other harassment is conduct that has the effect of substantially interfering with an individual's work performance and creating a hostile, intimidating or offensive working environment. Actions constituting such prohibited conduct include, among other things: Displaying material that is demeaning to or derogatory of a person because of his or her protected status, including material intended as humor; bringing to work for the purpose of sharing or communicating with other employees any material that is demeaning to or derogatory of a person because of his or her protected status, including material intended as humor; or communicating to any employee any comment that is demeaning to or derogatory of any person because of his or her protected status, including comments that are intended as humor. Filing a Discrimination/Harassment Complaint with Newport Vineyards It is the goal of this policy and its procedures to create an environment in which people that have experienced harassment or who have concerns about harassment or discrimination issues will feel free to discuss those concerns with someone in a position to do something about them. Upon receipt of a complaint, either oral or written, an investigation will be undertaken and prompt corrective action will be taken wherever necessary. If your initial complaint is oral, we may ask you to write down all the details, including facts, the names of individuals involved, and the names of any witnesses, if applicable, in order to assist in the investigation. Prompt reporting is important, as it allows Newport Vineyards to investigate while the facts are fresh and to take prompt corrective action. If you believe that you have been the victim of discrimination, harassment, or offensive communications you should use the following complaint procedure: Newport Vineyards designates, Human Resources, to serve as its Investigative Officer for sexual harassment, discrimination and retaliation issues. If you have a complaint of sexual harassment and/or

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retaliation, you should contact Human Resources, who may appoint a designee to assist in handling sexual harassment /retaliation complaints. Each employee is responsible for cooperating in any investigation of alleged harassment if requested to do so by the person conducting the investigation. All employees have the responsibility and duty to report any incidents of harassment to a member of management or designee, in order to allow Newport Vineyards to investigate and take corrective action as soon as possible in order to ensure that such incidents will not occur again. Any employee who has knowledge of such behavior and fails to report it is subject to disciplinary action. All employees have the explicit responsibility and duty to report any sexual, racial, ethnic, or other harassment of our employees. Failure to report will subject that person to disciplinary action. Those investigating for Newport Vineyards will preserve the confidentiality of facts and identities as much as practical. Those making a complaint or participating in an investigation are expected to maintain appropriate confidentiality and to act professionally and discreetly at all times. Retaliation or reprisal against any employee for making such a complaint or for filing any discrimination charge is strictly prohibited. Similarly, retaliation or reprisal against any employee participating in good faith in an investigation of a harassment complaint is strictly prohibited. Anyone found to have engaged in such wrongful behavior will be subject to appropriate discipline, which may include termination. Harassment by Nonemployees The Company will also endeavor to protect employees, from reported harassment by nonemployees in the workplace, including customers/patients, vendors and suppliers. Filing a Charge Employees have the right to file a charge of discrimination with the federal and state agencies responsible for enforcing the laws against illegal workplace harassment. The names and addresses of those agencies are listed below.

Rhode Island Commission for Human Rights 180 Westminster Street Providence, RI 02903 (401) 222-2661

Equal Employment Opportunity Commission One Congress St., Room 1001 Boston, MA 02114 (617) 565-3200

Discipline Any employee who is found, after appropriate investigation, to have violated any company policies concerning discrimination or harassment will be subject to appropriate discipline. Discipline may consist of a range of actions, including but not limited to warning, reassignment, unpaid suspension, mandatory counseling, and termination of employment. The disciplinary action taken will depend on the seriousness of the violation, as well as the employee’s overall disciplinary record. Any non-employee found to have committed an act of harassment or discrimination may be removed or barred Newport Vineyards premises, or other appropriate action may be taken. Newport Vineyards prohibits any form of retaliation against any employee for filing a bona fide complaint of harassment or discrimination or for assisting in the complaint investigation. Any employee

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with a concern that he or she is being retaliated against should immediately bring it to the attention of Human Resources, or designee. However ,if, after investigating any complaint of unlawful discrimination or harassment, Newport Vineyards determines that an employee intentionally provided false information regarding the complaint, disciplinary action, up to and including termination of employment, may be taken against any individual who provided the false information, including the initial complainant. It should be noted that while this policy sets forth our goal of providing a workplace that is free of harassment, the policy is not designed or intended to limit Newport Vineyards authority to discipline or take remedial action for workplace conduct which it deems to be unacceptable, regardless of whether that conduct satisfies the legal definition of sexual harassment.

Workplace Bullying Newport Vineyards defines bullying as “repeated inappropriate behavior, either direct or indirect, whether verbal, physical or otherwise, conducted by one or more persons against another or others, at the place of work and/or in the course of employment.” The purpose of this policy is to communicate to all employees, anyone with supervisory and/or management duties , that the company will not tolerate bullying behavior. Employees found in violation of this policy will be disciplined up to and including termination. Bullying may be intentional or unintentional. However, it must be noted that where an allegation of bullying is reported and the investigation substantiates that a reasonable claim was made, the intention of the alleged bully is irrelevant and will not be given consideration when meting out discipline. As with sexual harassment, it is the effect of the behavior upon the individual that is important. Newport Vineyards considers the following types of behavior examples of bullying:

• Verbal bullying: Slandering, ridiculing or maligning a person or his/her family; persistent name calling that is hurtful, insulting or humiliating; using a person as the butt of jokes; abusive and offensive remarks.

• Physical bullying: Pushing, shoving, kicking, poking, tripping, assault or threat of physical

assault; damage to a person’s work area or property.

• Gesture bullying: Nonverbal threatening gestures or glances that convey threatening messages.

• Exclusion: Socially or physically excluding or disregarding a person in work-related activities.

Safety, Security and Violence in the Workplace It is the intent of Newport Vineyards to provide a safe workplace for employees and to provide a comfortable and secure atmosphere for customers/patients and others with whom we do business. Employees are expected to refrain from conduct that may be dangerous to others. Newport Vineyards has zero tolerance for violent acts or threats of violence or intimidation. Any employee who commits or threatens to commit a violent act against any person during the course of their employment will be subject to immediate discharge.

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Employees within Newport Vineyards share the responsibility in identification and alleviation of threatening or violent behaviors. Indirect or direct threats of violence, incidents of actual violence and suspicious individuals or activities should be reported as soon as possible to Human Resources.

The Company will promptly and thoroughly investigate all reports of threats of violence or incidents of actual violence and of suspicious individuals or activities. Anyone found to be responsible for threats of or actual violence or other conduct that is in violation of these guidelines will be subject to prompt disciplinary action up to and including termination of employment.

Separation of Employment Separation of employment within an organization can occur for several different reasons.

• Resignation: Although we hope your employment with us will be a mutually rewarding experience, we understand that varying circumstances cause employees to voluntarily resign employment. Resigning employees are encouraged to provide two (2) weeks’ notice, preferably in writing, to facilitate a smooth transition out of the organization. Management reserves the right to provide an employee with two (2) weeks’ pay in lieu of their working through the notice period in situations where job or business needs warrant such action. If an employee provides less notice than requested, the employer may deem the individual to be ineligible for rehire depending on the circumstances regarding the notice given.

• Job abandonment: Employees who fail to report to work or contact their supervisor for three

(3) consecutive workdays shall be considered to have abandoned the job without notice, effective at the end of their normal shift on the third day. The Manager shall notify Human Resources at the expiration of the third workday and initiate the paperwork to terminate the employee. Such employees will not be eligible for rehire unless extenuating circumstances exist.

• Termination: Employees of Newport Vineyards are employed on an at-will basis, and the

company retains the right to terminate an employee at any time for any reason or no reason. Return of Company Property The separating employee is required to immediately return all Company-owned property used during his/her employment, and all documents, disks, and other materials containing proprietary or confidential information belonging to the Company. This includes without limitation, keys, credit cards, computers, vehicles, communication devices, uniforms, identification cards or badges, and any other equipment, materials, or items purchased, leased, owned, or otherwise belonging to Newport Vineyards. Upon separation, employees must return any originals or duplicates of any written or other tangible items, whether maintained in hard copy, film, or electronic medium, belonging to the Company, its subsidiaries, affiliates, successors, or assigns, including without limitation, correspondence, reports, memoranda, records, data, charts, notes, devices, specifications, drawings, customer lists, and any other item containing confidential information relating to Newport Vineyards services/care, designs, formulas, developmental or experimental work, computer programs, databases, customers/patients, marketing strategies, business plans, financial information, and employee information. These items are property of Newport Vineyards.

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The separating employee shall contact Human Resources as soon as notice is given to schedule an exit interview. The interview will be on the employee’s last day of work or another day, as mutually agreed on. After one year of employment, accrued but unused vacation leave will be paid on the next regular payday, and payable at the usual place of payment. Health insurance terminates the last day of the month of employment, unless an employee requests immediate termination of benefits. Information for COBRA continued health coverage will be provided. Employees will be required to pay their share of the dependent health and dental premiums through the end of the month. Rehire Former employees who left Newport Vineyards in good standing and were classified as eligible for rehire may be considered for reemployment. An application must be submitted to Newport Vineyards, and the applicant must meet all minimum qualifications and requirements of the position. Supervisors must obtain approval from Human Resources or designee prior to rehiring a former employee. Rehired employees begin benefits just as any other new employee. Previous tenure will not be considered in calculating longevity, leave accruals or any other benefits. An applicant or employee who is terminated for violating policy or who resigned in lieu of termination from employment due to a policy violation will be ineligible for rehire.

Workplace Safety

Accidents/Injuries In the event you become injured or witness an injury during your work hours, you are to report it immediately to the nearest available management personnel. You should report all nonfunctioning hazardous office equipment, liquid or chemical spills and leaks to your immediate supervisor.

Workers’ Compensation Newport Vineyards provides insurance for all work-related injuries or illness. The name of Newport Vineyard’s workers’ compensation insurance carrier and other pertinent information is posted. The carrier governs all insurance benefits provided by Newport Vineyards. These contracts shall not be limited, expanded or modified by any statements of Company personnel or Company documents. Any discrepancies shall be determined by reference to the insuring contracts.

Smoke-Free Workplace It is the policy of Newport Vineyards to prohibit smoking in all company buildings in order to provide and maintain a safe and healthy work environment for all employees. The law defines smoking as the "act of lighting, smoking or carrying a lighted or smoldering cigar, cigarette or pipe of any kind (including e-cigarettes)." Employees may smoke in designated smoking areas outside the building in accordance with state and local ordinances..

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Employees who violate the smoking policy will be subject to disciplinary action up to and including immediate discharge.

Drugs and Alcohol Newport Vineyards is dedicated to providing employees with a workplace that is free of drugs and alcohol. Newport Vineyards has a vital interest in maintaining safe and efficient working conditions for its employees. Substance abuse is incompatible with health, safety, efficiency, and success at Newport Vineyards employees who are under the influence of a drug or alcohol on the job compromise Company interests, endanger the employees own health and safety and the health and safety of others, and can cause a number of other work-related problems, including absenteeism and tardiness, substandard job performance, increased workloads for coworkers, behavior that disrupts other employees, delays in the completion of jobs, inferior quality in our products, and disruption of customer relations.

Alcohol Employees are prohibited from using or being under the influence of alcohol while performing company business for Newport Vineyards while operating a motor vehicle in the course of business or for any job-related purpose, or while on company premises or a worksite. Illegal Drugs Newport Vineyards employees are prohibited from using or being under the influence of illegal drugs while performing company business or while on a company facility or worksite. You may not use, manufacture, distribute, purchase, transfer or possess an illegal drug while on Newport Vineyards property, while operating a motor vehicle for any job-related purpose, while on the job, or while performing company business. This policy does not prohibit the proper use of medication under the direction of a physician; however, misuse of such medications is prohibited. Disciplinary Action Employees who violate this policy may be disciplined or terminated, even for a first offense. Violations include refusal to consent to and comply with testing and search procedures as described. Searches Newport Vineyards may conduct searches of employees and their personal property on company facilities or worksites when there is cause to believe that the employee has violated this policy or when circumstances or workplace conditions justify such a search. Such searches may be conducted at any time without prior notice. Employees are expected to cooperate fully. Employees have no reasonable expectation of privacy. Personal property may include, but is not limited to, purses, boxes, briefcases, as well as any Newport Vineyards property that is provided for employees' personal use, such as desks, lockers, and files. An employee's consent to a search is required as a condition of employment and the employee's refusal to consent may result in disciplinary action, including termination. Drug Testing To the extent allowed by applicable law, Newport Vineyards may require a test, in compliance with Rhode Island law, based on reasonable suspicion, of being under the influence of drugs or alcohol. The refusal to consent to testing may result in disciplinary action, including termination.

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Any employee found to use, sell, possess or distribute any illegal or unauthorized drugs (including excessive quantities of prescription or over-the-counter drugs) while on Newport Vineyards premises, performing Company-related duties, or while operating any Company equipment, is subject to disciplinary action, up to and including termination of employment.

Workplace Expectations

Confidentiality Electronic information technology makes confidentiality more easily compromised. Employees are responsible to respect all aspects of information confidentiality and develop a healthy suspicious to prevent being tricked into disclosing confidential information. Be suspicious if asked to ignore identification procedures. Two particular areas where employees are responsible to safeguard confidentiality and privacy are:

Employee Confidentiality: Information about employees is subject to important legal protections. No employee information may be made accessible without specific prior permission from the Human Resources Department.

Customer Confidentiality: Customer confidentiality is mandated by the professional standards of the Company. Employees are responsible to safeguard customer confidentiality at all times and in all electronic and other transactions. Customer confidentiality applies to customer names, customer information, and even the existence of the customer relationship. General Confidentiality Obligations Information that pertains to Newport Vineyards business, including all nonpublic information concerning the Company, its vendors and suppliers, is strictly confidential and must not be given to people who are not employed by Newport Vineyards. Please help protect confidential information -- which may include, for example, trade secrets, customer lists and company financial information -- by taking the following precautionary measures:

• Discuss work matters only with other Newport Vineyards employees who have a specific business reason to know or have access to such information.

• Do not discuss work matters in public places. • Monitor and supervise visitors to Newport Vineyards to ensure that they do not have access to

confidential information. • Destroy hard copies of documents containing confidential information that is not filed or

archived. • Secure confidential information in desk drawers and cabinets at the end of every business day.

Your cooperation is particularly important because of our obligation to protect the security of our clients' and our own confidential information. Use your own sound judgment and good common sense, but if at any time you are uncertain as to whether you can properly divulge information or answer questions, please consult a Newport Vineyards manager.

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Confidential Information Employees may, by virtue of their employment with the Company, obtain access to sensitive, confidential, restricted and proprietary information about the Company that is not generally known or made available to the public or competitors and that the Company has made reasonable efforts to keep confidential, including but not limited to financial records, customer or vendor records and files, referral or mailing lists, credit card numbers, and similar proprietary information whether stored electronically or in paper format. Such confidential information shall be used solely by employees in the performance of their job duties for the Company and shall not be used in any other manner whatsoever during their employment. Employees shall not, without the prior written consent of the Company, use, disclose, divulge, or publish to others any such confidential information acquired in the course of their employment. This prohibition expressly includes such information in electronic form. Such confidential information is the exclusive property of the Company and under no circumstances whatsoever shall employees have any rights to use, disclose or publish to others such confidential information subsequent to the termination of their employment.

Unauthorized use or disclosure of confidential information may result in discipline, up to and including immediate termination, prosecution, or other available action.

Upon termination of employment, employees must deliver to the Company immediately, any and all confidential information, whether stored electronically or in paper format, including but not limited to all copies of such documents prepared or produced in connection with their employment with the Company that pertain to the Company’s business or the employee’s services for the Company, whether made or compiled by the employee or furnished to the employee in connection with such services to the Company. In addition, at termination, employees must return to the Company all of the Company’s non-confidential property, documents, or electronic information. This policy does not limit the common law and statutory rights of the Company. Likewise, this policy does not limit (and will not be enforced so as to limit) an employee’s rights to discuss their terms and conditions of employment with each other or a third-party. Conflict of Interest Employees must avoid any interest, influence or relationship which might conflict or appear to conflict with the best interests of Newport Vineyards. You must avoid any situation in which your loyalty may be divided and promptly disclose any situation where an actual or potential conflict may exist. Examples of potential conflict situations include:

• Having a financial interest in any business transaction with Newport Vineyards. • Owning or having a significant financial interest in, or other relationship with, a Newport

Vineyards competitor, customer or supplier. • Accepting gifts, entertainment or other benefit of more than a nominal value from a Newport

Vineyards competitor, customer or supplier.

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Anyone with a conflict of interest must disclose it to management and remove themselves from negotiations, deliberations or votes involving the conflict. You may, however, state your position and answer questions when your knowledge may be of assistance.

Outside Activities You may engage in outside employment or personal educational activities during non-working hours, provided that such activities do not interfere with your job performance or constitute a conflict of interest. Prior to accepting outside employment, you are to notify management in writing. The notice must contain the name of the potential employer, the title and nature of the position, the number of working hours per week and the time of scheduled work hours. If the position constitutes a conflict of interest or interferes with your Newport Vineyards. job, at any time, you may be required to curtail or terminate such activity.

Electronic Assets Usage Newport Vineyards recognizes that use of the Internet has many benefits for Newport Vineyards and its employees. The Internet and email make communication more efficient and effective. Therefore, employees are encouraged to use the Internet appropriately. Unacceptable usage of the Internet can place Newport Vineyards and others at risk.

Software Policy Newport Vineyards regulates employees' use of its computer software. It is the policy of the Company to respect all computer software copyrights and adhere to the terms of all software licenses to which the company is a party. You may not duplicate any licensed software or related documentation for use, either on Company premises or elsewhere, unless expressly authorized to do so by written agreement with the licensor and with your supervisor's approval. And you may not provide licensed software to anyone outside the Company. Employees should be aware that the illegal duplication of software may result in the filing of criminal copyright charges by the owners of the copyrights and can subject both the employee and the company to liability. Only software purchased by Newport Vineyards with the approval of the appropriate management may be used on Company computers. Employees are not permitted to bring software from home and load it on Company computers, unless: (1) such action is approved by the Company’s management and technology department and (2) such use of the software is consistent with the terms of the software licensing agreements. Use of Company Communication Systems The Communication and Information Systems at Newport Vineyards should be used only for conducting company business. Communication systems include, but are not limited to cellular phones, smart phones, iPads, tablets, laptops, blackberries or more traditional devices such as phones, facsimile-machines and mailing systems. Information systems include computers, internet/intranet networks and electronic mail. Employees have no reasonable expectation of privacy when using the company communication system. Since Newport Vineyards reserves the right to access any personal communication without prior notice,

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company systems should not be used by employees to transmit any messages or to access any information that they would not want to be viewed or heard by a third party. Incidental, occasional and infrequent use of the Company’s communication and information systems for personal use is permitted as long as such use does not interfere with your work or the work of any other employee or with the computer’s operations. The communication and information systems of Newport Vineyards may not be used for any illegal, unethical, destructive or wasteful purpose. Employees should exercise care in personal use of any communication and information systems device and should not expect their use of personal information stored in these systems to be kept private. Telephone Usage The telephone system (including voicemail) at Newport Vineyards is the property of the Company and is provided for business purposes. To the extent permitted by law, Newport Vineyards may periodically monitor the use of the telephone systems to ensure compliance with this policy. Therefore employees should not consider their conversations on the Company telephone system to be private. Texting Employees’ use of texting on company issued cell phones should be limited to work-related matters, except for incidental personal use. Incidental personal use texting by employees is permitted as long as the use does not interfere with the employee’s work, the company’s operations, or use of communication facilities, and does not violate any policies. When texting from a breakroom designated area, employees are to follow company security procedures and employees should not text confidential, proprietary, or trade secret information or personnel information. Cell phones are not to be kept with the employee but placed in an area for personal belongings. Internet/Intranet and E-mail Usage The use of the Company’s information systems are subject to company policies applicable to traditional forms of communication. These include, but are not limited to, policies prohibiting discrimination, sexual harassment, solicitation, and use of company property and resources, disclosure of confidential information, misconduct and profanity. The electronic mail (e-mail) system is provided by the company to facilitate business activities within the organization. The hardware of the e-mail system is considered to be company property. All messages written, sent or received remain company property and are not considered to be private property of any employee. The information systems should not be used to upload (send) or download (receive) any trade secrets, proprietary information, copyrighted information, or any similar materials without prior authorization of company officials. The Company’s internet/intranet and e-mail systems must not be used to create disruptive or offensive messages. These may include, but are not limited to racial slurs, sexually implicative messages, or offensive comments about someone’s age, disability, national origin, political or religious belief, sexual orientation or national origin.

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Accessing files, utilizing codes or retrieving stored information is prohibited unless an employee has received prior authorization from management to conduct any such activity. Employees are also prohibited from gaining access to another employee’s e-mail unless permission was granted to do so. Unsolicited Messages Newport Vineyards strictly prohibits the transmission of unsolicited e-mails or mass-messages of any kind. Spam (i.e., unsolicited commercial or bulk e-mails, mass and junk e-mails) will not be tolerated. The electronic mail system is reserved for Company business. It may not be used for personal solicitation or any other improper purposes. Use of the Company’s communication and information systems constitutes consent to the Company’s Communication and Information Systems policy. Use of Social Media Policy Newport Vineyards acknowledges the growing popularity of social media as a means for sharing experiences, ideas, and opinions. However, the Company also strives to protect itself, its employees, and third parties such as affiliates, vendors, and business partners from the improper or unlawful use of social media. For purposes of this policy, "Social Media" are any type of internet-based media created through social or group interaction, where individuals primarily produce - rather than consume - the content. Examples of Social Media include: social and professional networking websites (Facebook, MySpace, LinkedIn), blogs (Twitter, industry blogs), video and image sharing websites (YouTube, Flickr, Pinterest), location-sharing websites (foursquare), consumer review websites (Yelp), virtual worlds (Second Life), and social bookmarking websites (Reddit). The lack of reference to a specific Social Media website in this policy does not limit the extent or application of this policy. Applicability This policy applies to all employees of the Company during both working and non-working hours, and regardless of whether the employee is using the Company's or the employees' computers, network, internet access, equipment, or technology. Employees must understand that the Company's other employee relations policies apply to online conduct, including use of Social Media. Keep in mind that any of your online conduct that violates Company policy, adversely affects your or your fellow employees' job performance, adversely affects the reputation or brand of the Company's residents, vendors, affiliates, or business partners, or adversely affects the Company's legitimate business interests may result in disciplinary action, up to and including termination. That being said, nothing in this Social Media policy is intended to prohibit employees from complying with or exercising their rights under any applicable federal state, or local law, or from communicating about wages, hours, or other terms and conditions of their or their co-workers' employment. If you have any questions about this policy or its applicability, please contact Human Resources. Newport Vineyards has and will continue to expand the promotion of its brand via Social Media, including through its official pages on (Facebook, Twitter, and LinkedIn). The Company encourages employee participation in its effort to promote its brand via Social Media. Such participation may include commenting on the Company’s Facebook, Twitter, and LinkedIn pages,

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providing internal suggestions and input for the content of such pages, and submitting your photos of the Company’s promotions, and events for inclusion on such pages. Suggestions, input, and photo submissions should be sent to the Marketing Director. Employees who create content or use Social Media for the Company’s business purposes as part of their job responsibilities and/or at the direction of the Company must understand that they are contributing content on behalf of the Company (and, therefore, representing the Company). Employees who create or contribute content to Company-created, sponsored, sanctioned, or assigned Social Media accounts or pages must understand that the Company (and not the employee) is the owner of all content contributed and connections made through these pages or accounts. These employees must adhere to the following guidelines: Guidelines Employees who choose to use Social Media for personal or professional reasons must adhere to the following guidelines:

• Use caution and your best personal and professional judgment when contributing content about or related to the Company, or third parties such as vendors, affiliates, or business partners.

• Do not engage in behavior or contribute content that could be considered an act or threat of violence, bullying, or unlawful discrimination or harassment.

• Do not intentionally or negligently contribute content that could damage the reputation or brand of the Company or interfere with the Company's business relationships with its vendors, affiliates, or business partners.

• Employees may not contribute content in the name of the Company, on behalf of the Company, or in a manner that could reasonably be attributed to the Company without prior written authorization from management.

• Do not contribute or disclose any content or information about or related to the Company, its employees, vendors, affiliates or business partners that you know to be false. Do not defame the Company's vendors, affiliates, or business partners.

• Do not contribute content that could identify Company vendors, affiliates, or business partners without prior consent from the Company.

• As a Company employee, you have access to proprietary information about the Company and its vendors, affiliates, or business partners. The Company trusts and expects you to keep this information confidential; you may not disclose it in Social Media. Note that "proprietary” includes the Company’s: (patents, copyrights, trade secrets, and inventions; internal processes, policies, and reports; source code and computer programs in various stages of development; competitive analysis and strategy; marketing and development plans; potential or actual mergers and acquisitions; resident and client lists; and names of vendors and suppliers).

• Do not use Company logos or trademarks for commercial gain without prior consent from the Company.

• Do not use your Company email address to register for personal Social Media. • Do not allow Social Media use to interfere with your work commitments, performance, or

productivity. • Consider whether connecting to the Company's business partners, vendors, or competitors via

Social Media is appropriate for your level, position, responsibilities within the Company, and relationship with the person at issue. To the extent that you do connect to Company business partners, vendors, or competitors via Social Media, consider using available privacy filters or settings to block any inappropriate, unprofessional, or personal content from such people.

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• Requests for employment references or recommendations through Social Media, such as LinkedIn, should be referred to the Human Resources.

Information Security & Use of Technology Resources Newport Vineyards considers information as one of the Company's major assets and desires to protect such information from misuse, destruction and unauthorized access. The goal and objective of this policy is to protect the Company's information assets by establishing employee responsibility for the security and appropriate use of the Company's information.

Unless otherwise indicated, the term “information” is construed broadly to mean both digital and print information that is used or created in the course of serving our customers or conducting business. It also refers to the information technology and systems that transmit and store and manipulate the information itself.

• Employees are individually responsible for understanding and adhering to the security rules of the systems they use and all aspects of this policy.

• Employees are required to take all reasonable precautions to protect information and information systems against unauthorized access, use, disclosure, modification, duplication or destruction. Employees are to use information only as appropriate for their job responsibilities. Posting photographs, videos or other images of Newport Vineyards employees, customers, business partners, affiliates or vendors without their written permission is prohibited.

• Employees are responsible to use available mechanisms and procedures to protect their own data and data under their control and they are responsible for assisting and cooperating in the protection of the systems they use.

• Employees and third parties acting for or at the direction of the Company must comply with applicable law and contract rights pertaining to the use and security of systems and information.

• Employees who have access to internal and/or public networks are expected to use all such resources: lawfully, by obeying all laws relating to electronic activity, confidentiality, copyrights, licenses and contractual agreements; respectfully, by using network access in a responsible and informed manner, conforming to network etiquette and customs; and responsibly, by not abusing Company computer resources for non-work related activities.

• Use of the Company's network resources is a privilege that may be revoked or lead to disciplinary actions including, but not limited to, any of the following reasons: any use of the network that results in personal profit; forwarding of chain letters; the excessive downloading of files for personal use, entertainment, or other non-business uses; the communication, generation or storage of offensive information; and/or violation of any of the policies stated herein.

A climate of open information sharing is desirable. However, when information is restricted, access is to be granted on a clear, business need-to-know basis. Access to information does not imply or confer authority to act as a spokesperson for the Company concerning that information or to discuss that information with others.

• Information will be retained and made available to authorized third party sources with proper approval and control in accordance with legal and contractual obligations.

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• Attempting unauthorized access to any computer, network or facility, whether internal or external to the Company, is prohibited.

• Passwords should be kept confidential and changed regularly.

Use of Personal Computing Devices Employees should be aware of proper data propagation, including but not limited to USB flash drive use. Only Newport Vineyards issued USB Flash Drives (soon to be biometric and given on an absolutely needed basis) are to be used on a need to use basis. All other data propagation is to strictly remain between Newport Vineyards owned nodes over TCP/IP. Plugging mobile phones/tablets via USB should be prohibited with use of corporate / Newport Vineyards nodes. The Newport Vineyards network as a whole allows appropriate data traffic flow from client/server and client/client communications and should be used as such without the need for external data storage media.

Use/Storage of Non-Business Related Audio/Video Files At no point shall an associate attempt to play or store on the computer provided to them any multimedia file (MP3, WMA, MPG, etc.) that is not business related. This is to ensure that all systems are fully operational and responsive without the need for unnecessary upgrades due to degradation of performance from their use. Any computer / network directory that shown to have any files listed above will be identified and deleted when discovered.

Phone Usage Newport Vineyards’ telephones are for business purposes only.

All Newport Vineyards employees are required to be professional and conscientious at all times when using company phones and to refrain from excessive usage of personal cell phones during working hours, including texting and downloading of web content. Cell phones are to be used in designated areas determined by the manager.

Personal Property Newport Vineyards is not liable for lost, misplaced or stolen property. You should take all precautions necessary to safeguard your personal possessions. You should refrain from having your personal mail sent to Newport Vineyards because mail may be automatically opened.

Your work area and any other Company property are subject to inspection and/or search at any time, with or without notice. Desks and office areas are to be kept as neat and organized as possible.

Attendance/Tardiness Your attendance is a major concern of Newport Vineyards. Unsatisfactory attendance, including tardiness and leaving work early, is unacceptable performance. You will be rated in your performance appraisal in the categories of attendance and punctuality.

If you are ill, injured or an unexpected emergency arises which prevents you from coming to work, you must find a replacement and notify your manager before the start of your scheduled work day. The manager must approve the change. If you know that you are going to be late for your shift, you must call

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and speak directly with your manager. If your manager is not available, you should contact a member of management. If you are physically unable to contact Newport Vineyards, you should direct another person to make the contact on your behalf. Leaving a message with a fellow staff employee is not considered proper notification.

When you call in absent, you are to advise Newport Vineyards of your expected date of return. Management reserves the right to require proof of illness, injury or accident, including a doctor’s statement(s) or notice(s), for any temporary disability.

Repeated absences, excessive absences (excused or unexcused) or a pattern of absences are unacceptable job performance. If you are absent for three (3) consecutive days and have not provided proper notification, Newport Vineyards will assume that you have abandoned your position and you may be treated as having voluntarily terminated your employment with Newport Vineyards.

If you become ill at work, notify your supervisor immediately. If you are unable to perform your job task, you will be either sent to a doctor or your home. You will be paid only for time actually worked and may receive paid sick time if eligible.

You shall be at your workstation, prepared to begin work at the start of your scheduled work time or resumption of your work duties. If you are not, you will be considered tardy. Excessive tardiness, whether excused or unexcused, constitutes unacceptable work performance.

Attire and Grooming It is important for all employees to project a professional image while at work by being appropriately attired. Newport Vineyards employees are expected to be neat, clean and well-groomed while on the job and may be required to wear a uniform. Clothing/uniform must be clean, pressed and in good shape. Torn, wrinkled, dirty or frayed clothing is not appropriate. Conservative clothing that covers undergarments is required. Jeans are acceptable provided they meet the criteria outlined. Skirts should be of modest length. Employees who have direct contact with customers and guests must create an image that enhances the overall perception of Newport Vineyards. No facial or tongue piercings or visible tattoos are acceptable. Newport Vineyards is confident that employees will use their best judgment regarding attire and appearance. Management reserves the right to determine appropriateness. Any employee who is improperly dressed will be counseled or in severe cases may be sent home to change clothes. Continued disregard of this policy may be cause for disciplinary action, which may result in termination.

Business Gifts We want at all times to avoid the appearance of impropriety in the acceptance of gifts from business contacts or clients. It is the express policy of Newport Vineyards that you are prohibited from, either directly or indirectly, asking, demanding, exacting, soliciting, or seeking, anything of value for yourself or for any other person or entity.

It is the express policy of Newport Vineyards that you are prohibited from, either directly or indirectly, accepting, receiving, or agreeing to receive anything of value for yourself or for any other person or entity (other than your pay check from Newport Vineyards) for or in connection with any transaction or

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business of Newport Vineyards that has a value of $25 or more. If you are promised, offered, or given anything of value from any member, prospective member, customer, or prospective customer for or in connection with any transaction or business of Newport Vineyards you are to advise your immediate supervisor at once.

Compensation

Hours of Work The standard workweek for Newport Vineyards’ tasting room, retail store and restaurant is Monday through Sunday.. The normal workweek for a full-time employee will consist of over 30 hours.

Newport Vineyards office hours are 8:30 a.m. to 5:00 p.m., Monday through Friday. Office staff are expected to be at your desks, ready to work at 8:30 a.m., unless an alternative work schedule has been arranged with management.

Schedules Newport Vineyards’ tasting room and retail store is open to the public seven days a week year round, but may have seasonal hours or closings. Tasting room employees must be available to work during normal business hours, weekends, some holidays and occasional evenings. Part-time employees must complete a schedule request form no later than three weeks before the calendar month. Some seasonal shut down may occur based on business needs. The schedule week begins on Monday and ends on Sunday. Schedules will usually be posted by 5:00 pm on the preceding Wednesday. Schedule requests must be submitted to the manager by the end of the day on Friday. Shift changes must be recorded in the shift change book and require the signatures of both employees, as well as, a manager’s approval and signature.

Pay Periods The standard work week for Newport Vineyards will begin on Monday and end at midnight the following Sunday.

The designated pay period for all employees in the winery is bi-weekly, and weekly for the restaurant and cafe. Paychecks are direct deposited on the Friday following the one or two-week period.

Pay Adjustments All pay increases are at the sole discretion of the Company and based upon merit and market factors, in accordance with applicable wage laws.

Your pay also may be adjusted downward. Salary decreases may take place due to job restructuring, job duty changes, job transfers, unsatisfactory performance or adverse business economic conditions.

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Overtime Newport Vineyards complies with all applicable federal and state laws with regard to payment of overtime work. Paid holidays are included in the forty hours for overtime calculations. Generally, exempt employees are not eligible to be compensated for overtime. Employees must obtain permission from the appropriate authority prior to working overtime. If you are eligible for overtime pay or extra pay you must maintain a record of the total hours you work each day. These hours must be accurately recorded on a timesheet that will be provided to you. Each employee must sign his or her timesheet to verify that the reported hours worked are complete and accurate (and that there is no unrecorded or “off-the-clock” work). Your timesheet must accurately reflect all regular and overtime hours worked, any absences, early or late arrivals, early or late departures and meal breaks. All employees must punch their own time card. An employee found to be punching another employee’s card will be subject to immediate termination. When you receive each pay check, please verify immediately that you were paid correctly for all regular and overtime hours worked each workweek. Corrections to timecards may only be handled by a supervisor.

Deductions Newport Vineyards makes mandatory deductions from all employee paychecks in accordance with current Federal and State Laws. Each employee must complete necessary forms with the Human Resources Manager regarding dependency status and report any changes if they occur.

Compensation It is our policy and practice to accurately compensate employees and to do so in compliance with all applicable state and federal laws. To ensure that you are paid properly for all time worked and that no improper deductions are made, you must record correctly all work time and review your online pay stub promptly to identify and to report all errors. You also must not engage in off-the-clock or unrecorded work.

We make every effort to ensure our employees are paid correctly. Occasionally, however, inadvertent mistakes can happen. When mistakes do happen and are called to our attention, we promptly will make any correction that is necessary. Please review your online pay stub to make sure it is correct. If you believe a mistake has occurred or if you have any question, please report the mistake to a member of management or Human Resources immediately.

Performance Evaluation Periodically, you will receive an appraisal of your job performance. Your Manager will evaluate your performance based on some of the following criteria:

• Job Knowledge • Customer Service/Hospitality • Quality of Work/Productivity • Creativity and Initiative • Attendance/Punctuality • Employee Relations • Adherence to Policy

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• Attitude

If in this appraisal you are given an evaluation sheet or other written document, you will be required to sign it. Your signature does not necessarily indicate that you agree with all the comments, but merely that you have had the opportunity to examine the evaluation and fully discuss the contents of it with your supervisor. The completed and signed evaluation form will be placed in your personnel file. You will receive a copy of the performance evaluation.

Promotions Newport Vineyards is most interested in providing maximum opportunity for your advancement within the Company if advancement opportunities are available. Accordingly, present employees of Newport Vineyards may be considered for promotions and may be preferred for promotion before any new employees are hired to fill vacancies that may arise. The Company retains sole discretion to determine the factors to be applied in any promotion decision and the relative weight of these factors.

Work Assignments In addition to specific duties that may accompany an individual’s job responsibilities, each job also includes "and other assigned duties". From time to time, you may be required to perform duties or tasks of a fellow employee who is absent or for a position that is temporarily vacant. You will be compensated at your regular rate of pay while performing other assigned duties on a temporary basis, unless overtime is warranted and approved. Meal/Rest Periods The scheduling of meal periods at Newport Vineyards is set by the employee’s immediate manager with the goal of providing the least possible disruption to company operations. If you wish to waive your meal period, please contact your Manager.

Mandatory Meal Period Employee meal periods are important to company productivity and employee health. Employees who work at least six (6) consecutive hours will be provided a twenty (20) minute unpaid meal period, and a thirty (30) minute unpaid meal period with an eight (8) hour shift. The meal period will not be included in the total hours of work per day and is not compensable. Nonexempt employees are to be completely relieved of all job duties while on meal breaks and must document meal periods. If the employee would like to voluntarily request to waive the meal period, a “Voluntary Waiver of Meal Break” form may be obtained from your manager and completed by the employee. The signed waiver form will be kept in your Personnel File. Impermissible Use of Meal Period: The meal period may not be used to account for an employee's late arrival or early departure or to cover time off for other purposes.

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Employee Meals Discounts on employee meals and staff purchases are posted periodically. Please see your manager for details.

Time Off/Leaves of Absence

Newport Vineyards observes the following holidays per year: New Year's Day Veterans Day Memorial Day Independence Day Labor Day Victory Day Columbus Day Thanksgiving Day Christmas Day Food Service staff is excluded from holiday pay per state law.

Vacation Employees who work at least 30 hours per week and have worked for The Company for a year, earn paid vacation. The purpose of a vacation benefit is to give you time away from the job for rest and relaxation. You should plan to take all the vacation you anticipate earning during the calendar year in which you earn it. Vacation time may not be carried over to the new calendar year. Any vacation accrued but not taken will be forfeited at the end of each calendar year.

Vacations must be scheduled in writing with reasonable advance notice, but at least 5 working days in advance, using the “Time Off Request Form” and must be approved by your immediate supervisor. Vacation may be taken in as little as 4 hour increments.

Generally, no more than one (1) week of vacation time will be granted to an employee at one time. Requests for vacation may be denied for a variety reasons.

Vacation accrual begins upon employment and is calculated as of January 1st. There are 2 steps of vacation accrual as follows:

Step 1 – Following the completion of one year of employment working a minimum of 30 hours per week, vacation time begins to accrue as of Jan.1 following the one-year anniversary. The accrual rate is .4174 of a day per month for twelve months totaling five (5) days of vacation.

Step 2 – From the start of the second calendar year , vacation earned is 2 work-weeks (10 days maximum). Vacation accrues at a rate of .835 of a day per month for twelve months totaling ten (10) days of vacation.

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If you have been employed at least a year and termination of employment occurs after vacation has accrued, but not used, the accrued vacation pay will be included in the employee's final paycheck. In the event an employee terminates after taking unearned vacation time, the unearned time taken will be deducted from the final paycheck, in accordance with applicable law.

Military Leave An employee who is a member of the reserve corps of the armed forces of the United States or of the National Guard or the Naval Militia will be granted temporary leave of absence for up to 30 days without pay while engaged in military duty as required by state employment law. A letter from your commanding officer is required to establish the dates of duty. The Uniformed Services Employment and Reemployment Rights Act (USERRA) protects the job rights of individuals who voluntarily or involuntarily leave employment positions to undertake military service or certain types of service in the National Disaster Medical System. USERRA also prohibits employers from discriminating against past and present members of the uniformed services, and applicants to the uniformed services. Reemployment Rights You have the right to be reemployed in your civilian job if you leave that job to perform service in the uniformed service and:

• You ensure that your employer receives advance written or verbal notice of your service; • You have five years or less of cumulative service in the uniformed services while with that

particular employer; • You return to work or apply for reemployment in a timely manner after conclusion of service;

and • You have not been separated from service with a disqualifying discharge or under other than

honorable conditions. If you are eligible to be reemployed, you must be restored to the job and benefits you would have attained if you had not been absent due to military service or, in some cases, a comparable job. Health Insurance Protection

• If you leave your job to perform military service, you have the right to elect to continue your existing employer-based health plan coverage for you and your dependents for up to 24 months while in the military.

• Even if you don't elect to continue coverage during your military service, you have the right to

be reinstated in your employer's health plan when you are reemployed, generally without any waiting periods or exclusions (e.g., pre-existing condition exclusions) except for service-connected illnesses or injuries.

State Law Additionally, state law provides that an employee who has worked for the Company for at least 12 months and for at least 1,250 hours in the last year and is the spouse or parent of a person called to military service lasting longer than 30 days is entitled to 15 days of unpaid family military leave during the time federal or state orders are in effect. Employees must give 14 days’ notice of the intended date upon which the family military leave will begin if the leave will consist of five or more consecutive work days. An employee cannot take this leave unless he or she has exhausted all accrued vacation leave,

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personal leave, compensatory leave, and any other leave that may be granted to the employee, except sick leave and disability leave. State law also provides that employees who are members of the state National Guard are entitled to all the rights, protections, provisions, and immunities provided by USERRA. Medical Leave of Absence

Family Medical Leave (FMLA) The Family and Medical Leave Act (“FMLA”) provides eligible employees the opportunity to take unpaid, job-protected leave for certain specified reasons. The maximum amount of leave an employee may use is either 12 or 26 weeks within a 12-month period depending on the reasons for the leave. EMPLOYEE ELIGIBILITY:

To be eligible for FMLA leave, you must:

• have worked at least 12 months for the Company in the preceding seven (7) years (limited exceptions apply to the seven-year requirement);

• have worked at least 1,250 hours for the Company over the preceding 12 months; and • currently work at a location where there are at least 50 employees within 75 miles.

All periods of absence from work due to or necessitated by service in the uniformed services are counted in determining FMLA eligibility. CONDITIONS TRIGGERING LEAVE:

FMLA leave may be taken for the following reasons:

• birth of a child, or to care for a newly-born child; • placement of a child with the employee for adoption or foster care; • to care for an immediate family member (employee’s spouse, child, or parent) with a

serious health condition; • because of the employee’s serious health condition that makes the employee unable to

perform the employee’s job; • to care for a Covered Service member with a serious injury or illness related to certain

types of military service (up to 26 weeks) (see Military-Related FMLA Leave for more details); or,

• to handle certain qualifying exigencies arising out of the fact that the employee’s spouse, son, daughter, or parent is on covered active duty or call to covered activity

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duty status in the Uniformed Services (see Military-Related FMLA Leave for more details).

The maximum amount of leave that may be taken in a 12-month period for all reasons combined is 12 weeks, with one exception. For leave to care for a Covered Service member, the maximum combined leave entitlement is 26 weeks, with leaves for all other reasons constituting no more than 12 of those 26 weeks. DEFINITIONS: A “Serious Health Condition” is an illness, injury, impairment, or physical or mental condition that involves either an overnight stay in a medical care facility, or continuing treatment by a health care provider for a condition that either prevents the employee from performing the functions of the employee’s job, or prevents the qualified family member from participating in school or other daily activities. Subject to certain conditions, the continuing treatment requirement includes an incapacity of more than three full calendar days and two visits to a health care provider or one visit to a health care provider and a continuing regimen of care; an incapacity caused by pregnancy or prenatal visits, a chronic condition, or permanent or long-term conditions; or absences due to multiple treatments. Other situations may meet the definition of continuing treatment. IDENTIFYING THE 12-MONTH PERIOD: The Company measures the 12-month period in which leave is taken by the “rolling” 12- month method, measured backward from the date of any FMLA leave with one exception. For leave to care for a covered service member, the Company calculates the 12-month period beginning on the first day the eligible employee takes FMLA leave to care for a covered service member and ends 12 months after that date. FMLA leave for the birth or placement of a child for adoption or foster care must be concluded within 12 months of the birth or placement. USING LEAVE: Eligible employees may take FMLA leave in a single block of time, intermittently (in separate blocks of time), or by reducing the normal work schedule when medically necessary for the serious health condition of the employee or immediate family member, or in the case of a covered service member, his or her injury or illness. Eligible employees may also take intermittent or reduced-scheduled leave for military qualifying exigencies. Intermittent leave is not permitted for birth of a child, to care for a newly-born child, or for placement of a child for adoption or foster care. Employees who require intermittent or reduced-schedule leave must try to schedule their leave so that it will not unduly disrupt the Company's operations. USE OF ACCRUED PAID LEAVE: During your leave, you are required to use accrued paid leave (such as sick leave, vacation, or PTO), concurrently with your FMLA leave. In order to substitute paid leave for FMLA leave, an eligible employee must comply with the Company’s normal procedures for the applicable paid-leave policy (e.g., call-in procedures, advance notice, etc.).

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MAINTENANCE OF HEALTH BENEFITS: If you and/or your family participate in our group health plan, the Company will maintain coverage during your FMLA leave on the same terms as if you had continued to work. You will be required to pay your share of health plan premiums within 30 days. Nonpayment of the employee’s portion of benefits beyond this time will result in a termination of benefits. FAILURE TO RETURN AFTER FMLA LEAVE: Any employee who fails to return to work as scheduled after FMLA leave or exceeds the 12-week FMLA entitlement (or in the case of military caregiver leave, the 26-week FMLA entitlement), will be subject to the Company’s standard leave of absence and attendance policies. This may result in termination of employment. At the end of your FMLA leave, the Company’s obligation to maintain your group health plan benefits will end and COBRA will be extended. OTHER EMPLOYMENT: The Company generally prohibits employees on FMLA or other leaves of absence from working at another job. Violations of this policy may result in disciplinary action, up to and including immediate termination of employment. FRAUD: Providing false or misleading information or omitting material information in connection with an FMLA leave will result in disciplinary action, up to and including immediate termination. Employees who have completed 12 consecutive months of employment with the Company and work an average of 30 hours or more each week are entitled to 13 consecutive weeks of unpaid leave to care for their own serious medical condition or that of a family member, or for childbirth or adoption for parental within two consecutive calendar years. Employees are entitled to continuation of benefits in accordance with applicable law. RI Family and Medical Leave Leave entitlement for eligible employees is up to thirteen (13) weeks of unpaid leave in a two-year period which may be used for the birth of your child, the adoption of a child under the age of 16 or due to your serious illness or that of a spouse, civil union partner, child, parent or parent-in-law. You must provide at least 30 day notice of your need for leave, except in the case of a medical emergency. This notice must include your intended date of departure, the length of your parental or family leave, and the expected date of your return. This notice must also include a certification from your family member’s treating health care provider establishing your medical eligibility for this leave. This notice should be provided to Human Resources. You are entitled to return to your former position or to a similar position of equivalent seniority, status, employment benefits, pay and other terms and conditions of employment. This leave may run concurrently with the Federal Family and Medical Leave Act and/or any other leave where permitted by state and federal law.

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RI Temporary Caregiver Insurance (TCI) This mandatory insurance covers every employee and provides a weekly benefit, up to four weeks in a benefit year, if you are needed to care for a newborn, newly adopted child,or sick relative (e.g., child, spouse, domestic partner, parent, parent-in-law, or grandparent) for more than seven consecutive days. A premium is deducted from your salary from each paycheck. Further information is available in the Human Resources Department. Please note that determination for qualification is determined by the Rhode Island Department of Labor and Training at 401-462-8420. It is the employee’s responsibility to contact RIDLT to determine qualification requirements for TCI coverage. RI Temporary Disability Insurance (TDI) This mandatory insurance covers every employee and provides a weekly benefit if you are disabled, unable to work for more than seven consecutive days and are qualified. Further information is available in the Human Resources Department. Please note that determination for qualification is determined by the Rhode Island Department of Labor and Training (TDI) at 401-462-8420.It is the employee’s responsibility to contact TDI to determine qualification requirements for TDI coverage. In addition all employees are covered by the provision of the Rhode Island Temporary Disability Act. Jury Service Leave Employees of Newport Vineyards called for jury duty will be granted an unpaid leave of absence in accordance with applicable law. You must inform your manager within three days of your receipt of notice to appear for jury duty. Upon completion of jury duty, a verification of attendance form from the court must be provided to the Human Resources Department. If you are excused from jury duty for the day, or are excused early, please contact your manager.

Employees appearing as a plaintiff, a defendant or for a non-subpoenaed court appearance must do so on their own personal, unpaid time.

Witness Leave If you are requested to serve as a witness on behalf of Newport Vineyards, you will be granted a witness leave at regular pay for such time as it is necessary to comply with a subpoena. Paid witness leave shall not be granted to an employee subpoenaed as an expert witness, as a party in a case, or as a lay witness other than as delineated above.

Bereavement Leave A full-time employee of Newport Vineyards you may request a leave of absence with pay for a maximum of three (3) consecutive working days upon the death of a member of his or her immediate family. Members of the immediate family are defined as: father, mother, spouse, domestic partner, child, sister, brother, father-in-law, or mother-in-law. Proof of death may be required. School Involvement Leave Under Rhode Island law, an employee is allowed up to 10 hours per year to attend school conferences or school related activities for a child of whom the employee is the parent, foster parent or guardian; and any "qualifying exigency" arising out of the fact that the spouse, son, daughter or parent of the

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employee is on active duty, or has been notified of an impending call to active duty status, in support of a contingency operation.

Benefits Eligible Newport Vineyard employees are provided with a wide range of benefits. A number of the programs (such as Social Security, Workers Compensation, and Unemployment Insurance) cover all employees in the manner prescribed by law. Some benefit programs require contributions from employees, and others are fully paid by Newport Vineyards. The following benefit programs are available to eligible Newport Vineyard employees:

• Health/Dental Insurance Plans • Simple IRA

For more information regarding benefits programs, please refer to the company Summary Plan Descriptions, which are provided to employees upon hire, or contact Human Resources. The provisions of the Plan Documents will govern the terms of any benefits.

Medical and Dental Insurance Full-time regular employees are entitled to benefits under Newport Vineyard’s medical and dental insurance plans, as may be in effect from time to time. Newport Vineyards reserves the right to change or terminate medical plans or other benefits at any time.

Full-time employees are eligible for coverage on the first day of the month following successful completion of the sixty (60) day probationary period or by reaching 1,560 hours of work in a year from the date of hire. Employees have up to 30 days prior to coverage to make medical, dental plan elections. Once made, elections are fixed for the remainder of the plan year. Changes in family status, as defined in the Plan document, allow employees to make midyear changes in coverage consistent with the family status change. Please contact Human Resources to determine if a family status change qualifies under the Plan document and IRS regulations. At the end of each plan year during open enrollment, employees may change medical, dental elections for the following plan year. Human Resources is available to answer benefits plan questions and assist in enrollment as needed.

Continuation of Benefits (COBRA) The right to continuation coverage for group health benefits was created by a federal law, the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA). COBRA continuation coverage can become available to you when you would otherwise lose your group health coverage. It can also become available to other members of your family who are covered under the group health plan when they would otherwise lose their group health coverage.

If You Have Questions

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Questions concerning your Plan or your COBRA continuation coverage rights should be addressed to the contact identified below:

Cornerstone Group 931 Jefferson Blvd. Suite 3001 Warwick, RI 02886 1-800-678-17000

Employee Handbook Acknowledgement

I have received a copy of the Newport Vineyards’ Employee Handbook. I understand that I am responsible for reading and understanding the personnel policies and procedures described within. If I do not understand any portion of this Handbook after reviewing it, I will inform the Human Resources immediately so he or she can clarify its policies and procedures. I will take particular care when reviewing the Anti-Harassment and Complaint Procedures and will ask questions about them if they contain provisions I do not understand.

I agree to abide by the policies and procedures contained within. I understand that the policies and benefits contained in this employee handbook may be changed, modified or deleted at any time, except that the Company will not modify its policy on employment at-will. I understand that neither this Handbook nor any other communication by Newport Vineyards, Management, Human Resources or any other individual is intended to create a contract of employment.

I understand that either I or the Company may terminate my employment, at any time, with or without notice.

If I have questions regarding the content or interpretation of this handbook, I will bring them to the attention of the Employer or Human Resources.

This Handbook is intended to be used only as a guideline and for information. Its provisions are not conditions of employment and may be changed at any time, with or without notice. The policies contained in the Handbook are not intended as a contract of employment. All employment is at will, and may be terminated by Newport Vineyards at any time, with or without notice, at any time, for any reason or for no reason, at Newport Vineyards’ sole discretion. I understand that under the applicable law, provisions contained in an employee handbook do not imply a term or condition of employment and do not constitute an employment contract. I agree to follow its reporting procedures and agree to inform the appropriate parties immediately if I have any concerns about my wages, discrimination, harassment, bullying or financial irregularities.

Employee Name: Date:__________________________

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Employee’s Signature: __________________________________________________________________

Anti-Harassment Policy Acknowledgement

Newport Vineyards is committed to providing work environment free from intimidation and harassment and strictly prohibits such behavior, in addition to prohibiting retaliation against anyone complaining about harassment or discrimination. Abuse of the dignity of anyone through ethnic, racist or sexist slurs or through other derogatory or objectionable conduct is offensive employee behavior. If you harass another employee of Newport Vineyards or applicant to Newport Vineyards because of race, religion, color, sex, gender, sexual orientation, pregnancy, age, national origin, ancestry, gender identity or expression, physical or mental disability, medical condition, marital status, ethnicity, alienage, genetic status, veteran status or any other protected classification, in accordance with applicable federal, state, and local laws, you will be subject to disciplinary action, including discharge. Likewise, if you feel you have been the object of harassment or intimidation based upon the aforementioned, you are to immediately follow the normal Complaint Procedure outlined later in this Handbook. In the event of sexual harassment, Employees may elect to follow either the normal Complaint Procedure or the Sexual Harassment Reporting Procedure found below.

What is Sexual Harassment?

Sexual harassment is a form of sex discrimination, which includes gender-based harassment of a person of the same or opposite sex as the harasser. It is the express policy of Newport Vineyards that sexual harassment of employees or applicants, by you or agents of Newport Vineyards, are unacceptable and will not be tolerated. Unwelcome or unwanted sexual advances, requests for favors or other visual, verbal or physical conduct will be deemed sexual harassment when:

• Submission to such conduct is explicitly or implicitly a condition of employment; • Submission to or rejection of such conduct is used as the basis of employment decisions; and • Such behavior has the purpose or effect of unreasonably interfering with an individual's work

performance or creating an intimidating, hostile or offensive work environment.

Whether a particular action or incident is a purely personal, social relationship without a discriminatory employment effect requires a factual determination. Newport Vineyards further recognizes that

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allegations of this type of discrimination may have serious effects on innocent women and men. Therefore, Newport Vineyards has devised two procedures to process a sexual harassment complaint. First, the normal Complaint Procedure as set forth herein may be utilized. Second, if the employee desires confidentiality, the following procedure may be requested.

Filing a Discrimination/Harassment Complaint with Newport Vineyards It is the goal of this policy and its procedures to create an environment in which people that have experienced harassment or who have concerns about harassment or discrimination issues will feel free to discuss those concerns with someone in a position to do something about them. Upon receipt of a complaint, either oral or written, an investigation will be undertaken and prompt corrective action will be taken wherever necessary. If your initial complaint is oral, we may ask you to write down all the details, including facts, the names of individuals involved, and the names of any witnesses, if applicable, in order to assist in the investigation. Prompt reporting is important, as it allows Newport Vineyards to investigate while the facts are fresh and to take prompt corrective action. If you believe that you have been the victim of discrimination, harassment, or offensive communications you should use the following complaint procedure: Newport Vineyards designates, Human Resources, to serve as its Investigative Officer for sexual harassment, discrimination and retaliation issues. If you have a complaint of sexual harassment and/or retaliation, you should contact Human Resources, who may appoint a designee to assist in handling sexual harassment /retaliation complaints. Each employee is responsible for cooperating in any investigation of alleged harassment if requested to do so by the person conducting the investigation. All employees have the responsibility and duty to report any incidents of harassment to a member of management or designee, in order to allow Newport Vineyards to investigate and take corrective action as soon as possible in order to ensure that such incidents will not occur again. Any employee who has knowledge of such behavior and fails to report it is subject to disciplinary action. All employees have the explicit responsibility and duty to report any sexual, racial, ethnic, or other harassment of our employees. Failure to report will subject that person to disciplinary action. Those investigating for Newport Vineyards will preserve the confidentiality of facts and identities as much as practical. Those making a complaint or participating in an investigation are expected to maintain appropriate confidentiality and to act professionally and discreetly at all times. Retaliation or reprisal against any employee for making such a complaint or for filing any discrimination charge is strictly prohibited. Similarly, retaliation or reprisal against any employee participating in good faith in an investigation of a harassment complaint is strictly prohibited. Anyone found to have engaged in such wrongful behavior will be subject to appropriate discipline, which may include termination. I hereby affirm that I have read, understand and agree to abide by the foregoing Anti-Harassment Policy:

Employee Name: Date:__________________________

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Employee’s Signature: __________________________________________________________________