Last Updated on October 8, 2020

About this Handbook
About Spytec GPS
 Mission
 Purpose
 Our Story
 Vision
 Values

General Employment Policies and Practices
 Equal Employment Opportunity
 Your Employment Relationship with the Company
 Recruitment and Hiring
  Employee Referral Program
 Employment Classifications
  Exempt Employees
  Non-Exempt Employees
  Full-Time Employee
  Part-Time Employee
  Temporary Employee
 Orientation and Training
 Immigration Law Applicable to All Employees
  Serious Misconduct
 Hours of Work
  General
  Customer Support
 Flex Time
  General
  Customer Support
 Telecommuting
 Overtime Hours
 Meal and Rest Periods
 Attendance and Punctuality
   Customer Support Team Attendance
 Inclement Weather
 Dress Code and Public Image
 Work Space
 Company Equipment
 Personnel Records
 Performance Reviews, Salary Reviews
 Internet Access
  Right to Monitor
  Responsibilities and Obligations
  Violation of this Policy
 Email
  Confidentiality of Electronic Mail
 Social Media
 Employee Privacy
 Internet Phones and Cell Phones
 Smoking
 Drug-Free Workplace
 Safety and Accident Rules
  Workplace Violence Prevention Policy
 Promotions and Transfers
 Non-Solicitation Policy
Company Sponsored Charitable Initiatives and Causes

Anti-Discrimination & Harassment
 Discrimination Is Prohibited
 Americans with Disabilities Act
  Disabled Defined
  Reasonable Accommodation
 Accommodation for Pregnant Employees
 Lactation Break Facilities and Accommodations
  Breaks
  Multi-Purpose Space
  Accommodation Request Procedure
 Workplace Harassment
  Sexual Harassment
   What Is “Sexual Harassment”?
   Examples of sexual harassment
   Retaliation
   Reporting Sexual Harassment
   Supervisory Responsibilities
   Complaint and Investigation of Sexual Harassment
   Legal Protections and External Remedies
    Civil Rights Act of 1964
    NY State Human Rights Law (New York Employees)
    Local Protections
    Contact the Local Police Department

Compensation
 Equal Pay
 Payroll Practices
 Pay Increases
 Salary Deductions and Withholding
  Taxes
  Insurance
 Direct Deposit

Benefits
 General
 Employee Contributions
 Late Applicants
 Medical Insurance
 Open Enrollment
 Special Enrollment
 Continuation of Health Coverage
 Health Care Flexible Spending Account (FSA)
 Dental Insurance
 Vision Insurance
 Workers' Compensation Insurance
 Other Benefits
 Profit-Sharing and Defined Benefits
 Fitness Allowance
  Tax Treatment
  Approval and Payment Process
 Charitable Gift Matching
  Approval Process
 Educational Assistance Program
  Qualified Education Expense Criteria
  Approval and Payment Process
 Coworking Stipend
  Eligible Employees
  Approval and Payment Process
 Travel, Lodging, and Entertainment

Holidays, Vacation and Other Leave
 Religious Observance
 Holiday Pay
 Paid Time Off (PTO)
 Family and Medical Leave (FMLA)
 State-Mandated Paid Family Leave and Other Unpaid Family Care, Medical and Military Family Leave (New York and California Employees Only)
  How Paid Family Leave Is Funded
   California Employees
   New York Employees
  Requesting Leave
  Eligibility
   California Employees
   New York Employees
  Entitlement
   New York Employees
   California Employees
  Permissible Uses
   California Employees
  Substitution of Paid Leave
  Amount of Leave
   California Employees
   New York Employees
  Effect on Pay
  Effect on Benefits
 Paid Parental Leave (Other States)
 Military Service Leave
 Break Time for Nursing Mothers
 Jury Duty
 Voting Leave
 Appearance as a Witness
 Bereavement
Additional Policies
 Separation from Employment

This Employee Handbook (“Handbook”) is a compilation of personnel policies, practices and procedures currently in effect at Spytec GPS, Inc (“Company”).



The Handbook is designed to introduce you to our Company, familiarize you with Company policies, provide general guidelines on work rules, benefits and other issues related to your employment, and help answer many of the questions that may arise in connection with your employment.



This Employee Handbook is not a contract. Like most American companies, Spytec GPS, Inc generally does not offer individual employees formal employment contracts with the Company. This Handbook does not create a contract, express or implied, guaranteeing you any specific term of employment, nor does it obligate you to continue your employment for a specific period of time. The purpose of the Handbook is simply to provide you with a convenient explanation of present policies and practices at the Company. This Handbook is an overview or a guideline. It cannot cover every matter that might arise in the workplace. For this reason, specific questions regarding the applicability of a particular policy or practice should be addressed to the Human Resources Representative.



The Company reserves the right to modify any of our policies and procedures, including those covered in this Handbook, at any time. We will seek to notify you of such changes by email and/or other appropriate means. However, such a notice is not required for changes to be effective.

We relentlessly pursue building the best location-based tools to provide peace of mind to our customers. Spytec GPS is focused on simplifying our customers’ lives by helping them keep track of what’s important to them, whether they’re a parent ensuring their child makes it safely to school or a global enterprise ensuring the security of its fleet.

Our purpose is to build the highest impact location-based tools & services that ensure our customers receive the sense of security they deserve, whether they are an individual or a global enterprise.

After the chaos of the September 11th attacks, New Yorkers’ sense of security was turned upside down and there was heavy demand for products that could help provide peace of mind. From this environment, our company has grown over the years by solving the pain points of everyday citizens. We’ve grown from a small brick-and-mortar in midtown Manhattan to a global GPS leader by addressing the difficulties of living in an uncertain yet ever-changing technological world. Over the years we have built a team of experts from around the world with the shared vision of creating the highest quality location-based security solutions which address each customer’s specific needs, with our ultimate goal of being a go-to, always-reliable GPS partner.

We tirelessly work to deliver the highest standard of quality around GPS tracking at every touch point in the customer journey, whether it be the digital experience, our hardware, or interactions with our knowledgeable support staff. Our north star is focusing on how our technology can best serve the customers’ end goals.

As a GPS tracking company we are more heavily shaped by the problems we solve than the products that we sell. Applications of our technology are ever-evolving and we will continue to focus our resources and energy towards solving both novel and all-too-common location-based problems to achieve our end goal of providing peace of mind to our consumers.

We whole-heartedly embrace and promote these seven core values in all aspects of our business:

1. Customer-focus - We keep a minimal distance between ourselves and our customers. We walk in our customers’ shoes. Constant research and applying feedback across our organization ensures we focus on what and who are most important to our business.

2. Expertise - We aren’t just experts in our products, brand, or technology. We are experts around the entire domain of our customers’ problems and potential solutions.

3. Simplicity - We only show the customer what is most valuable to them. While very complex work goes on behind the scenes, we take extra steps to package only the most relevant information in an easily digestible manner.

4. Empathy - We don’t just sell gadgets to a faceless audience. We provide solutions for problems that deserve careful attention and sensitivity, whether business or personal, and this instills in us a certain responsibility.

5. Progress - Leadership in our industry doesn’t come from following a set of rules. We do not rely on our competition to guide us. Rather, we move forward by listening to our customers and constantly working on improving all aspects of our business.

6. Integrity - We act with integrity, doing the right thing even if that comes at a short-term loss. We gain our customers’ trust not by telling them to trust us, but by showing them how they can trust us.

7. Flexibility - We meet our customers where their needs are. Whether this means designing a malleable architecture for our software to allow for developing novel, customized solutions or traveling across the country to consult prospective clients at their headquarters, our flexibility helps us better understand and serve our customers.

The Company is an equal opportunity employer. We will extend equal opportunity to all individuals without regard to race, religion, color, sex (including pregnancy, sexual orientation and gender identity), national origin, disability, age, genetic information, employee’s or dependent’s reproductive or sexual decision health-making, hair/hairstyle or any other status protected under applicable federal, state, or local laws. Our policy reflects and affirms the Company’s commitment to the principles of fair employment and the elimination of all discriminatory practices. Details of our equal employment opportunity policies are further explained in Anti-Discrimination & Harassment below.

While we hope you have an excellent experience and lasting relationship with us, we are required to explain that employment with the Company is “at will.” This means that you or the Company may end your employment at any time for any lawful reason.

We also need to explain that...



This Employee Handbook is not a contract. It does not create any agreement, express or implied, guaranteeing you any specific terms or conditions of employment. Nothing contained in this Handbook should be construed as creating a contract guaranteeing employment for any specific duration, nor does the Handbook obligate you to continue your employment for a specific period of time. Unless you have entered into an employment agreement that supersedes this document, either you or the Company may terminate the employment relationship at any time. The Handbook does not guarantee any prescribed process for discipline and discharge.

No manager or other representative of the Company, other than the CEO, COO and VP of Operations, have the authority to enter into any agreement guaranteeing employment for any specific period. No such agreement shall be enforceable unless it is in writing and signed by the authorized signer and the employee.

Spytec GPS seeks to hire the highest caliber candidates for our open positions. The Company’s primary goal when recruiting new employees is to fill vacancies with persons who have the best available knowledge, skills, abilities or experience needed to perform the work. Decisions regarding the recruitment, selection and placement of employees are made on the basis of job-related criteria and business needs.



Because we hire and train the best, we like to promote from within whenever possible. When positions become available, qualified current employees are encouraged and are welcome to apply for open positions via our career page, and to let their supervisors know that they have applied.

At Spytec GPS, our greatest asset is our incredible team. As we continue to grow, we want to ensure that we hire the best talent that will enhance and align with our culture and vision. We know you know great people, and we want to partner with you to help us find the best candidates for our open positions.

If you know someone who would be a good addition to our team and they meet the qualifications of one of our open positions, you may be eligible to receive a referral reward if they are hired. Please see the specific program eligibility, reward amount and instructions Instructions found on the HR Wiki page here: Employee Referral Program Policy and Employee Referral Program Instructions.

The following terms will be used to describe employment classifications and status:

Exempt employees are not subject to the minimum wage or overtime pay provisions of the federal Fair Labor Standards Act (FLSA). An exempt employee is one whose specific job duties and salary meet all of the requirements of the U.S. Department of Labor’s regulations. In general, an exempt employee is one who is paid on a salary basis at not less than $684 per week who holds an administrative, professional, or management position. Certain outside sales people and a few other job categories are also exempt. Where state and / or local laws require a greater salary basis, the salary basis most favorable to the employee will be observed.

Salaried employees who are not administrative, professional, or managerial employees (as defined by the U.S. Department of Labor) and many hourly employees are generally not exempt from the FLSA’s minimum wage and overtime provisions.

Full-time employees are those who are regularly scheduled to work at least 30 hours per week that are not hired on a temporary basis.

Part-time employees are those who are regularly scheduled to work fewer than 30 hours per week that are not hired on a temporary basis. Part-time employees are not eligible for Company paid benefits, with the exception of the 401(k) plan, except as required by law. (Any employee over age 21 who has worked with the company for at least 3 months may participate in the 401(k) plan). 

Employees hired for an interim period of time, usually to fill in for vacations, leaves of absence, or projects of a limited duration. Temporary employees are not eligible for Company paid benefits, except as required by law. 

To help you become familiar with the Company and our way of doing things, the Company will provide an orientation and training session within the first few days after you begin work. Some of the content of the session will depend in large part on the nature of your responsibilities, while other parts will be applicable to all employees. In addition, the Company may periodically offer additional training or educational programs. Some programs may be voluntary, while others will be required.

The Company complies with the Immigration Reform and Control Act of 1986 by employing only U.S. citizens and non-citizens who are authorized to work in the United States. All employees are asked on their first day of work to provide original documents verifying the right to work in the United States and to sign a verification form required by federal law (Form I-9). If you cannot verify your right to work in the United States within three (3) days of hire, the Company is required by law to terminate your employment.

Depending upon business needs, the company may choose to sponsor H1B Visa holders. Foreign, non-immigrant employees hired under an H1B Visa are required to maintain their work authorization and to alert the company immediately if their work authorization is revoked.

Spytec GPS seeks to promote an environment characterized by mutual respect that is free from conflicts of interest, dishonesty, harassment, gossip and violations of company policy or of the law. The Company expects ethical behavior on the part of all employees.

Examples of ethical behavior include, but are not limited to:

• Telling on yourself promptly when you make a mistake;

• Supporting and encouraging your coworkers;

• Reporting any known or observed policy violations to your supervisor immediately;

• Adhering to the company’s attendance policy;

• Working directly with a coworker to politely resolve a misunderstanding or conflict with the coworker;

• Accurately recording all hours worked;

• Accurately and honestly completing paperwork, applications, online forms, etc.

• Disclosing any potential conflicts of interest (e.g. ownership, employment or stock in a competing company, family relationship with a vendor, etc.)

• Honestly answering any lawful questions and complying with all lawful requests made by your supervisor or management;

• Reporting any known or observed safety hazard or employee injury immediately (or as soon as is safely possible);

• Doing your part to ensure the workplace is free from harassment by refraining from inappropriate or discriminatory behavior;

• Conducting yourself in a manner that does not violate any laws, regulations or company policies.

Failure to adhere to the above standards or to any part of this handbook will be considered a violation of this policy..

Certain ethical violations are considered serious misconduct that may result in immediate termination of employment. Serious misconduct includes but is not limited to: Theft, assault, harassment, dishonesty, fraud, falsifying time records, destroying company property or deliberately causing financial harm to the company or a customer of the company.

The workweek is generally from Monday through Friday, with employees working within normal operating hours of 9:00 AM to 7:00 PM, with a reasonable break time for lunch. 

The Customer Support team operates in a 24 X 7 call center environment. The workweek for the Customer Support team is based upon each team member’s individual schedule. While we strive to provide team members with their ideal shifts, schedules are subject change based upon business needs.

The Company recognizes that many employees need flexibility in work schedules in order to meet child care and other needs. Core business hours are between 9:00 AM and 7:00 PM and all employees should be at work within those hours. Depending on the nature of your position, you may be required to work specific times (e.g. 9:00 AM-6:00 PM). Some employees may be approved to have flex time, where they are permitted to work any 8 hours as long as the 8 hours overlap most of the normal business hours (e.g. 8:00AM-5:00PM or 10:00AM-7:00PM). Approval of flex time will be at management’s discretion.

Due to the nature of our business and the needs of our customers, Customer Support team members are not eligible for flex time. We will, however, make efforts to accommodate team members’ requests for schedule changes wherever possible.

The Company also offers some employees the opportunity to telecommute. Supervisors may approve certain types of employees to telecommute, provided that individual performance levels are maintained.Not all jobs are suitable for telecommuting, however. Some positions, such those on the Warehouse and Customer Support teams, are not generally eligible for telecommuting.

All Company policies, including but not limited to those contained in this handbook also apply to all remote employees while teleworking.

Employees who are issued company equipment will be asked to complete an Acknowledgement of Receipt of Company Property form, and must agree to safeguard Company equipment.

Typically, non-exempt employees will not be permitted to telework, however, should a non-exempt employee be approved to telework temporarily, the non-exempt employee must still properly record all hours worked.

Employees who are approved to work remotely will be reimbursed for reasonable, approved business expenses.

Injuries sustained while teleworking must still be reported to Human Resources immediately, in accordance with our safety and workers’ compensation policies.

Overtime is paid to non-exempt, hourly employees at 1 ½ times employees’ regular rate of pay for any hours worked over 40 in a workweek. The workweek for payroll purposes runs from Saturday to Friday. All hours worked over 40 hours from Saturday to Friday will be paid at 1 ½ your regular rate of pay.

Only hours worked count towards overtime hours. Holiday pay, PTO, jury duty, bereavement or any other type of paid time that are not hours worked are not counted in overtime calculations. Paid breaks 20 minutes or less in length (e.g. two 15 minute stretch breaks) are considered compensable work time and that time is included when calculating overtime.

All overtime must be approved in advance by your supervisor before it is worked. This approval should be in writing (e.g. Slack or email) and not just verbal. If there is an urgent work issue that must be addressed that results in overtime, you must let your supervisor know as soon as possible. Failure to get proper approval prior to working overtime may result in disciplinary action.

All employees (exempt and non-exempt) are required to take a meal break of at least 30 minutes around noontime. If you work outside of normal business hours or perform shift work, contact your Human Resources Representative for your specific meal break requirements. Employees may not choose to opt out of their required meal breaks. Additional rest periods may be permitted at the discretion of your direct supervisor. Non-exempt employees are required to clock in and out from all meal and rest period breaks via the time and attendance app, TSheets.

It is important for you to report to work on time and to avoid unnecessary absences. The Company recognizes that illness or other circumstances beyond your control may cause you to be absent from work from time to time. However, frequent absenteeism or tardiness may result in disciplinary action up to and including discharge. Excessive absenteeism or frequent tardiness puts an unnecessary strain on your co-workers and can have a negative impact on the success of the Company.



You are expected to report to work when scheduled.

Whenever you know in advance that you are going to be absent, you should:

• notify your immediate supervisor or the designated manager,
• submit a time off request through the Company’s Payroll/benefits system, Justworks,
• make sure your out of the office (OOO) Slack and email notifications are turned on, if applicable, and
• review your work calendar and cancel or reschedule any meetings that were planned for the day(s) of your absence. 


If your absence is unexpected, you should:

• attempt to reach your immediate supervisor as soon as possible, but in no event later than one hour before you are due at work.
  • In the event your immediate supervisor is unavailable, you must speak with a manager.
  • If you must leave a voicemail, you must provide a number where your supervisor may reach you if need be. 
• If possible, you should also still
  • make sure your out of the office (OOO) Slack and email notifications are turned on, if applicable and
  • review your work calendar and cancel or reschedule any meetings that were planned for the day(s) of your absence.
• For unexpected absences, you must still submit your time off request through Justworks upon your return to work.

Please note that some, but not all, absences are compensated under the Company’s leave and benefits policies.



You are expected to be at your workstation at the beginning of each business day. If you are delayed, you must call your immediate supervisor to state the reason for the delay. As with absences, you must make every effort to speak directly with a manager. Due to the extreme strain that tardies, unapproved early departures and unapproved absences place on the business, repeated offences may result in termination of employment.

Our Customer Support team has a separate attendance policy, which is detailed below. Adherence to all scheduled days & shifts is a critical component to delivering a WOW customer experience. Each absence, tardiness, or incomplete shift results in a customer who has to wait longer for a resolution to their problem and the burden of additional workload is absorbed by the other members of the team. Simply put, maintaining sound attendance practices results in a win for the business, our agents, and most importantly, the customers.

Ample Warning
We understand that life happens, and you may not be able to make it for your shift. In cases where you are ill or have a personal situation keeping you from clocking in for your shift, we ask that you provide notice at least two hours prior to the start of your shift. Failure to do so puts undue stress on the team with urgent schedule changes and last minute adjustments.

Documentation
If your absence is due to illness, generally a doctor’s note would not be necessary. If you miss three or more consecutive days, leadership may ask for documentation from a doctor’s office.

If you’re working from home, stable resources (i.e. power & internet) are a requirement to conduct the requirements of the job. If your absence is due to technical limitations (i.e. power or internet outages) while working from home, we may require documentation from the service provider acknowledging the outage in your area.

Special attendance considerations will be made for “State of Emergency” situations (i.e. extreme weather, health pandemics, etc).

Ample Warning
Tardiness & Partial Shift Missed are defined as missing more than ten minutes of your shift. Examples include:

• Starting late
• Leaving early
• Returning late from lunch / break
• Clocking out before your shift ends

The nature of these situations are typically different from a full day's absence. Leadership asks that you contact them as soon as you know you may need to miss part of your shift. For example, if there was a traffic incident on your way to work and you will miss the start of your shift, a text message explaining the situation 20-30 minutes before the start of your shift would suffice.

Acceptable Occurrences
Spytec GPS operates under the belief that, as a professional, you’ll do what’s in the best interest of your health, the business, and our customers. If there is a trend of attendance issues, leadership reserves the right to administer disciplinary action, up to and including separation of employment.

Special Considerations

• Agents are encouraged to “trade shifts” with another agent if there is a pre-planned absence or special need requiring a partial or fully missed shift. Both parties agreeing to the shift trade must document their approval with an email to leadership.
• Agents may make up missed time within the same pay period with manager's approval. This is not considered a “shift trade” and the original absence / tardiness would still be documented.

The Company is open for business unless there is a government-declared, weather-related state of emergency or unless you are advised otherwise by your supervisor. There may be times when we will delay opening, and on rare occasions, we may have to close. Use common sense and your best judgment when traveling to work in inclement weather.

In the event that the Company’s facilities are closed by the Company or the government due to inclement weather, employees will be paid for the first day of closure. Subsequent days of closure will be charged to (1) paid time off (PTO) or (2) unpaid time off, in that order If the Company’s facilities are open and you are delayed getting to work or cannot get to work at all because of inclement weather, the absence will be charged to (1) paid time off (PTO) or (2) unpaid time off, in that order. You should always use your judgment about your own safety in getting to work.  Salaried employees who have the ability to work remotely, may do so during inclement weather if they are approved to do so by their supervisor.

When severe weather develops or is anticipated to develop during the day and a decision is made by the Company to close before the end of your scheduled workday, you will be compensated as if you had worked to the end of your regularly scheduled hours for that day. If you elect to leave prior to the time the Company closes, you will be required to use paid time off (PTO) in an amount equal to the number of hours between the time you left and the time the office closed.

As an employee of the Company, we expect you to present a clean and professional appearance when you represent us, whether you are in or outside of the workplace. You are, therefore, required to dress in appropriate business attire and to behave in a professional, businesslike manner. It is essential that you act in a professional manner and extend the highest courtesy at all times to co-workers, visitors, customers, vendors and clients. A cheerful and positive attitude is essential to our commitment to extraordinary customer service and exceptional quality. 
 

The current Company dress code is casual attire. Generally, clean, neat clothing is acceptable. However, torn jeans or other torn clothing and tee shirts with inappropriate verbiage or pictures are not appropriate casual attire. As always, please use common sense in your choice of business attire.


It is the intent of this policy to comply with applicable state, local and federal laws prohibiting discrimination on the basis of color, race, religion, sex (including pregnancy, sexual orientation and gender identity), national origin, disability, age, genetic information and any other status protected under such laws.

Employees are responsible for maintaining the workspace assigned to them. A clean, orderly workspace provides an environment conducive to working efficiently. Employees should keep in mind that their workspace is part of a professional environment that portrays the Company’s overall dedication to providing quality service to its customers. Therefore, your workspace should be clean, organized and free of items not required to perform your job. 

Certain equipment is assigned to staff depending on the needs of the job, such as a headset, personal computer, printer and access to our central computers and servers. This equipment is the property of the Company and cannot be removed from the office without prior approval from your supervisor. It is expected that you will treat this equipment with care and report any malfunctions immediately to staff members equipped to diagnose the problem and take corrective action.

Certain employees who are equipped with laptops or other high-value company property will be required to sign an acknowledgement of receipt.

Separate employees who telecommute (or who otherwise have company equipment in their possession) must ship back any company-issued equipment, postmarked within 3 business days of separation from employment.

It is important that the Company maintain accurate personnel records at all times. You are responsible for updating your personal information by logging into Justworks and making any needed changes to your name, email, home address, telephone number, marital status, number of dependents, immigration status, or any other pertinent information. By making any needed updates in a timely manner, you will avoid compromise of your benefit eligibility, the return of W-2 forms, or similar inconvenience.

The contents of your personnel file are the property of Spytec GPS, Inc. and must be maintained for government and company record keeping purposes. Employees are welcome to view the contents of their personnel files anytime. You will either be able to view the contents of your personnel file in Justworks, or you may view them by requesting access to them from Human Resources.

Some documents related to your employment may not be part of your personnel file, such as notes on an investigation. These files will generally be maintained separately, and access to these types of files would be restricted as permitted by state and local laws.

All files connected with an employee are considered strictly confidential, and access will be limited only to those who have a job-related need to know the information and who have been authorized to see the file in question. For example, your supervisor would have access to view your resume, credentials, performance reviews and corrective actions, but your supervisor would not have access to your payroll or benefits documents.

Personnel files will be maintained in accordance with all applicable legal requirements.

At Spytec GPS we value open communication and two-way feedback. It is important to us that you have the tools you need to succeed, and performance reviews are a great way to ensure that both employees and supervisors express their expectations. While more formal performance reviews may take place annually, Spytec GPS strives to have on-going informal communications about your performance. An employee's first formal performance review will generally take place within the first 3 months of employment with the Company (e.g. 30, 60, 90-day reviews). All performance reviews will be completed in writing by your supervisor or manager on the form designated by the Company, and reviewed during a conference with you. Factors considered in your review include the quality of your job performance, your attendance, meeting the requirements of your job description, dependability, attitude, cooperation, compliance with Company employment policies, any disciplinary actions, and year-to-year improvement in overall performance. Compensation increases are not guaranteed, but may be given by the Company at its discretion in consideration of various factors, including your performance review.

Access to the Internet is given principally for work-related activities or approved educational / training activities. Incidental and occasional personal use and study use is permitted. This privilege should not be abused and must not affect the employee’s performance of employment-related activities.

The Company email and Internet system is at all times the property of the Company. By accessing the Internet, Intranet and electronic mail services through facilities provided by the Company, you acknowledge that the Company (by itself or through its Internet Service Provider) may from time to time monitor, log and gather statistics on employee Internet activity and may examine all individual connections and communications. Please note that the Company uses email filters to block spam and computer viruses. These filters may from time to time block legitimate email messages. If required for your access level or job role, you must only access company information via the designated company VPN.

Employees may not access, download or distribute material that is illegal, or which others may find offensive or objectionable, such as material that is pornographic, discriminatory, harassing, or an incitement to violence. 

You must respect and comply with copyright laws and intellectual property rights of both the Company and other parties at all times. When using web-based sources, you must provide appropriate attribution and citation of information to the websites. Software must not be downloaded from the Internet without the prior approval of qualified persons within the Company. Employees must follow IT’s policy on only maintaining their passwords via 1Password, the company’s designated password management tool.

In all circumstances, use of Internet access and email systems must be consistent with the law and Company policies. Violation of this policy is a serious offense and, subject to the requirements of the law, may result in a range of sanctions, from restriction of access to electronic communication facilities to disciplinary action, up to and including termination. 

The email system is the property of the Company. All emails are archived on the server in accordance with our records retention policy, and all emails are subject to review by the Company. You may make limited use of our email system for personal business matters, so long as such use is kept to a minimum and does not interfere with your work.

The Company email system is Company property, and as such, is subject to monitoring. System monitoring is done for your protection and the protection of the rights or property of the provider of these services. Please consider this when conducting personal business using Company hardware and software.

Electronic mail is like any other form of Company communication, and may not be used for harassment or other unlawful purposes. Your email account is a Company-provided privilege, and is Company property. Remember that when you send email from the Company domain, you represent the Company whether your message is business-related or personal. 

As noted above, electronic mail is subject at all times to monitoring, and the release of specific information is subject to applicable laws and Company rules, policies and procedures on confidentiality. Existing rules, policies and procedures governing the sharing of confidential information also apply to the sharing of information via commercial software. 

The term “social media” includes all means of communicating or posting information or content of any sort on the Internet, including to your own or someone else’s web log or blog, journal or diary, personal website, social networking or affinity website, web bulletin board, or a chat room, whether or not associated or affiliated with the Company, as well as any other form of electronic communication. The same principles and guidelines found in the Company rules, policies and procedures apply to an employee’s social media activities online.

Any conduct that adversely affects an employee’s job performance or the performance of fellow employees, or otherwise adversely affects the Company’s legitimate business interests, may result in disciplinary action, up to and including termination. Similarly, inappropriate postings, including but not limited to discriminatory remarks, harassment and threats of violence or similar inappropriate or unlawful conduct will not be tolerated and may result in disciplinary action, up to and including termination. However, this restriction will not apply to any postings made in the exercise of any rights granted to an employee by federal law.

In this age of the Internet where privacy has become an increasing concern, we take your privacy very seriously. The privacy and security of your personal data (the “Personal Information”) which we collect from you is important to us. It is equally important that you understand how we handle this data. The Company will not knowingly collect or use Personal Information in any manner not consistent with this policy, as it may be amended from time to time, and applicable laws.


In the course of conducting our business and complying with federal, state, and local government regulations governing such matters as employment, tax, insurance, etc., we must collect Personal Information from you. The nature of the information collected varies somewhat for each employee, depending on your employment responsibilities, the location of the facility where you work, and other factors. We collect Personal Information from you solely for business purposes, including those related directly to your employment with the Company, and those required by governmental agencies.


The primary purposes for collection, storage and/or use of your Personal Information include, but are not limited to: 

• Human Resources Management. We collect, store, analyze, and share (internally) Personal Information in order to attract, retain, and motivate a highly qualified workforce. This includes recruiting, compensation planning, succession planning, reorganization needs, performance assessment, training, employee benefit administration, compliance with applicable legal requirements, and communication with employees and/or their representatives. 

• Business Processes and Management. Personal Information is used to run our business operations including, for example,  scheduling work assignments, managing Company assets, reporting and/releasing public data (e.g., annual reports, etc.); and populating employee directories. Information may also be used to comply with government regulation.

• Safety and Security Management. We use such Personal Information as appropriate to ensure the safety and protection of employees, assets, resources, and communities. 

• Communication and Identification. We use your Personal Information to identify you and to communicate with you.


The Company acts to protect your Personal Information and ensure that unauthorized individuals do not have access to such information by using security measures to protect Personal Information. We will not knowingly disclose, sell, or otherwise distribute your Personal Information to any third party without your knowledge and, where appropriate, your express written permission, except where disclosure is reasonably necessary to comply with the law.




We employ reasonable security measures and technologies, such as password protection, two-factor authentication, encryption, physical locks, etc., to protect the confidentiality of your Personal Information. Only authorized employees have access to Personal Information. If you are an employee with such authorization it is imperative that you take the appropriate safeguards to protect such information. Paper and other hard copy containing Personal Information (or any other confidential information) should be secured in a locked location when not in use. Computers and other access points should be secured when not in use by logging out or locking. Passwords and user IDs should be guarded and not shared. When no longer necessary for business purposes, paper and hard copies should be immediately destroyed using paper shredders or similar devices. Do not leave copies in unsecured locations waiting to be shredded or otherwise destroyed. Do not make or distribute unauthorized copies of documents or other tangible medium containing Personal Information. Electronic files containing Personal Information should only be stored on secure computers and cloud applications and not copied or otherwise shared with unauthorized individuals within or outside of the Company.



The Company will make reasonable efforts to secure Personal Information stored or transmitted electronically from hackers or other persons who are not authorized to access such information.



Any violation or potential violation of this policy should be reported to your immediate supervisor, designated manager, or the Employee Relations Department. The failure by any employee to follow these privacy policies may result in discipline up to and including discharge of the employee. Any questions or suggestions regarding this policy may also be directed to your immediate supervisor, designated manager, or the Employee Relations Department.

Access to the Company internet phone system is given principally for work-related activities or approved educational / training activities. Incidental and occasional personal use is permitted. This privilege should not be abused and must not affect the employee’s performance of employment-related activities.  Internet phone usage should be based upon cost-effective practices that support the Company’s mission and should comply with applicable rules and regulations.



Not all job roles are permitted to be in possession of personal devices, including cell phones while performing their job duties (e.g. Customer Service team members). Other employees should use common sense and their best judgment when making or receiving personal cellular phone calls at work. To the extent possible, employees should make personal cell phone calls during their breaks or lunch times. The use of cameras on cell phones during work hours is prohibited to protect the privacy of the Company as well as of fellow employees. However, this restriction will not apply to any recordings made in the exercise of any rights granted to an employee by federal law.



The Company’s internet phone system is at all times the property of the Company. By accessing the phone system through facilities provided by the Company, you acknowledge that the Company has the right to monitor its phone system from time to time to ensure that employees are using the system for its intended purposes.

The Company prohibits the use of hand-held cellular devices while driving. Employees are strongly encouraged to use a hands-free cellular device while driving, should the use become a necessity in the course of employment. Sending and/or receiving text messages is expressly prohibited while operating any vehicle.

In order to provide a safe and comfortable working environment for all employees, smoking is strictly prohibited at all times inside any Company building.

The Company recognizes alcohol and drug abuse as potential health, safety and security problems. The Company expects all employees to assist in maintaining a work environment free from the effects of alcohol, drugs or other intoxicating substances. Compliance with this Drug-Free Workplace policy is made a condition of employment, and violations of the policy may lead to discipline and/or discharge.



All employees are prohibited from engaging in the unlawful manufacture, possession, use, distribution or purchase of illicit drugs, alcohol or other intoxicants, as well as the misuse of prescription drugs on Company premises or at any time and any place during working hours. While we cannot control your behavior off the premises on your own time, we certainly encourage you to behave responsibly and appropriately at all times.  All employees are required to report to their jobs in appropriate mental and physical condition, ready to work.

Substance abuse is an illness that can be treated. Employees who have an alcohol or drug abuse problem are encouraged to seek appropriate professional assistance. You may inform your immediate supervisor, designated manager, or the Human Resources Representative for assistance in seeking help to address substance abuse, who can also help you determine coverage available under the Company’s medical insurance plan.



When work performance is impaired, admission to or use of a treatment or other program does not preclude appropriate action by the Company.



Any violator of this Drug-Free Workplace policy will be subject to disciplinary action up to and including termination of employment.

Spytec complies with all federal, state and local laws regarding maintaining a safe work environment for our employees. Safety is a joint venture at the Company. We provide a clean, hazard-free, healthy, safe environment in which to work and make every effort to comply with all relevant federal, state and local occupational health and safety laws, including the federal Occupational Safety and Health Act. As an employee, you have a duty to comply with the safety rules of the Company, and you are expected to take an active part in maintaining this hazard-free environment. You should observe all posted safety rules, adhere to all safety instructions provided by your supervisor and use safety equipment where required. Your workspace should be kept neat, clean and orderly. You are required to report any accidents or injuries – including any breaches of safety – and to promptly report any unsafe equipment, working condition, process or procedure to a supervisor. In addition, if you become ill or get hurt while at work, you must notify your manager immediately.

Failure to do so may result in a loss of benefits under the state workers’ compensation law. 

Failure to abide by the Company’s safety and accident rules may result in disciplinary action, up to and including termination. 

As stated above, the Company is committed to the safety and security of our employees. Workplace violence presents a serious occupational safety hazard to our organization, staff, and clients.



Workplace violence includes any physical assault or act of aggressive behavior occurring where an employee performs any work-related duty in the course of his or her employment including but not limited to an attempt or threat, whether verbal or physical, to inflict physical injury upon an employee; any intentional display of force which would give an employee reason to fear or expect bodily harm; intentional and wrongful physical contact with a person without his or her consent that entails some injury; or stalking an employee with the intent of causing fear of material harm to the physical safety and health of such employee when such stalking has arisen through and in the course of employment.



Acts of violence by or against any of our employees where any work-related duty is performed will be thoroughly investigated and appropriate action will be taken, including involving law enforcement authorities when warranted. All employees are responsible for helping to create an environment of mutual respect for each other as well as clients and visitors, following all policies, procedures and practices, and for assisting in maintaining a safe and secure work environment. Any threats of violence or threatening or suspicious behaviors should be reported to your Supervisor, Manager or Human Resources Representative immediately.

In an effort to match you with the job for which you are most suited and/or to meet the business and operational needs of the Company, you may be transferred from your current job. This may be either at your request or as a result of a decision by the Company.



Reasons for transfer may include, but are not necessarily limited to, fluctuations in department workloads or production flow; a desire for more efficient utilization of personnel; increased career opportunities; personality conflicts; health; other personal situations; or other business reasons. Temporary transfers may be made at the discretion of the Company management.   Any employee is welcome to request a transfer and to be considered for a promotion at any time.Your eligibility for transfer for or promotion is dependent, of course, on your having the needed skills, education, experience and other qualifications that are required for the job. 

In the spirit of maintaining a work environment free of uncomfortable or inappropriate social pressures Spytec GPS requires that all staff refrain from soliciting for any outside activity or organization during work time. This includes but is not limited to soliciting donations for charitable causes during work time. Spytec GPS further defines solicitation as including verbal or written communication, raffle tickets, for-sale merchandise, e-mail distributions, circulars, handbills, or other kinds of literature.

Furthermore, staff should not use Company computer and communication systems and materials, including inter-department e-mail, instant messaging, telephone, fax, supplies, or other related company equipment for any purposes not directly related to company business and/or activities without the expressed approval of a supervisor. Posting or distribution of non-work related materials should be limited to non-work areas during non-work times. Non-work times include break periods, meal times, or other specified periods during the workday when staff are not expected to be performing their work tasks.

From time-to-time, the company may sponsor or lead initiatives by partnering with charities and promoting certain causes. When this happens, employees are encouraged to participate on behalf of the company according to the guidelines provided by management. Employees who assist with company sponsored initiatives will be compensated at their regular rate of pay for all time spent participating in approved fund-raising campaigns or volunteerism during normal work hours.

The Company is an equal opportunity employer and makes all employment decisions without regard to

• race or color,
• religion or creed,
• ethnicity,
• sex (including pregnancy, sexual orientation and gender identity),
• national origin,
• disability or presumed disability,
• age,
• military service or veteran status,
• political views, affiliation or activities,
• criminal history (prior arrests or convictions),
• familial status
• domestic victim status,
• genetic information,
• an employee’s or dependent’s reproductive or sexual decision health-making,
• protected hair/hairstyle,
• an employee’s status as one who is infected, may be infected, was previously infected, or is presently or was previously in contact with or among individuals infected with COVID-19, or are experiencing any of the signs and symptoms of COVID-19 or
• any other status protected under applicable federal, state, or local laws.

This policy applies to all terms and conditions of employment, including but not limited to, hiring, placement, promotion, termination, layoff, recall, transfer, leaves of absence, benefits, compensation and training. We seek to comply with all applicable federal, state and local laws related to discrimination and will not tolerate the interference with the ability of any of the Company’s employees to perform their job duties. 

The Company makes decisions concerning employment based strictly on an individual’s qualifications and ability to perform the job under consideration, the comparative qualifications and abilities of other applicants or employees, and the individual’s past performance within the organization. 

The Company will respect and not in any manner intrude upon an employee’s or an employee’s dependents’ reproductive health decisions. As such, the Company will not (1) access an employee’s personal information regarding the employee’s or the employee’s dependents’ reproductive health decision-making, including, but not limited to, the decision to use or access a particular drug, device or medical service, without the employee’s prior informed affirmative written consent; (2) require an employee to sign a waiver or other document which purports to deny the employee the right to make their own reproductive health care decisions, including the use of a particular drug, device or medical service; or (3) discriminate or take any retaliatory action against an employee with respect to compensation, terms, conditions, or privileges of employment regarding the employee’s or the employee’s dependents’ reproductive health decision-making. Any employee who feels there has been a violation of this policy should report their concern to Human Resources.



If you believe that an employment decision has been made that does not conform with management’s commitment to equal opportunity, you should promptly bring the matter to the attention of your immediate supervisor, designated manager, or the Employee Relations Department. Your complaint will be promptly, thoroughly and impartially investigated. There will be no retaliation against any employee who files a complaint in good faith, even if the result of the investigation produces insufficient evidence to support the complaint.

The federal Americans with Disabilities Act (ADA) prohibits discrimination against qualified individuals with disabilities in job application procedures, hiring, firing, advancement, compensation, fringe benefits, job training and other terms, conditions and privileges of employment. The ADA does not alter the Company’s right to hire the best-qualified applicant, but it does prohibit discrimination against a qualified applicant or employee because of his or her disability, or because of a perceived disability. As a matter of Company policy, the Company prohibits discrimination of any kind against people with disabilities.

An applicant or employee is considered disabled if he or she (1) has a physical or mental impairment that substantially limits one or more major life activities; (2) has a record or past history of such an impairment; or (3) is regarded or perceived (correctly or incorrectly) as having such impairment.



A qualified employee or applicant with a disability is an individual who satisfies the requisite skill, experience, education and other job-related requirements of the position held or desired, and who, with or without reasonable accommodation, can perform the essential functions of that position.

A reasonable accommodation is any change in the work environment (or in the way things are usually done) to help a person with a disability apply for a job, perform the duties of a job, or enjoy the benefits and privileges of employment.



Qualified applicants or employees who are disabled should request reasonable accommodation from the Company in order to allow them to perform a particular job. If you are disabled and you desire such reasonable accommodation, contact your immediate supervisor, designated manager, or Human Resources Representative. On receipt of your request we will meet with you to discuss your disability. We may ask for information from your health care provider(s) regarding the nature of your disability and the nature of your limitations or take other steps necessary to help us determine viable options for reasonable accommodation. We will then work with you to determine whether your disability can be reasonably accommodated, and if it can be accommodated, we will explore alternatives with you and endeavor to implement a mutually agreeable accommodation.



Reasonable accommodation may take many forms and it will vary from one employee to another. Please note that according to the ADA, the Company does not have to provide the exact accommodation you want, and if more than one accommodation works, we may choose which one to provide. Furthermore, the Company does not have to provide an accommodation if doing so would cause undue hardship to the Company.

As of January 2016, pregnant employees who work in New York have the right to reasonable accommodations for any pregnancy-related conditions, including:

• occasional breaks to rest or drink water,
• a modified work schedule,
• leave for related medical needs,
• available light duty assignments, and
• transfers away from hazardous duty.

Employees who take leave due to a pregnancy or a pregnancy-related condition, have the right to return. may not be required to remain on leave until the birth. The Company will hold pregnant employees’ jobs for them to the extent that the Company does so for employees who take leave for other reasons.

Spytec GPS will provide a reasonable amount of time for an employee to express breast milk and will not unreasonably limit the amount of time or the frequency that an employee expresses breast milk. The employee’s supervisor will speak with the employee to determine a schedule of breaks that reasonably accommodates the pumping needs of the employee.

An employee who uses their break time to express breast milk will be compensated to the same extent and in the same way that other employees are compensated for break time.

Spytec GPS has at least one designated office space at each location that serves as a lactation room when employees are using the room to express breast milk. The Company will notify other employees that the room will be prioritized as a lactation room and may only be used for expressing breast milk during the time[s] when employees need the space and will post proper signage to ensure that it is free from intrusion and shielded from view of others while being used as a lactation room. The employees who need the room for pumping will be given priority use of the room and their pumping needs will determine the availability of the room for other purposes.

The Company will ensure that the multi-purpose room can be locked from the inside so that the employee pumping can do so without intrusion. The Company will ensure that the multi-purpose room is clean, free from intrusion, and meets as many of the following requirements as possible: contains at least one electrical outlet, a surface to place a pump and other personal items, and a chair; and is near running water and a refrigerator to store breast milk.

When more than one employee needs to use the multi-purpose room to express breast milk, the Company will discuss alternative options with all employees who use the shared space to determine what arrangement addresses their needs. Options may include: finding an alternative space; sharing the space among multiple users with screens, curtains, or other privacy measures; or creating a schedule for use.

If the multi-purpose room is unavailable for use as a lactation room when an employee needs it, the Company will provide an alternative space for temporary use as a lactation room.

Even if the multi-purpose room is available, an employee who wishes to pump at their usual workspace will be permitted to do this so long as it does not create an undue hardship for the Company.

Before an employee returns from parental leave, the HR Representative will resend this policy to the employee in writing (electronically or by mail) and request information from the employee regarding the need for a reasonable accommodation to express breast milk at work.

Employees may also independently request a lactation accommodation by contacting the Human Resources Representative. A request may be made orally or in writing to the employee’s direct supervisor and should indicate that the employee will need accommodations for expressing breast milk at work.

The supervisor will consult Human Resources and will respond to a request for a lactation accommodation as quickly as possible. Under no circumstances will this amount of time exceed five (5) business days. During the time it takes to respond to a request and/or engage in a cooperative dialogue to determine the accommodation, SpytecGPS will provide a temporary accommodation to the employee so that the employee can pump in a manner that meets the employee’s immediate needs, unless that poses an undue hardship for the employer.

The company recognizes that employees’ lactation accommodation needs may change over time. Employees may request changes to their existing lactation accommodation at any point.

The Company is committed to providing a work environment that provides employees equality, respect and dignity. In keeping with this commitment, the Company has adopted a policy of “zero tolerance” with regard to employee harassment. Harassment is defined under federal law as unwelcome conduct that is based on race, color, religion, sex (including pregnancy, sexual orientation and gender identity), national origin, age (40 or older), disability or genetic information. Harassment becomes unlawful where: (1) enduring the offensive conduct becomes a condition of continued employment; or (2) the conduct is severe or pervasive enough to create a work environment that a reasonable person would consider intimidating, hostile, or abusive.



This policy applies to all terms and conditions of employment. Harassment of any other person, including, without limitation, fellow employees, contractors, visitors, clients or customers, whether at work or outside of work, is grounds for immediate termination. The Company will make every reasonable effort to ensure that its entire community is familiar with this policy and that all employees are aware that every complaint received will be promptly, thoroughly and impartially investigated and resolved appropriately. The Company will not tolerate retaliation against anyone who complains of harassment or who participates in an investigation. 

Spytec GPS is committed to maintaining a workplace free from sexual harassment. We are committed to providing a work environment that provides our employees equality, respect and dignity. Sexual harassment is a form of workplace discrimination. All employees are required to work in a manner that prevents sexual harassment in the workplace. This Policy is one component of Spytec GPS’s commitment to a discrimination-free work environment. Sexual harassment is against the law1 and all employees have a legal right to a workplace free from sexual harassment and employees are urged to report sexual harassment by filing a complaint internally with Spytec GPS Employees can also file a complaint with a government agency or in court under federal, state or local antidiscrimination laws.

Spytec GPS’s policy applies to all employees, applicants for employment, interns, whether paid or unpaid, contractors and persons conducting business, regardless of immigration status, with Spytec GPS. In the remainder of this document, the term “employees” refers to this collective group.

Sexual harassment will not be tolerated. Any employee or individual covered by this policy who engages in sexual harassment or retaliation will be subject to remedial and/or disciplinary action (e.g., counseling, suspension, termination).

Retaliation Prohibition: No person covered by this Policy shall be subject to adverse action because the employee reports an incident of sexual harassment, provides information, or otherwise assists in any investigation of a sexual harassment complaint. Spytec GPS will not tolerate such retaliation against anyone who, in good faith, reports or provides information about suspected sexual harassment. Any employee of Spytec GPS who retaliates against anyone involved in a sexual harassment investigation will be subjected to disciplinary action, up to and including termination. All employees, paid or unpaid interns, or non-employees working in the workplace who believe they have been subject to such retaliation should inform a supervisor, manager, or HR representative. All employees, paid or unpaid interns or non-employees who believe they have been a target of such retaliation may also seek relief in other available forums, as explained below in the section on Legal Protections.

Sexual harassment is offensive, is a violation of our policies, is unlawful, and may subject Spytec GPS to liability for harm to targets of sexual harassment. Harassers may also be individually subject to liability. Employees of every level, who engage in sexual harassment, including managers and supervisors who engage in sexual harassment or who allow such behavior to continue, will be penalized for such misconduct.

Spytec GPS will conduct a prompt and thorough investigation that ensures due process for all parties, whenever management receives a complaint about sexual harassment, or otherwise knows of possible sexual harassment occurring. Spytec GPS will keep the investigation confidential to the extent possible. Effective corrective action will be taken whenever sexual harassment is found to have occurred. All employees, including managers and supervisors, are required to cooperate with any internal investigation of sexual harassment.

All employees are encouraged to report any harassment or behaviors that violate this policy. Spytec GPS will provide all employees a complaint form for employees to report harassment and file complaints.

Managers and supervisors are required to report any complaint that they receive, or any harassment that they observe or become aware of, to the HR Representative.

This policy applies to all employees, paid or unpaid interns, and non-employees and all must follow and uphold this policy. This policy must be provided to all employees and should be posted prominently in all work locations to the extent practicable (for example, in a main office, not an offsite work location) and be provided to employees upon hiring.

Sexual harassment is a form of sex discrimination and is unlawful under federal, state, and (where applicable) local law. Sexual harassment includes harassment on the basis of sex, sexual orientation, self-identified or perceived sex, gender expression, gender identity and the status of being transgender.

Sexual harassment includes unwelcome conduct which is either of a sexual nature, or which is directed at an individual because of that individual’s sex when:

• Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive work environment, even if the reporting individual is not the intended target of the sexual harassment;
• Such conduct is made either explicitly or implicitly a term or condition of employment; or
• Submission to or rejection of such conduct is used as the basis for employment decisions affecting an individual’s employment.

A sexually harassing hostile work environment includes, but is not limited to, words, signs, jokes, pranks, intimidation or physical violence which are of a sexual nature, or which are directed at an Individual because of that individual’s sex. Sexual harassment also consists of any unwanted verbal or physical advances, sexually explicit derogatory statements or sexually discriminatory remarks made by someone which are offensive or objectionable to the recipient, which cause the recipient discomfort or humiliation, which interfere with the recipient’s job performance.

Sexual harassment also occurs when a person in authority tries to trade job benefits for sexual favors. This can include hiring, promotion, continued employment or any other terms, conditions or privileges of employment. This is also called “quid pro quo” harassment. Any employee who feels harassed should report so that any violation of this policy can be corrected promptly. Any harassing conduct, even a single incident, can be addressed under this policy.

The following describes some of the types of acts that may be unlawful sexual harassment and that are strictly prohibited:

• Physical acts of a sexual nature, such as:

  • Touching, pinching, patting, kissing, hugging, grabbing, brushing against another employee’s body or poking another employee’s body;
  • Rape, sexual battery, molestation or attempts to commit these assaults.

• Unwanted sexual advances or propositions, such as:

  • Requests for sexual favors accompanied by implied or overt threats concerning the target’s job performance evaluation, a promotion or other job benefits or detriments;
  • Subtle or obvious pressure for unwelcome sexual activities.

• Sexually oriented gestures, noises, remarks or jokes, or comments about a person’s sexuality or sexual experience, which create a hostile work environment.

• Sex stereotyping occurs when conduct or personality traits are considered inappropriate simply because they may not conform to other people's ideas or perceptions about how individuals of a particular sex should act or look.

• Sexual or discriminatory displays or publications anywhere in the workplace, such as:

  • Displaying pictures, posters, calendars, graffiti, objects, promotional material, reading materials or other materials that are sexually demeaning or pornographic. This includes such sexual displays on workplace computers or cell phones and sharing such displays while in the workplace.

  • Hostile actions taken against an individual because of that individual’s sex, sexual orientation, gender identity and the status of being transgender, such as:

  • Interfering with, destroying or damaging a person’s workstation, tools or equipment, or otherwise interfering with the individual’s ability to perform the job;

  • Sabotaging an individual’s work;

  • Bullying, yelling, name-calling

Sexual harassment can occur between any individuals, regardless of their sex or gender. New York Law protects employees, paid or unpaid interns, and non-employees, including independent contractors, and those employed by companies contracting to provide services in the workplace. Harassers can be a superior, a subordinate, a coworker or anyone in the workplace including an independent contractor, contract worker, vendor, client, customer or visitor.

Unlawful sexual harassment is not limited to the physical workplace itself. It can occur while employees are traveling for business or at employer sponsored events or parties. Calls, texts, emails, and social media usage by employees can constitute unlawful workplace harassment, even if they occur away from the workplace premises, on personal devices or during non-work hours.

Unlawful retaliation can be any action that could discourage a worker from coming forward to make or support a sexual harassment claim. Adverse action need not be job-related or occur in the workplace to constitute unlawful retaliation (e.g., threats of physical violence outside of work hours).

Such retaliation is unlawful under federal, state, and (where applicable) local law. The New York State Human Rights Law protects any individual who has engaged in “protected activity.” Protected activity occurs when a person has:

• made a complaint of sexual harassment, either internally or with any anti-discrimination agency;

• testified or assisted in a proceeding involving sexual harassment under the Human Rights Law or other anti-discrimination law;

• opposed sexual harassment by making a verbal or informal complaint to management, or by simply informing a supervisor or manager of harassment;

• reported that another employee has been sexually harassed; or

• encouraged a fellow employee to report harassment.

Even if the alleged harassment does not turn out to rise to the level of a violation of law, the individual is protected from retaliation if the person had a good faith belief that the practices were unlawful. However, the retaliation provision is not intended to protect persons making intentionally false charges of harassment.

Preventing sexual harassment is everyone’s responsibility. Spytec GPS cannot prevent or remedy sexual harassment unless it knows about it. Any employee paid or unpaid intern or non-employee who has been subjected to behavior that may constitute sexual harassment is encouraged to report such behavior to a supervisor, manager or HR Representative. Anyone who witnesses or becomes aware of potential instances of sexual harassment should report such behavior to a supervisor, manager or HR Representative.

Reports of sexual harassment may be made verbally or in writing. A form for submission of a written complaint is located on the Company’s HR Wiki page, and all employees are encouraged to use this complaint form. Employees who are reporting sexual harassment on behalf of other employees should use the complaint form and note that it is on another employee’s behalf. Employees, paid or unpaid interns or non-employees who believe they have been a target of sexual harassment may also seek assistance in other available forums, as explained below in the section on Legal Protections.

All supervisors and managers who receive a complaint or information about suspected sexual harassment, observe what may be sexually harassing behavior or for any reason suspect that sexual harassment is occurring, are required to report such suspected sexual harassment to HR Representative.

In addition to being subject to discipline if they engaged in sexually harassing conduct themselves, supervisors and managers will be subject to discipline for failing to report suspected sexual harassment or otherwise knowingly allowing sexual harassment to continue.

Supervisors and managers will also be subject to discipline for engaging in any retaliation.

All complaints or information about sexual harassment will be investigated, whether that information was reported in verbal or written form. Investigations will be conducted in a timely manner and will be confidential to the extent possible.

An investigation of any complaint, information or knowledge of suspected sexual harassment will be prompt and thorough, commenced immediately and completed as soon as possible. The investigation will be kept confidential to the extent possible. All persons involved, including complainants, witnesses and alleged harassers will be accorded due process, as outlined below, to protect their rights to a fair and impartial investigation.

Any employee may be required to cooperate as needed in an investigation of suspected sexual harassment. Spytec GPS will not tolerate retaliation against employees who file complaints, support another’s complaint or participate in an investigation regarding a violation of this policy.

While the process may vary from case to case, investigations should be done in accordance with the following steps:

• Upon receipt of complaint, the HR Representative will conduct an immediate review of the allegations, and take any interim actions (e.g., instructing the respondent to refrain from communications with the complainant), as appropriate. If complaint is verbal, encourage the individual to complete the “Complaint Form” (located on the Company’s HR Wiki page and in Justworks) in writing. If he or she refuses, prepare a Complaint Form based on the verbal reporting.

• If documents, emails or phone records are relevant to the investigation, take steps to obtain and preserve them.

• Request and review all relevant documents, including all electronic communications.

• Interview all parties involved, including any relevant witnesses;

• Create a written documentation of the investigation (such as a letter, memo or email), which contains the following:

  • A list of all documents reviewed, along with a detailed summary of relevant documents;
  • A list of names of those interviewed, along with a detailed summary of their statements;
  • A timeline of events;
  • A summary of prior relevant incidents, reported or unreported; and o The basis for the decision and final resolution of the complaint, together with any corrective action(s).

• Keep the written documentation and associated documents in a secure and confidential location.

• Promptly notify the individual who reported and the individual(s) about whom the complaint was made of the final determination and implement any corrective actions identified in the written document.

• Inform the individual who reported of the right to file a complaint or charge externally as outlined in the next section.

Sexual harassment is not only prohibited by Spytec GPS but is also prohibited by state, federal, and, where applicable, local law.

Aside from the internal process at Spytec GPS employees may also choose to pursue legal remedies with the following governmental entities. While a private attorney is not required to file a complaint with a governmental agency, you may seek the legal advice of an attorney. In addition to those outlined below, employees in certain industries may have additional legal protections.

The following sections outline a few (but not all) of the applicable labor laws:

The United States Equal Employment Opportunity Commission (EEOC) enforces federal anti-discrimination laws, including Title VII of the 1964 federal Civil Rights Act (codified as 42 U.S.C. § 2000e et seq.). An individual can file a complaint with the EEOC anytime within 300 days from the harassment. There is no cost to file a complaint with the EEOC. The EEOC will investigate the complaint and determine whether there is reasonable cause to believe that discrimination has occurred, at which point the EEOC will issue a Right to Sue letter permitting the individual to file a complaint in federal court.

The EEOC does not hold hearings or award relief but may take other action including pursuing cases in federal court on behalf of complaining parties. Federal courts may award remedies if discrimination is found to have occurred. In general, private employers must have at least 15 employees to come within the jurisdiction of the EEOC.

An employee alleging discrimination at work can file a “Charge of Discrimination.” The EEOC has district, area, and field offices where complaints can be filed. Contact the EEOC by calling 1-800-669-4000 (TTY: 1-800-669-6820), visiting their website at www.eeoc.gov or via email at [email protected].

If an individual filed an administrative complaint with DHR, DHR will file the complaint with the EEOC to preserve the right to proceed in federal court.

The Human Rights Law (HRL), codified as N.Y. Executive Law, art. 15, § 290 et seq., applies to all employers in New York State with regard to sexual harassment, and protects employees, paid or unpaid interns and non-employees, regardless of immigration status. A complaint alleging violation of the Human Rights Law may be filed either with the Division of Human Rights (DHR) or in New York State Supreme Court.

Complaints with DHR may be filed any time within three years of the harassment. If an individual did not file at DHR, they can sue directly in state court under the HRL, within three years of the alleged sexual harassment. An individual may not file with DHR if they have already filed a HRL complaint in state court.

Complaining internally to Spytec GPS does not extend your time to file with DHR or in court. The one year or three years is counted from date of the most recent incident of harassment.

You do not need an attorney to file a complaint with DHR, and there is no cost to file with DHR.

DHR will investigate your complaint and determine whether there is probable cause to believe that sexual harassment has occurred. Probable cause cases are forwarded to a public hearing before an administrative law judge. If sexual harassment is found after a hearing, DHR has the power to award relief, which varies but may include requiring your employer to take action to stop the harassment, or redress the damage caused, including paying of monetary damages, attorney’s fees and civil fines.

DHR’s main office contact information is: NYS Division of Human Rights, One Fordham Plaza, Fourth Floor, Bronx, New York 10458. You may call (718) 741-8400 or visit: www.dhr.ny.gov.

Contact DHR at (888) 392-3644 or visit dhr.ny.gov/complaint for more information about filing a complaint. The website has a complaint form that can be downloaded, filled out, notarized and mailed to DHR. The website also contains contact information for DHR’s regional offices across New York State.

Many localities enforce laws protecting individuals from sexual harassment and discrimination. An individual should contact the county, city or town in which they live to find out if such a law exists. For example, employees who work in New York City may file complaints of sexual harassment with the New York City Commission on Human Rights. Contact their main office at Law Enforcement Bureau of the NYC Commission on Human Rights, 40 Rector Street, 10th Floor, New York, New York; call 311 or (212) 306-7450; or visit www.nyc.gov/html/cchr/html/home/home.shtml.

California-based employees have the right to file a complaint with the California Department of Fair Employment and Housing (DFEH) at 800-884-1684 (voice), 800-700-2320 (TTY) or California’s Relay Service at 711, or by emailing them at [email protected].

Employees working in other states should consult their state’s department of labor’s website for more information on how to report unlawful harassment to the state.

If the harassment involves unwanted physical touching, coerced physical confinement or coerced sex acts, the conduct may constitute a crime. Contact the local authorities by calling 911.

As part of our commitment to equal opportunity, we believe that all team members should receive equal pay for equal work. This means that all our team members (regardless of their gender or sexual orientation) are paid consistently for performing the same work of equivalent skill. Job performance may still be taken into account when determining pay, as well as, but not limited to, past work experiences, educational experiences, current workload and job responsibilities, etc. Other legitimate business reasons such as the going rates of pay needed to attract talent in different geographic locations may also be taken into consideration.

Employees are paid biweekly, and the workweek runs from Sunday to Saturday, with the payday falling on every other Friday. When a payroll date falls on a holiday, employees will, when possible, be paid on the last business day before the holiday. Otherwise, employees will be paid on the first business day following the scheduled payroll date.

Employees may receive pay increases based on a number of factors, such as performance, market changes or changes in job duties and increased responsibilities. Employees who receive a pay increase as part of a promotion will still be eligible to be considered for an annual performance-based pay increase. Pay increases, like bonuses are not guaranteed and are issued at management’s discretion based on company and individual performance.

The Company will withhold the following from your paycheck: 

Federal, state and local taxes, as required by law, as well as the required FICA (Social Security and Medicare) payments.

Your contribution to health insurance or other insurance premiums for yourself and any eligible family members or to other contributory benefit programs.



Other deductions which you authorize, including 401K, FSA, Commuter Benefits, Federal or State Garnishments (as required). 

Your paycheck will be deposited directly into your bank account via Justworks. Exceptions may be made as required by state law.

The Company offers medical insurance to all eligible employees. Details of the plan(s) may be found in the benefit booklets. This Handbook does not constitute such a legal document. The Company offers medical coverage for eligible employees and their eligible dependents. Your Summary Plan Description (SPD) contains more details. In the event of any conflict between the information contained in this Handbook and in the Company’s SPDs, the SPDs shall govern. The plan(s) is subject to change at the Company’s discretion.

The Company’s benefit package is contributory; that is, you are responsible for a portion of the premium for your benefits. A portion of the premium, up to a maximum per month, is contributed by the Company. Your contributory cost is deducted from your paycheck. 

At the time you are hired, you are given an opportunity to elect certain benefits. If you waive participation in any of these programs for either yourself or your eligible dependents, you will generally be allowed to apply for entry into the various plans only during Open Enrollment. This section describes the fringe benefits provided by the Company and information on your eligibility for benefits. Details regarding each benefit plan are contained in the Company’s Benefit Booklet. Benefit plans governed by the federal Employee Retirement Income Security Act (ERISA) may be further described in formal Summary Plan Descriptions or other legal documents available for your review in the Employee Relations Department.



Employees meeting the eligibility criteria for particular benefits may participate in the various insurance programs offered by the Company. You may review the eligibility criteria for each benefit in the Company’s Benefit Booklet and/or the Summary Plan Description for the particular benefit. Periodically there will be an Open Enrollment period (described below). If you decline to participate in these programs on your initial eligibility date, you may request entry into the plan during Open Enrollment or Special Enrollment (described below).

The Open Enrollment period allows employees to add or change their benefits coverage. Applications for Medical Plan, Dental Plan, Health Care Flexible Spending Account, Vision Plan, and any other employer-sponsored benefit may be submitted during this period. Changes, additions and other elections made during Open Enrollment will take effect on the effective date following the Open Enrollment period. Once you have made a change, you generally cannot change that selection until the next Open Enrollment period (except in the case of certain life events; see Special Enrollment). 

Special enrollment allows individuals who previously declined coverage to enroll in the plan upon loss of eligibility for other coverage and upon certain life events, such as marriage and the birth, adoption, or placement for adoption of a child. Employees must generally request enrollment within 30 days of the loss of coverage or life event triggering the special enrollment. For specific details regarding special enrollment, please refer to your Summary Plan Description.

Federal law generally requires employers with 20 or more employees to give employees, spouses (including same-sex spouses) and dependent children the right to continue group health benefits for limited periods of time under certain circumstances, such as voluntary or some types of involuntary job loss, reduction in hours worked, death, divorce and other life events. Employees ordinarily may continue their health coverage for up to 18 months when their employment is terminated. Separated employees who elect COBRA coverage will pay the employer and employee portions of the premiums as well as a 2% administration fee.

The Company offers a health care Flexible Spending Account (FSA) that eligible employees can use to pay for certain out-of-pocket health care costs. Please refer to the health care FSA Summary Plan Description in Justworks for an explanation of benefits and limitations.

The Company offers a dental plan for eligible employees. Please refer to the dental Summary Plan Description in Justworks for an explanation of the plan benefits and limitations.

The Company offers a vision plan for eligible employees. Please refer to the vision Summary Plan Description in Justworks for an explanation of the plan benefits and limitations.

To provide for payment of your medical expenses and for partial salary continuation in the event of a work-related accident or illness, you are covered by workers’ compensation insurance, provided by the Company and based on state regulations. The amount of benefits payable, as well as the duration of payments, depends upon the nature of your injury or illness. However, all medical expenses incurred in connection with an on-the-job injury or illness and partial salary payments are paid in accordance with applicable state law. If you are injured or become ill on the job, you must immediately report the injury or illness to the Employee Relations Department. This ensures that the Company can help you obtain appropriate medical treatment. Your failure to follow this procedure may delay your benefits or may even jeopardize your receipt of benefits. Questions regarding workers’ compensation insurance should be directed to the Employee Relations Department.

The Company offers a Profit-Sharing Plan and a Defined Benefits Plan for eligible employees. Please refer to the respective Profit-Sharing or Defined Benefits Plan Benefit Booklet and/or Summary Plan Description on the Human Resources Wiki page for additional details.

The Company will reimburse full-time employees for up to $50.00 per month towards the cost of an employee’s

• gym membership,
• fitness classes,
• sports leagues or
• personal trainer.

This is a taxable reimbursement, and employees who receive this benefit will be required to pay taxes on this benefit. The reimbursements will be added to payroll, included in gross income and will show up on tax form W2.

Eligible employees must request reimbursement by submitting receipts to substantiate their requests to [email protected] with a CC to [email protected] . Payroll will reimburse employees by Justworks payroll, coded as a taxable reimbursement. Only one $50.00 reimbursement per month per employee may be approved.

Please note that Spytec GPS will not reimburse for fitness-related activities that involve weapons (real or fake). This means things like paintball and archery would not be approved.

The Company will match up to $1,000 in charitable giving per full-time, regular employee, per calendar year for employee donations to 501(c)(3) charitable or educational nonprofits. This does not include political, social or other types of nonprofit organizations.

Employees should complete the Charitable Gift Matching Request Form and submit it along with proof of the donation amount made to HR through GoogleForms to request approval. HR will seek approval from the owners and will inform the employee whether or not their request is approved. The Company may, at the owners’ sole discretion, determine that a particular charity is not in keeping with the spirit of this policy and may decline to match donations.

The Company reimburses the cost of qualified education expenses up to $1,000 per calendar year per full-time, regular employee.

Qualified education expenses under this Educational Assistance Program include the cost of:

• Job-related courses, certifications, licenses and professional memberships that are earned in support of the business.
  • Must be able to explain the relevance of the expense to the employee’s job/employer’s business.

OR

• Courses that are part of an undergraduate or graduate degree program at an accredited university (online or brick-and-mortar).
  • Must show proof of a passing score on the employee’s transcript
  • Includes the cost of books, equipment, fees, supplies, and tuition
  • Does not need to be job-related

Prior to incurring the expense, employees should complete the Education Assistance Request Form and submit it to HR through GoogleForms. HR will seek approval from the owners and will inform the employee whether the request was approved.

This initial approval shows that the company will reimburse the employee for the particular educational assistance requested, as long as the employee adheres to the following expense reimbursement processes:

• Upon successful completion of the course, program, exam, membership enrollment or seminar, eligible employees must submit receipts to substantiate their requests by emailing them to [email protected] with a CC to [email protected]. Payroll will reimburse employees through Justworks payroll, coded as a tax-exempt reimbursement.
• Education expenses will not be approved prior to the expenses being incurred or prior to the completion of the course, exam, etc. and receipt of a passing score (if applicable).

The Company also offers certain employees a reimbursement of up to $100 per month towards the cost of renting a coworking space.

In order to be eligible to request reimbursement for the cost of a coworking space, employees must meet all of the following criteria. An employee must be

• classified as a full-time, regular employee,
• classified as exempt under the FLSA (i.e. salaried employees),
• not be required by management to work from a regular company office location (e.g. New York Office) and
• not living within a commutable distance from a regular company office location.
  • This includes employees who may be temporarily living in a location that is not a commutable distance from a regular company office location, as long as the temporary work arrangement has been approved in advance, in writing by the CEO or COO.

Eligible employees must request reimbursement by submitting receipts to substantiate their requests via email to [email protected] with a CC to [email protected] . Payroll will reimburse employees by check or direct deposit either outside of payroll or through payroll, coded as a tax-exempt reimbursement.

For information on business travel-related expenditures, mileage reimbursement and other expenses and reimbursements, please reference Spytec GPS’s Expense Policy.

Federal and state equal opportunity laws generally require employers to reasonably accommodate the sincerely held religious beliefs of employees, but do not require them to provide paid leave. The Company respects your religious beliefs, however, and therefore, will provide one (1) day of paid leave to employees who, for religious reasons, must be away from the office on days of normal operation. Employees who require additional time off may use paid time off (PTO). This leave must be requested through the department manager two weeks prior to the event.

Full-Time and Part-Time employees are currently entitled to the following 12 paid holidays:


• New Year’s Day
• Memorial Day
• Juneteenth
• Independence Day
• Labor Day
• Thanksgiving Day
• Christmas Day
• New Year’s Eve
• Christmas Eve
• 2 Floating Holidays
• Your Birthday

Holidays are paid at 8 hours for full-time employees and 4 hours for part-time employees. Half days are paid at 4 hours for full-time employees and 2 hours for part-time employees.

Non-exempt employees who work a company-paid holiday will receive double time pay for their hours worked on the holiday.

Holidays that fall on a Saturday will be observed on the preceding Friday, and holidays that fall on a Sunday will be observed the following Monday.

Rather than allocating employees separate amounts of time off for sick, vacation, and personal days, the Company provides Paid Time Off (PTO) to give employees greater flexibility to meet their personal needs. Eligible employees will be provided PTO days each year to use however they want, up to a certain amount each year. The amount of PTO earned will depend on your length of service with the Company. The Company may require you to use any accrued PTO during unpaid family and medical leave, or any other leave of absence, subject to applicable laws and regulations.

Please note that this policy does not replace the Company’s holiday schedule and employees will continue to have designated paid holidays each year in accordance with this section.


Employees’ PTO is front-loaded with a starting balance when they first begin work for the Company. PTO is prorated based on the hire date in the first year, and then the balance refreshes at the beginning of each calendar year. Employees may use their PTO for vacation at any time after the first 90 Days of employment. For sick days, PTO may be used prior to completing 90 days of employment. (Employees must have a medical need to use the hours in advance of the 90-day waiting period).



The amount of PTO that an employee is entitled to generally depends upon the career level of the employee’s job role, as well as their length of service.

Accept where otherwise required by state or local law, PTO is “use it or lose it.” This means that your balance resets at the beginning of each calendar year, and any unused PTO is forfeited as of January 1. It is important for employees to request time off as far in advance as possible so that their requests may be received timely enough to be approved.

Requests for PTO should be submitted through the Company’s Payroll/Benefits System, Justworks. The Human Resources Representative will coordinate with the Supervisor and other stakeholders to determine whether or not the leave may be approved. Both salaried and hourly employees are required to adhere to the company’s time off request procedure.

If time off is needed for a vacation or for any other foreseeable personal, non-medical issue, the company generally requires at least 30 days' advance notice, particularly for vacations more than 3 days in duration.

For unforeseeable personal time off needed, approval will be determined on a case-by-case basis according to the circumstances and business need. In all cases, the request for personal time off should be made as soon as the need for leave becomes foreseeable.

General Procedure
For medical-related requests for planned procedures, the company requires at least 7 days' notice. For other medical-related requests, the company requires as much advance notice as is reasonable/possible for the situation. At no time should an employee call out less than 2 hours before the employee’s scheduled shift. Employees who use more than 3 consecutive workdays’ worth of paid sick leave may be required to provide certification from their healthcare provider. Prior to the use of 3 consecutive workdays’ worth of paid sick and safe leave, employees may be required to sign a self-certification, verifying that they are using the paid sick and safe leave for a covered reason, based on their work location’s requirements.

New York City Employees
The following procedure for medical-related time off requests applies to all employees working in New York City. Paid sick and safe leave is included in PTO (40 hours front-loaded, no roll-over; increasing to 56 hours in 2021), but to be counted as job-protected paid sick and safe leave may only be used for the following purposes:

• The employee’s mental or physical illness, injury, or health condition
• The employee’s need for medical diagnosis, care, or treatment of a mental or physical illness, injury, or health condition
• The employee’s need for preventive medical care
• The employee's elective surgery, including organ donations
• Care of a family member who needs medical diagnosis, care, or treatment of an illness, injury, or health condition, or who needs preventive medical care
• Care of a family member who has elective surgery, including organ donations
• Closure of employee’s workplace due to a public health emergency (as declared by the Commissioner of the New York City Department of Health and Mental Hygiene or the Mayor)
• The employee’s need to care for a child whose school or child care provider is closed due to a public health emergency
• The following actions for an employee or an employee’s family member who may be the victim of any act or threat of domestic violence or unwanted sexual physical contact, stalking, or human trafficking:
  • Obtain services from a domestic violence shelter, rape crisis center, or other services program.
  • Participate in safety planning, relocate, or take other actions to protect your safety or that of your family members, including enrolling children in a new school.
  • Meet with an attorney or social service provider to obtain information and advice related to custody; visitation; matrimonial issues; orders of protection; immigration; housing; discrimination in employment, housing, or consumer credit.
  • File a domestic incident report with law enforcement or meet with a district attorney’s office.

California Employees
For employees whose primary work location is in California, the minimum required amount of paid sick leave is included in PTO (40 hours front-loaded, no roll-over) but may only be used as paid sick leave for the following reasons:

• Diagnosis, care, or treatment of an existing health condition, or preventive care for, an employee or an employee’s family member.
• Reasonable accommodations for a victim of domestic violence, sexual assault, or stalking who requests an accommodation for the safety of the victim while at work.

Employees in Other States
Employees working in other states may or may not be entitled to “protected” sick leave under state and / or local law. In all cases, the company will adhere to federal, state and / or local requirements (whichever is more favorable to the employee).

PTO requests are approved by your immediate supervisor and are generally granted on a first-come, first-served basis. Other factors that may be taken into considerations when deciding which employees’ requests are approved include

• the Company’s staffing needs during the relevant period,
• the individual performance of each requestor,
• the amount and frequency with which each requestor has already taken time off,
• the requestor’s current workload and ability to find suitable coverage and
• the time of year relative to the needs of the business and requestor’s job responsibilities.

PTO for personal or vacation must be requested and used in a minimum of 4-hour increments. PTO requested for paid sick and safe leave purposes may be taken in smaller increments if needed for a covered reason. Requests to use PTO for fewer than 4 hours in one day will not be approved.

If approved by your supervisor, you may opt to take time off unpaid instead of using your PTO balance for the following reasons:

• Personal
• Vacation
  If the paid sick leave balance portion of PTO already has been exhausted, employees may not opt to use unpaid time off in lieu of accrued, unused PTO for any absences due to reasons covered under
• paid sick and safety leave,
• FMLA,
• ADA or
• any other type of unpaid protected leave.

Accept where otherwise required by state or local law, PTO has no cash value. Any unused PTO is not paid out upon termination of employment or at the end of the calendar year.

Spytec GPS, Inc. complies with the federal Family and Medical Leave Act (FMLA), which requires employers to grant unpaid leaves of absence to qualified workers for certain medical and family-related reasons. The company abides by any state regulated leave laws. The more generous of the two laws will apply to the employee if the employee is eligible under both federal and state laws.

In addition to entitlements under the FMLA, the Company provides additional protections based upon State and Local laws. Please contact your Human Resources Representative for a full summary of your leave entitlements and leave definitions for your work location.

Please note there are many requirements, qualifications, and exceptions under the law, and each employee’s situation is different. Contact your Human Resources Representative department to discuss options for leave.

Who is eligible to take FMLA? Employees may take FMLA leave if:

• they have worked for the company for at least 12 months
• they worked at least 1,250 hours during the previous 12 months, and
• they work at a location with at least 50 employees within a 75-mile radius.

Reasons for Taking Leave. Under federal law, unpaid leave may be requested for pregnancy and prenatal care; pre-placement activities, birth, adoption, or foster placement of a child; or the serious health condition of a child, spouse, parent, domestic partner, or the employee. State law may have additional reasons defined.

Military Family Leave Entitlements. Under federal law, unpaid leave may also be requested by eligible employees who have any qualifying exigency arising out of the fact that the spouse or a son, daughter, parent, domestic partner, or next of kin of the employee is on covered active duty (or has been notified of an impending call or order to covered active duty) in the armed forces and may use their 12-week entitlement to address certain qualifying circumstances. Qualifying circumstances may include deploying on short-notice, attending certain military events, arranging for alternative child care and school activities, addressing certain financial and legal arrangements, attending certain counseling sessions, engaging in rest and recuperation, and attending post deployment reintegration briefings.

The federal FMLA also includes a special leave entitlement that permits eligible employees to take up to 26 weeks of leave to care for a covered service member during a single 12-month period. This leave applies if the employee is the spouse, son, daughter, parent, domestic partner, or next of kin caring for a covered military service member or veteran recovering from an injury or illness suffered while on active duty in the armed forces or that existed before the beginning of the member’s active duty and was aggravated by service or that manifested itself before or after the member became a veteran.

Leave Designation. If an employee does not expressly request FMLA leave, the company reserves the right to designate a qualifying absence as FMLA leave and will give notice of the FMLA designation to the employee. If an absence is a qualifying event under FMLA, the leave will run concurrent with short-term disability, long-term disability, sick leave, vacation, workers’ compensation, and/or any other leave where permitted by state and federal law.

Benefits. Under federal law, employers must continue healthcare benefits during FMLA leave as though the employees were still at work and must pay the employer’s part of the premium. The employee will continue to be responsible for the employee’s portion of the premium. Please contact Accounting/Payroll to coordinate payment.

Interaction with Accrued Paid Time Off. FMLA leave, and paid time off will run concurrently as provided under company policy except where prohibited by state law.

Job Protection. An employee’s job, or an equivalent job, is protected while the employee is on leave. Both federal and applicable state laws require that employees be returned to their positions or to another job of like pay and status at the end of FMLA leave.

Note: If an employee is unable to return to work after the expiration of federal or state FMLA, an extension may be granted if the condition constitutes a disability under the Americans with Disabilities Act (ADA) or in certain workers’ compensation cases.

Return-to-Work Policy. When such work is available, the company will attempt to provide an employee with a temporary modified or light-duty assignment in accordance with documented medical restrictions.

This policy covers the various types of paid and unpaid leave provided to eligible employees. It also provides information on how other benefits such as paid sick leave and vacation apply to different types of leave.

Employees working in California pay into a Paid Family and Medical Leave/Disability Leave benefit via required payroll deduction. The state dictates employee contribution amount, and Spytec GPS is required to withhold and remit that amount to the state. Eligible employees may apply for paid family leave with their respective states, and the benefit is then administered through the state. The amount paid to eligible employees for their paid family leave is determined by the state and is a percentage of an employee’s past earnings up to a maximum weekly benefit amount.

New York employers are required to purchase Paid Family Leave/Disability Leave insurance. This benefit is funded through employee payroll contributions that are set each year to match the cost of coverage. The rate of employee contributions is reviewed annually by the New York State Department of Financial Services and is subject to change. Spytec GPS is required to withhold and remit the payroll contributions. Eligible employees may apply for paid family leave through the company’s insurance carrier. The amount paid to eligible employees for their paid family leave is determined by the insurance carrier and is a percentage of an employee’s past earnings up to a maximum weekly benefit amount.

Employees should provide their supervisors and HR Representative with at least 30 days’ notice of the need to take any type of leave or as much notice as possible. “As much notice as possible” generally means that you should inform your supervisor and the HR Representative as soon as the need for leave becomes foreseeable. For paid family leave, once notified of an employee’s request to apply for leave, the Spytec GPS HR Representative will complete the company’s portion of any required paperwork and provide it to the employee. For FMLA or CFRA, the HR Representative will provide the employee with the required notices and, if applicable, the paperwork that needs to be completed by the employee and the healthcare provider.

Because the eligibility criteria are set by state law, Spytec GPS does not control who is or is not approved for Paid Family Leave or Paid Disability Leave. Spytec GPS also follows federal and state law when determining whose FMLA or CFRA is approved. Our HR Representative will help you navigate the processes with the state or insurance carrier if applicable and will answer any questions you may have.

To be eligible for unpaid, job-protected family care, medical, and military family leave under the FMLA and CFRA, an employee must (1) have worked for the Company for at least twelve months prior to the date on which the leave is to commence; (2) have worked at least 1,250 hours in the twelve (12) months preceding the leave; and (3) work at an location with 50 employees or more within a 75-mile radius of the Company’s next closest facility. An employee returning from fulfilling his or her National Guard or Reserve military obligation will be credited with the hours of service that would have been performed but for the period of military service in determining the 1,250 hours of service.

In the case of a pregnancy-related disability or other legally protected disability or medical condition or work-related injury, an employee may not need to satisfy all of the above requirements. In such circumstances, the employee should contact the Human Resources Representative. California employees may also qualify for Paid Family Leave if they are a part- or full-time employee who has contributed to the State Disability Insurance program through mandatory payroll deductions at some point during the previous 18 months. There are additional circumstances under which California employees my be eligible, and more information can be obtained from the EDD’s website. California’s paid family leave and paid disability leave do not come with job protection unless an employee is also covered under FMLA or CFRA.

Eligibility for New York employees to take job-protected Paid Family Leave is determined based upon hours worked and length of employment. The below service requirements must be met before employees will be covered under Spytec GPS’s Paid Family Leave insurance.

20 or more scheduled hours per week: Employees who work a regular schedule of 20 or more hours per week are eligible after 26 consecutive weeks of visits to a health care provider or one visit and a regimen of continuing treatment, or incapacity due to pregnancy, or incapacity due to a chronic condition. Other conditions may meet the definition of continuing treatment.

Military Exigency Leave may be requested when there is a qualifying military exigency arising out of the fact that an employee’s spouse, child, or parent is on covered active duty (or has been notified of an impending call or order to covered active duty) in the Armed Forces outside of the United States.

Qualifying military exigencies include the following:

• Short-notice deployment where the employee may take leave to attend any issue that arises from the fact that a military member (whether in the Regular Armed Forces, National Guard, or Reserves) is notified of an impending call or order to active duty seven or less calendar days prior to the date of deployment. Leave taken for this purpose can be used for a period of seven calendar days beginning on the date the covered service member receives the notification.
• Military events and related activities where the employee may take leave to attend to any official ceremonies, programs or events related to the call to active duty and to attend to family support, assistance programs, or informational briefings related to the call to active duty.
• Childcare and school activities where the employee may take leave to arrange for alternative childcare or to provide childcare on an urgent, immediate need basis when the need arises from the call to active duty, to enroll or transfer a child to a new school, to attend meetings with school or daycare facility staff regarding disciplinary measures, parent-teacher conferences, or meetings with school counselors.
• Financial and legal arrangements where the employee may take leave to make or update financial or legal arrangements related to the covered service member’s absence, such as preparing powers of attorney, wills, transferring bank accounts, and the like, or appearing or acting on behalf of the absent servicemember in matters related to military benefits.
• Counseling where the employee may take leave to attend counseling, the need for which arises from the call to active duty of the covered servicemember.
• Rest and recuperation where the employee may take up to fifteen days of leave to spend time with a covered servicemember each time the servicemember is on short-term rest and recuperation leave during the period of deployment.
• Post-deployment activities where the employee may take leave for a period of up to 90 days following the termination of the deployment to attend arrival ceremonies, reintegration briefings and events, and other official ceremonies or programs provided by the military, or to address issues that arise out of the death of a covered servicemember.
• Parental leave where the employee may take qualifying leave to care for the parent of a military member, or someone who stood in loco parentis to that military member, when the parent is incapable of self-care. To qualify as parental leave, the need for the leave must arise out of the military member’s call to active duty. Further, the leave must be for one of the following purposes: (1) to arrange for alternative care for the parent; (2) to provide care for the parent on an urgent, immediate need basis; (3) to admit or transfer the parent of the military member to a care facility; or (4) to attend a meeting with staff at a care facility for the parent.
• Additional activities where the employee may take leave to address other events that arise out of the call to active duty as the Company and the employee may agree as to both timing and duration.

Military Caregiver Leave may be requested to care for a covered servicemember if the employee is the covered service member’s spouse, child, parent, or next of kin. For purposes of this leave, a covered servicemember is: (1) a current member of the Armed Forces, including a member of the National Guard or Reserves who is undergoing medical treatment, recuperation, or therapy, is otherwise in outpatient status, or is otherwise on the temporary disability retired list, for a serious injury or illness, or (2) a covered veteran who is undergoing medical treatment, recuperation, or therapy, for a serious injury or illness.

Less than 20 scheduled hours per week: Employees who work a regular schedule of less than 20 hours per week are eligible after working 175 days, which do not need to be consecutive. Employees are eligible regardless of citizenship and/or immigration status.

Starting in 2019 and before 2021, eligible employees may take up to 10 weeks of leave in a 12-month period under this policy, the first 8 weeks of which are covered under New York Paid Family Leave insurance and the last two weeks of which are paid by Spytec GPS. In 2021, the paid leave entitlement for eligible employees will increase to 12 weeks in a 12-month period, the full 12 weeks of which will be covered under New York Paid Family Leave insurance. Employees may choose to supplement their payments from the insurance carrier with available PTO; however, it is not required. Employees who qualify to receive New York Disability Leave insurance payments may also be entitled to additional paid leave not to exceed 26 weeks for PFL and DBL combined.

Eligible employees may take up to 10 weeks of PFL leave in a 12 month period under this policy, the first 6 weeks of which are covered under California Paid Family Leave (PFL) and the last four weeks of which are paid by Spytec GPS. Employees may choose to supplement their payments from the insurance carrier with available PTO; however, it is not required. Eligible employees under the CFRA may also be entitled to an additional amount of unpaid, job-protected leave under the CFRA. Employees should work with the Human Resources Representative to determine eligibility and coordinate the various types of leave.

California Paid Family Leave may be requested for (1) the birth or adoption of an employee’s child; (2) the placement of a foster child with the employee; or (3) the serious health condition of an employee’s child, registered domestic partner, spouse, or parent; or (4) an employee’s own serious health condition.

• A serious health condition is an illness, injury, impairment, or physical or mental condition that involves either (1) the individual being admitted to a medical care facility with the expectation that the or she will remain at least overnight, or (2) 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 may be met by a period of incapacity of more than three consecutive calendar days combined with at least visits to a health care provider or one visit and a regimen of continuing two treatment, incapacity due to pregnancy, or incapacity due to a chronic condition.

New Child: You can take Paid Family Leave during the first 12 months following the birth, adoption, or fostering of a child. Expectant mothers cannot take Paid Family Leave for their own pregnancy. Paid Family Leave for the birth of a child begins after the birth. It is not available for prenatal conditions.

Serious Illness: You can take Paid Family leave to care for a close relative with a serious health condition. These relatives can live outside of New York State and even outside the country. You cannot take Paid Family Leave for your own health condition. (Your own health condition would fall under New York City’s Paid Safe and Sick Leave if you are eligible and have a balance of accrued sick time to use.) A serious health condition is an illness, injury, impairment, or physical or mental condition that involves:

• Inpatient care in a hospital, hospice, or residential health care facility, or
• Continuing treatment or continuing supervision by a health care provider.

Military Active Service Deployment: You can take Paid Family Leave to assist with family situations arising when your spouse, domestic partner, child, or parent is deployed abroad on active military service or has been notified of an impending military deployment abroad. You cannot use Paid Family Leave for your own qualifying military event.

Employees are only required to substitute paid sick and safe leave for their own medical leaves. Spytec GPS otherwise does not require employees to use all their vacation and paid sick leave prior to using paid family leave or unpaid family medical leave; however, employees may choose to do so. Employees may elect to substitute sick leave to attend to an illness of a child, parent, spouse or domestic partner of the employee, or for other types of family care leave.

Provided all the conditions of this policy are met, an employee may take a maximum of 12 weeks of unpaid family care, medical, and military exigency leave in a rolling 12-month period measured backwards from the date the employee’s leave commences.

Employees who are unable to work due to pregnancy disability will be granted the greater of 12 weeks unpaid leave or the amount of leave to which the employee may be entitled under California state law for a pregnancy-related disability or in connection with childbirth. Family care leaves for the birth, adoption, or foster care placement of a child must be concluded within one year of the birth, adoption, or placement.

Provided all the conditions of this policy are met, an employee may take a maximum of 26 weeks of military caregiver leave in a single 12-month period, inclusive of the time the employee takes for a family care, medical, or military exigency leave during that period. This 12-month period will be measured forward from the first day leave is taken.

Spouses who are both employed by the Company may take a maximum combined total of 26 weeks in the 12-month period for the care of the servicemember and the birth, adoption, or foster care of their child or to care for an ill parent, provided that no more than 12 weeks of this combined 26-week period may be taken for reasons other than to care for the servicemember.

Medical leave for the employee’s own serious health condition, family care leave for the serious health condition of the employee’s spouse, parent, or child, and military caregiver leave may be taken intermittently or on a reduced schedule when medically necessary. Where the intermittent or reduced schedule leave is for planned medical treatment, the employee must make an attempt to schedule the treatment so as not to disrupt unduly the Company’s operations. Where the family care leave is to be taken in connection with the birth, adoption, or foster placement of a child, the minimum duration for each period of leave is two weeks, except that the employee may request leave of less than two weeks duration on any two occasions. Exigency leave also may be taken intermittently or on a reduced schedule.

California employees also may be entitled to Paid Family Leave (PFL) benefit payments for up to six (6) weeks in any twelve-month period during leaves to care for qualifying family members. To the extent possible, PFL benefits must run concurrently with family care leave and FMLA and do not entitle an employee to take any additional time off.

Paid Family Leave (PFL) benefits phase in over four years, providing up to eight weeks of leave for employees who started Paid Family Leave in 2018; 10 weeks for leave starting in 2019 and 2020, and 12 weeks in 2021. Leave can be taken either all at once or intermittently but must be taken in full-day increments. You may take the maximum time-off benefit in any given 52-week period. To the extent possible, PFL benefits must run concurrently with FMLA and do not entitle an employee to take any additional time off.

Except to the extent that other paid leave is substituted for family care, medical, and military family leave, leave under the FMLA and the CFRA is unpaid. However, employees may be entitled to California State Disability Insurance (SDI) or New York City Paid Sick Leave when leave is taken for their own serious health condition. New York and California Paid Family Leave (PFL) are paid by the state or by the employer’s insurance carrier, according to each states’ respective requirements.

During an employee’s leave under this policy, the Company will continue to pay for the employee’s participation in group health plans to the same extent and under the same terms and conditions as would apply had the employee not taken leave. Thus, the employee must continue to pay his or her share of the health plan premiums during the leave. If paid leave is substituted for the unpaid leave, such payments will be deducted from the employee’s pay through the regular payroll deductions. Otherwise, the employee must make other arrangements with the Company.

Under certain circumstances, such as the employee failing to return from leave, the Company may be able to recover any health plan premiums paid by the Company on the employee’s behalf during any periods of the leave.

With regard to other employee benefit plans, the Company will continue to pay for the employee’s participation in such plans to the same extent and under the same conditions as apply to other leaves that are not family care, medical and military family leaves. Family care, medical or military family leaves will not be treated as a break in service and will not result in the loss of seniority or in the loss of any employment benefit that accrued prior to the start of an employee’s leave.

While employees working in Florida, South Carolina and other states may not be entitled to state-funded/administered Paid Family Leave (PFL), eligible full-time employees in these states may take up to 10 weeks of leave in a 12-month period under this policy (at management’s discretion) following 2080 hours of continuous employment (unless afforded a greater benefit under FMLA or state law, which will apply and run concurrently with this Paid Parental Leave Policy and which will allow employees to receive no more than one hundred percent of their base compensation at any time).

Eligible employees may use this paid time off

• for the birth, adoption or placement of a child in foster care and/or

• to bond with a new baby.

Employees will be paid at their regular rate of pay for 8 hours per day or 40 hours per week of approved PFL absence. Time off must be requested as soon as the need for leave becomes foreseeable, and must be requested via Justworks.

Employees serving in the uniformed services, including the Army, Navy, Marine Corps, Air Force, Coast Guard and Public Health Service commissioned corps, as well as the reserve components of each of these services, may take unpaid military leave, as needed, to enable them to fulfill their obligations as servicemembers. Servicemembers must provide advance written or verbal notice to the Company for all military duty, unless giving notice is impossible, unreasonable, or precluded by military necessity. Employees should provide notice as far in advance as is reasonable under the circumstances. In addition, employees may, but are not required to, use accrued paid time off (PTO) while performing military duty.

The federal Fair Labor Standards Act (FLSA) allows employees to take reasonable, unpaid break time to express breast milk as needed for up to one (1) year after the birth of a child. The Company will provide a place for the employee to express breast milk, other than a bathroom, that is shielded from view and free from intrusion from co-workers and the public. Employees will not be discharged or in any other manner discriminated against in exercising their rights under this policy. 

The Company encourages employees to fulfill their civic duties. To that end, employees will be allowed leave to serve on a jury, if summoned. We request that you bring in a copy of your summons notice and your proof of time served as soon as you receive it, so that we may keep it on file. If you are called during a particularly busy period, we may ask you to request a postponement. The Company will provide additional documentation in this regard, if necessary, to obtain such postponement.



Jury duty can last from a portion of a single day to several months or more. During this time you will be considered on a leave of absence and will be entitled to continue to participate in insurance and other benefits as if you were working. While serving on jury duty, you are expected to call in to your supervisor periodically to keep him or her apprised of your status. 


The Company will compensate full-time employees for the difference between jury duty compensation and your current daily pay for the first 5 days of jury service (or in accordance with applicable law, if different). If additional time is required, it will be granted, but without pay. 

Spytec GPS recognises that most employees will have ample time outside of regular work hours to vote; however, for those employees who do not have at least 4 consecutive off-duty hours to vote while the polls are open, Spytec GPS will provide up to 2 hours of paid voting leave during work hours at the beginning or end of the employee’s shift. Employees must request to use their voting leave at least 2 but not more than 10 working days in advance.

An employee called to appear as a witness will be permitted time off to appear, but without pay. Employees will be permitted to use accrued paid time off (PTO) when appearing as witnesses.

All employees are eligible for up to 3 additional days of paid bereavement for the death of a close relative. For the purposes of this policy, a close relative is a spouse, parent, sibling, grandparent, child, cousin and aunt or uncle (includes stepparents, stepchildren and step siblings).

Voluntary Separations:

Resignations - An employee may choose to end the employment relationship. This is considered a voluntary resignation. If you wish to resign your employment with the Company, you are requested to notify your manager of your anticipated departure date at least two (2) weeks in advance.  This notice should be in the form of a written note or letter to your manager or your Human Resources Representative.

In addition to resignations, there are a few other forms of voluntary separation:

• Job Abandonment - a job is considered abandoned if an employee fails to call in or show up for work as scheduled for 3 or more scheduled work days.
• Failure to Return from Leave - When an employee goes out on medical or personal leave, the employer may request periodic updates of the employee’s intent to return to work. The employer may also request sufficient certification to show that the leave is necessary or valid. Failure to provide notice of your intent to return from leave or appropriate certification in the timeframe specified by Spytec GPS may be considered a voluntary separation.

Involuntary Separations:

When employees leave the Company’s employ, and it is the company’s choice to end the employment relationship, it is considered an involuntary separation.

There are a few types of involuntary separation:

• Layoffs - When the company has a temporary downturn in work and needs to suspend employment until work picks back up and the worker can be recalled, it is considered a layoff.
• Reduction in Force (RIF) - When, for financial reasons, the company has to eliminate positions, it is considered a reduction in force.
• Job Elimination - Similar to a RIF, job elimination occurs when the company needs to restructure and either completely eliminate or change the scope or nature of a role.
• Termination - When an employee is discharged for violating policy or for poor performance, it is considered a termination.

Final Pay: All final compensation, including bonus payments, wages and commissions will be paid by your next regularly scheduled payday. The last payment will generally be made via direct deposit or a check will be mailed to the employee’s designated address. Note: California employees and other employees in states with different final pay requirements will be paid according to their work location’s state and local laws.

Logistics: Company will deny access to electronic files and email/FTP accounts at the end of the employee’s last day of employment.

Return all Company property, keys, files, materials, and equipment at or before your last day.

The Company appreciates your feedback and asks all employees to participate in an exit interview with their immediate supervisor or Human Resources Representative prior to leaving the Company. This provides an opportunity to return keys and other property and to tie up any loose ends. You will receive preliminary information at that time regarding continuation coverage and any other continuation of benefits for which you may be eligible.

If you leave the Company in good standing, you may be considered for reemployment at a later date. However, in the case of rehiring, you may be considered a new employee with respect to paid time off (PTO), benefits and seniority.



In a perfect world, every employment relationship would be smooth and harmonious. However, there are, unfortunately, times when employees and employers disagree. These disagreements often arise in the context of involuntary employment termination, but there may be disagreements regarding the right to a promotion, expense reimbursement, or a parade of other things

Although we seek to provide a workplace in which all employees feel that they are an important part of the Company and where employees feel fairly treated, there may be times when you have a dispute with a supervisor or the Company which can best be resolved through a formal procedure for dispute resolution.

Any grievance or concern should first be addressed with your direct supervisor. If you are not comfortable going to your supervisor or are unsatisfied by the decision made by your supervisor, you may escalate your concern to the Human Resources Representative or to the VP of Operations. If your grievance involves senior management, you may submit your written grievance to the CEO.