WESTERN GLOBAL AIRLINES Employee Handbook United States

Western Global Airlines Employee Handbook, May 2018 Edition Page | 1

WESTERN GLOBAL AIRLINES

Employee Handbook

United States

May 2018 Edition

Western Global Airlines Employee Handbook, May 2018 Edition Page | 2

INTRODUCTION

Dear Western Global Team Member:

Welcome to Western Global Airlines. You are part of a select team of talented individuals who work together to achieve

a higher purpose--connecting people anywhere in the world to the urgent necessities that are important to them,

through safe, reliable, responsive and low-cost air transportation, utilizing our extensive fleet of efficient wide-body

freighter aircraft. To accomplish this, you are entrusted with very valuable capital resources, highly upgraded wide body

freighter airplanes equipped with advanced GE engines, and supported by an extensive parts inventory, which you would

be operating, maintaining, scheduling, loading, coordinating and managing. We expect that you use common sense and

good judgment in all situations, and treat one another with honesty and respect. When it comes to taking care of our

customers, and in all your interactions with other Western Global employees, suppliers, vendors or any other third

parties, you are expected to represent the Company’s best interests with excellence, loyalty, and pride.

Our goal is to make Western Global Airlines the best airline in the world and a great place to work for all of our

employees. We wish to be a positive force in our community, our country and the world. Together, we can make this

happen, and each and every employee of Western Global will be part of it. We are creating a different and better type

of airline, based on companywide collaboration and teamwork, where every employee has a voice and direct influence.

Having flown to over 300 cities in more than 100 countries on 6 continents in a mere three years, Western Global

Airlines has already made remarkable progress as a start-up airline and we are well positioned to continue to grow,

expand and succeed.

The Employee Handbook is intended to guide our employees with regard to Western Global’s standards, policies, and

procedures concerning the important aspects of employment, and to establish expectations. The Handbook is a “living”

document and as such, we will make adjustments over time as we grow and evolve. We believe that each of us arrives at

work each day to do our best, and with the right training, resources and guidance our potentials are unlimited.

In order to accomplish this, we need to work closely together across every expertise and function--we must be

collaborative. We must clearly communicate with each other and ensure that all of our communications are understood

and the intended result achieved. We must be professional, and always, always treat others with respect.

Every employee is expected to comply with the policies in the Handbook and any other applicable laws, regulations,

expectations, policies, procedures and guidelines that apply to your position. If you have any questions or doubts, be

sure to reach out to your resources, including your supervisor, department head or Human Resources manager. We are

here to help.

Congratulations on being part of the WGA team!

Sincerely,

Western Global Airlines

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Disclaimer: Nothing contained in this Employee Handbook shall be construed as constituting a contract of employment,

or as creating any contractual obligations on the part of Western Global Airlines, LLC (hereinafter the “Company”)

Instead, the rules, policies, and standards of the Employee Handbook are guidelines subject to modification, deletion, or

addition at any time. Employees will be informed of any such changes via communication from the Human Resources

Department on the Company’s Communication System, ADP. Employees are required to check ADP frequently for

Company information and are required to read revisions to the Employee Handbook. Since the Company reserves the

right to make modifications to the Handbook, all employees are hereby advised that the only valid version of the

Employee Handbook is located on ADP. If an employee chooses to print a copy of the Employee Handbook, it is the

Employee’s responsibility to check ADP frequently to ensure that the employee has a copy of the current version of the

Employee Handbook.

We reserve the right to revise or terminate any or all policies, procedures and benefits (if offered to you by the

Company), in whole or in part at any time, and employees will be informed of any changes made. Company benefit plans

(available if premiums and contributions are paid and if participation and other requirements are met), are defined in

legal documents such as insurance contracts, official plan texts, and summary plan descriptions. This means that if you

are offered benefits and if a question ever arises about the nature and extent of plan benefits, or if there is conflicting

language, the formal language of the plan documents govern, not the informal wording of this Handbook. Plan

documents, if applicable, are available for your inspection.

Nothing in this Handbook, or in any other personnel document, including benefit plan descriptions, creates or is intended

to create a promise or representation of continued employment for any employee, or change the at-will nature of

employment with the Company

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CONTENTS

WORKPLACE COMMITMENTS ................................................................................................................. 6

OPEN DOOR POLICY AND PROCEDURE ................................................................................................. 6

EQUAL EMPLOYMENT OPPORTUNITY .................................................................................................. 6

DISCRIMINATION, HARASSMENT, AND RETALIATION ........................................................................... 6

REASONABLE ACCOMMODATIONS ...................................................................................................... 8

EMPLOYMENT ......................................................................................................................................... 9

AT-WILL EMPLOYMENT........................................................................................................................ 9

IMMIGRATION LAW AND COMPLIANCE ............................................................................................... 9

EMPLOYMENT STATUS ........................................................................................................................ 9

PROBATIONARY PERIOD .................................................................................................................... 10

BACKGROUND CHECKS ...................................................................................................................... 10

COMPANY AND EMPLOYEE PROPERTY ............................................................................................... 10

LEGAL COMPLIANCE .......................................................................................................................... 11

WHISTLEBLOWER AND COMPLAINT POLICY ....................................................................................... 12

ENDING THE EMPLOYMENT RELATIONSHIP ....................................................................................... 12

WORKPLACE SAFETY .............................................................................................................................. 13

SUBSTANCE ABUSE ............................................................................................................................ 13

EDUCATION AND AWARENESS PROGRAM ......................................................................................... 15

WORKPLACE VIOLENCE ...................................................................................................................... 15

SAFETY .............................................................................................................................................. 16

INCLEMENT WEATHER ....................................................................................................................... 16

SMOKING .......................................................................................................................................... 17

SECURITY ........................................................................................................................................... 18

WORKPLACE EXPECTATIONS.................................................................................................................. 18

CONFIDENTIALITY .............................................................................................................................. 18

STANDARDS OF CONDUCT ................................................................................................................. 19

CRIMINAL CONVICTIONS.................................................................................................................... 22

ATTENDANCE..................................................................................................................................... 22

PERSONAL APPEARANCE.................................................................................................................... 23

ELECTRONIC MEDIA AND COMMUNICATIONS ................................................................................... 25

CELL PHONE USAGE/TEXTING ............................................................................................................ 26

SOLICITATION AND DISTRIBUTION ..................................................................................................... 26

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EMPLOYEE RECORDS ......................................................................................................................... 27

EMPLOYMENT REFERENCES ............................................................................................................... 27

COMPENSATION.................................................................................................................................... 28

SAFE HARBOR .................................................................................................................................... 28

PAYMENT OF WAGES......................................................................................................................... 29

RECORDING TIME WORKED ............................................................................................................... 30

OVERTIME ......................................................................................................................................... 30

WORK WEEK, BREAKS, AND MEAL PERIODS ....................................................................................... 30

WESTERN GLOBAL WAY (WGW) BONUS PROGRAM ........................................................................... 30

EMPLOYEE TRAVEL POLICY ................................................................................................................ 30

EMPLOYEE EXPENSE REIMBURSEMENT POLICY...................................................................................... 33

TIME OFF ............................................................................................................................................... 34

HOLIDAYS .......................................................................................................................................... 34

PAID TIME OFF (PTO) ......................................................................................................................... 34

FAMILY AND MEDICAL LEAVE ACT (FMLA) ......................................................................................... 35

BEREAVEMENT LEAVE........................................................................................................................ 40

JURY DUTY LEAVE .............................................................................................................................. 40

VOTING LEAVE ................................................................................................................................... 40

MILITARY LEAVE OF ABSENCE ............................................................................................................ 40

BENEFITS ............................................................................................................................................... 41

BENEFITS OVERVIEW ......................................................................................................................... 41

COBRA ............................................................................................................................................... 42

HIPPA ................................................................................................................................................ 42

WORKERS COMPENSATION INSURANCE ............................................................................................ 42

APPENDIX A –

EMPLOYEE RIGHTS AND RESPONSIBILITIES UNDER THE FAMILY AND MEDICAL LEAVE ACT.................... 43

ACKNOWLEDGMENT (EMPLOYEE COPY) ............................................................................................... 45

ACKNOWLEDGMENT (HUMAN RESOURCE COPY) ................................................................................. 46

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WORKPLACE COMMITMENTS

OPEN DOOR POLICY AND PROCEDURE

Western Global Airlines welcomes open communication between employees and supervisors. Employees are invited to

share their concerns and provide input to their supervisor at any time. It is your supervisor’s responsibility to address any

employee concerns and provide appropriate follow up with the employee. If, however, your immediate supervisor

cannot adequately address your questions or solve your problem, or if you do not feel comfortable speaking with your

immediate supervisor, you may contact your department head or the Manager of Human Resources.

EQUAL EMPLOYMENT OPPORTUNITY

It is the policy of Western Global Airlines to provide equal opportunity employment to all employees and applicants

without regard to race, creed, color, sex, religion, ancestry, national origin, citizenship, genetic information, age, veteran

status, disability, handicap, pregnancy, marital status, sexual orientation, sexual identification, or any other status

protected by applicable law, subject to regulatory and government compliance

This policy relates to all employment decisions, including those in connection with recruitment, hiring, training,

promotion, compensation, benefits, termination, and all other terms and conditions of employment. All policies are in

accordance with federal, state and local equal employment opportunity principles and other related laws. The Company

will not tolerate any unlawful discrimination or harassment, and any such conduct is prohibited. Any employee who feels

that he or she has been subject to unlawful discrimination or harassment should inform his or her immediate supervisor,

or the Manager of Human Resources.

The Company does not tolerate retaliation for making a good-faith complaint of discrimination or harassment. Any

employee who feels he or she has been retaliated against in violation of making such a complaint is responsible for

reporting the retaliation to his or her immediate supervisor or the Manager of Human Resources, in the same manner as

any other form of harassment or discrimination should be reported.

DISCRIMINATION, HARASSMENT, AND RETALIATION

Western Global Airlines expressly prohibits unlawful discrimination, harassment and retaliation with regard to any of

our employees, customers, vendors, suppliers, or independent contractors, based on race, creed, color, sex, pregnancy,

religion, ancestry, national origin, disability, citizenship status, handicap, genetic information, age, marital status, sexual

orientation, sexual identification, veteran status, or any other protected category under federal, state, or local law.

Conduct that unlawfully interferes with the Company or an individual’s work performance, or creates an intimidating,

hostile or offensive working environment is prohibited. The Company will not tolerate any attempts of retaliation against

an employee who raises a sincere and valid concern that this policy has been violated. The Company will take all

allegations of unlawful discrimination, harassment, and retaliation very seriously and is firmly committed to ensuring a

workplace free of discriminatory and retaliatory activities. Anyone engaging in unlawful discrimination, harassment, or

retaliation will be subject to disciplinary action, up to and including termination of employment.

Harassment Prohibited – Definition

As used in this Handbook, the term “unlawful harassment” refers to conduct relating to a person’s race, creed, color, sex,

pregnancy, religion, ancestry, national origin, disability, citizenship status, handicap, age, marital status, sexual

orientation, sexual identification, veteran status, or any other protected category under federal, state, or local law. This

policy protects and covers the conduct of all employees, vendors, residents and visitors. Unlawful harassment that is

forbidden by this policy can take several forms, including but not limited to:

1) Sexual Harassment

The definition of Sexual Harassment includes unwelcome sexual advances, requests for sexual favors, or other

verbal or physical conduct of a sexual nature which unreasonably interferes with an employee’s work

performance or creates an intimidating, hostile or offensive environment and/or where the individual is made

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to feel as if he or she must agree to the request or submit to the advance in order to get favorable treatment at

work. While not exhaustive, the following is a list of some examples of sexual harassment:

• Unwanted sexual advances.

• Offering employment benefits in exchange for sexual favors.

• Making or threatening reprisals after a negative response to sexual harassment.

• Visual conduct such as leering, making sexual gestures, displaying or distributing sexually suggestive

objects or pictures, cartoons or posters.

• Verbal conduct such as making or using sexually derogatory comments, epithets, slurs, or jokes.

• Verbal sexual advances or propositions.

• Verbal abuse of a sexual nature, graphic verbal commentaries about an individual's body, sexually

degrading words used to describe an individual, suggestive or obscene letters, notes or invitations.

• Physical conduct or threat of physical conduct, such as unwanted touching, assault, or impeding or

blocking movements.

2) Other Forms of Harassment

This form of harassment can include any verbal, written, or physical act that makes an employee uncomfortable

at work or interferes with an employee's ability to perform their job, and is based on race, creed, color, religion,

ancestry, national origin, disability, citizenship status, handicap, genetic information, age, gender, pregnancy,

marital status, sexual orientation, sexual identification, veteran status, or any other protected category under

federal, state, or local law.

While not exhaustive, the following is a list of some examples of the above referenced types of harassment:

• Jokes that refer to a person’s race, creed, color, religion, ancestry, national origin, disability, citizenship

status, handicap, genetic information, age, gender, pregnancy, marital status, sexual orientation, sexual

identification, veteran status, or any other protected category under federal, state, or local law.

• Posting or distributing cartoons, drawings, emails, or any other material that a reasonable person might

find offensive or degrading.

• The use of slurs or other offensive language.

• Practical jokes, horseplay, or teasing that makes fun of or insults a person’s race, creed, color, religion,

ancestry, national origin, disability, citizenship status, handicap, genetic information, age, gender,

pregnancy, marital status, sexual orientation, sexual identification, veteran status, or any other protected

category under federal, state, or local law.

Responsibility

All Company employees, particularly supervisors, have a responsibility for keeping our work environment free of

harassment. Any employee who becomes aware of an incident of harassment, whether by witnessing the incident or

being told of it, must report it to their immediate supervisor, their department head, and the Manager of Human

Resources. When Management becomes aware of the existence of harassment, it is obligated to take prompt and

appropriate action, whether or not the victim wants the Company to do so.

Reporting and Investigating Discrimination, Harassment, and Retaliation

In an effort to eliminate all workplace unlawful discrimination, harassment, and retaliation, Western Global Airlines will

utilize an internal investigation process to respond to any such complaints. Anyone who believes he or she is being

subjected to discrimination, harassment, or retaliation or who has witnessed such conduct must report the conduct as

outlined in the following procedure.

• Report any discriminatory, harassing, or retaliatory behavior that you experience or witness to your immediate

supervisor immediately.

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• If the issue is not addressed in a timely manner, or if you are not comfortable addressing the issue with your

immediate supervisor, contact the department head, the Manager of Human Resources, or another member of

Management.

• A thorough investigation will be conducted, and there will be no retaliation against anyone who, in good faith,

reports such conduct or otherwise participates in the investigation.

• Anyone who knowingly fails to report an incident of unlawful discrimination, harassment, or retaliation may be

subject to disciplinary action up to and including termination.

Confidentiality

In cases involving a report of unlawful harassment or discrimination, all reasonable efforts will be made to protect the

privacy of the individuals involved. In many cases, however, the Company’s duty to investigate and remedy harassment

makes absolute confidentiality impossible. The Company will try to limit the sharing of confidential information with

employees on a “need to know” basis. In some cases, employees who assist in an investigation may be required to

maintain the confidentiality of all information they learn of or provide.

Assurance of Non-Retaliation

Western Global Airlines expressly prohibits retaliation of any kind against anyone for reporting unlawful harassment or

discrimination. Any such retaliation will not be tolerated and may result in discipline up to and including discharge.

REASONABLE ACCOMMODATIONS

Western Global Airlines is committed to complying fully with the Americans with Disabilities Act (“ADA”) and is

committed to ensuring equal opportunity in employment for qualified persons with disabilities. We conduct all our

employment practices and activities on a non-discriminatory basis.

Our hiring procedures provide meaningful employment opportunities for persons with disabilities. Upon request, we will

make job applications available in alternative, accessible formats. We will also give assistance in completing the

application. We only make pre-employment inquiries regarding an applicant's ability to perform the essential duties of

the job.

It is Western Global Airlines’ policy to provide reasonable accommodations to individuals with disabilities who are

otherwise qualified to perform the essential functions of their position, and due to an individual’s sincerely-held religious

beliefs, unless such accommodations would impose an undue hardship on the Company.

A reasonable accommodation is a change in the work environment or in the way a job is performed that enables a

person with a disability or sincerely-held religious beliefs to enjoy equal employment opportunities. While there are

many potential accommodations that the Company may be able to provide, the Company generally will not consider the

elimination of essential job requirements, leaves of an indefinite duration, or the creation of a new position as a

reasonable accommodation.

Requests for reasonable accommodation should be sent to the Human Resource Department. The Company also may

require documentation in order to confirm the nature of your disability or religious beliefs and to help us identify the

appropriate accommodation, including, but not limited to, medical certification when an accommodation is requested

because of a disability. While the Company will make every attempt to provide your requested accommodation, we may

not always be able to do so. The Company reserves the right to provide an alternative reasonable accommodation that is

effective at removing the workplace barrier in question and to not provide accommodation when doing so would pose

an undue hardship on the Company’s business.

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EMPLOYMENT

AT-WILL EMPLOYMENT

Nothing in this information constitutes an employment contract. Your employment with Western Global Airlines

remains at-will, which means that both you and the Company reserve the right to end the employment relationship at

any time for any or no reason. Your job status does not guarantee employment for any specific length of time or terms.

Your employment is entered into voluntarily, and both you and the Company are free to end the employment

relationship at any time. The policies in this Handbook should not be construed to constitute contractual obligations of

any kind or a contract of employment between Western Global Airlines and any employee.

The provisions in this Handbook have been developed at the discretion of the Company, and except for the policy of

employment-at-will, may be amended or cancelled at any time at the sole discretion of Western Global Airlines.

IMMIGRATION LAW AND COMPLIANCE

Western Global Airlines is committed to employing only people who are legally authorized to work in the United States.

Western Global Airlines does not discriminate because of a person's citizenship or national origin. Because the Company

complies with the Immigration Reform and Control Act of 1986, every new employee at Western Global Airlines is

required to complete the Employment Eligibility Verification Form I-9 and show documents that prove identity and

employment eligibility.

If you leave Western Global Airlines and are rehired, you must complete another Form I-9 if the previous I-9 with

Western Global Airlines is more than three years old, if the original I-9 is no longer accurate, or if the Company no longer

possesses the original I-9. If you have questions or want information on the immigration laws or this policy, contact the

Manager of Human Resources.

EMPLOYMENT STATUS

At the time you are hired, you will be classified as either “exempt” or “non-exempt.” This is necessary because, by law,

“non-exempt” employees are entitled to overtime pay for hours worked in excess of eight (8) hours per day or forty (40)

hours per workweek. . Exempt employees include managers, executives, professional staff, technical staff, outside sales

representatives, officers, directors, and others whose duties and responsibilities allow them to be “exempt” from

provisions as provided by the Federal Fair Labor Standards Act (FLSA) and any applicable state laws. If you are an

“exempt” employee, you will be advised that you are in this classification at the time you are hired, transferred, or

promoted. Participation in our benefits programs may be affected by your employment status or classification. All

employees of Western Global Airlines, whether exempt, non-exempt, full-time, part-time or per diem are employed at-

will.

EXEMPT status applies to certain administrative, professional, and executive staff. Exempt employees qualify for

exemption from overtime regulations under state and federal law and their salaries already take into account their

duties.

NON-EXEMPT status applies to all other regular employees. Non-exempt employees are covered by regulations in

accordance with the FLSA as well as state specific regulations in the states where they work and receive extra pay for

overtime work (as described in the overtime section of this Employee Handbook).

FULL-TIME employees work on a regular basis for at least 40 hours per week. Full-time employees may or may not be

exempt. They are eligible for all benefits available through work at the Company, as long as they meet the applicable

requirements (such as length of service).

PART-TIME (WITHOUT BENEFITS) employees work on a regular basis for fewer than 30 hours per week. Part-time

employees are not eligible for benefits covered in this Handbook other than those specified and/or required by law.

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CONTRACT employees work on an as-needed schedule. Contract employees are not eligible for benefits covered in

this Employee Handbook other than those required by law or as stipulated in writing signed by the CEO of the Company.

TEMPORARY employees are contracted through one of the Company’s temporary agency partners when there is a

temporary need for additional staff. Temporary employees are not eligible for benefits covered in this Employee

Handbook, other than those required by law or as stipulated in writing signed by the CEO of the Company.

PROBATIONARY PERIOD

Western Global Airlines has a probationary period of 90 days for new employees. During the probationary period, your

supervisor will evaluate your performance and abilities to make sure that you can perform your job satisfactorily. The

probationary period also gives you time to decide if the new job meets your expectations. Since your employment with

Western Global Airlines is voluntary and at will, you may terminate your employment at any time during or after the

probationary period, with or without cause or advance notice. Likewise, Western Global Airlines may also terminate your

employment at any time during or after the probationary period, with or without cause or advance notice.

During and at the end of the new hire probationary period, your supervisor will discuss your job performance with you.

During the course of the discussion, you are encouraged to provide your comments and ideas as well.

BACKGROUND CHECKS

Western Global Airlines recognizes the importance of maintaining a safe workplace with employees who are honest,

trustworthy, qualified, reliable, and non-violent, and who do not present a risk of harm to their fellow employees or our

clients. As part of the Company’s focus on these concerns and interests, Western Global Airlines reserves the right to

investigate an employee’s prior employment history, personal references, and educational background, as well as other

relevant information. Consistent with legal requirements, the Company also reserves the right to obtain and to review

an applicant’s or an employee’s criminal history, and other relevant information, and to use such information when

making employment decisions. Credit reports will only be requested in very limited situations where a credit report is

permitted under applicable state law based upon the nature of your job duties. Likewise, criminal history reports will

only be requested and used in compliance with applicable law. You may also be requested to provide fingerprints when

required for your job. If an applicant indicates on his or her application that they would prefer that Western Global

Airlines not contact the applicant’s current employer, and the applicant is subsequently hired, Western Global Airlines

will complete the applicant’s background check by contacting the previous employer at that time. Failure to successfully

complete a background check (including fingerprinting) will result in an applicant’s denial of employment, the denial of a

transfer request, or separation from employment, as appropriate. Pilots will be subject to PRIA records checks. Pilots will

be required to sign all authorization forms related to PRIA records if required. PRIA records will be maintained by the

Company. In addition, the Company will release required PRIA information to future employers when receiving a

properly signed PRIA request.

COMPANY AND EMPLOYEE PROPERTY

Each of us has the responsibility to safeguard the assets of Western Global Airlines.

Equipment essential to accomplishing job duties is often expensive and may be difficult to replace. When using Company

property, employees are expected to exercise care and respect, perform required maintenance, and follow all operating

instructions, safety standards, and guidelines while guarding against waste and abuse.

The Company requires that all equipment be in proper working order and safe to work with at all times. If any equipment

appears to be damaged, defective, or in need of repair, do not use it until a qualified technician certifies that it is

repaired and serviceable in accordance with government regulations. Never try to fix broken equipment yourself. Please

notify your manager of any equipment breakdown as soon as it happens. If the breakdown requires emergency repairs,

your supervisor/manager will try to deal with the emergency situation as soon as possible. Prompt reporting of damages,

defects, and the need for repairs could prevent possible personal injury and deterioration of equipment. Please ask your

supervisor/manager if you have any questions about your responsibility for maintenance and care of equipment used on

the job.

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Employees are responsible for all Company property, materials, or written information issued to them or in their

possession. You may be asked to sign an acknowledgment of receipt of Company property issued to you. A copy of such

form can be found on ADP. All Company property must be returned on or before an employee’s last day of work, and in

the same condition as when it was received. You may be responsible for the replacement cost of Company property not

returned upon request or returned in damaged condition.

All employees and business associates must protect from unauthorized disclosure or misuse of all non-public information

received about the Company, including, for example, technology, competitive position, strategy, unreleased financial

results, and customer information.

Company cars are for Company business only, and only authorized employees may drive Company cars. Employee

spouses, children, friends or anyone other than the employee may not operate these vehicles, unless an emergency

arises. A violation of these rules, or excessive or avoidable traffic and parking violations, may result in disciplinary action,

up to and including termination.

Employees who are required to drive a Company vehicle or their own vehicle on Company business will be required to

show proof of a current, valid driver’s license and current effective auto insurance coverage prior to the first day of

employment. Employees who drive their own vehicles on Company business will be reimbursed at the current IRS rate.

Western Global Airlines is not responsible for personal property that is lost, damaged, or stolen. If you bring personal

property onto Company property, you are responsible to keep track of the item(s). The Company prohibits any items on

Company premises that are sexually suggestive, offensive, or demeaning to individuals or groups. For security reasons,

you should not leave personal belongings of value in the workplace. Personal items and desks are subject to inspection

and search, with or without notice, and with or without your prior consent. Because even a routine search for Company

property might result in the discovery of an employee’s personal possessions, employees are encouraged not to bring

into the workplace any item of personal property which they do not want to reveal to the Company.

In addition, all desks, offices, work spaces, credenzas, cabinets, email, telephone systems, office systems, computer

systems, Company vehicles and other areas or items belonging to the Company are open to the Company and its

employees.

Employees must have no expectation of privacy in any of these areas:

Personal items and messages or information that an employee considers private should not be placed or kept in desks,

offices, workspaces, credenzas, cabinets, email, telephone systems, office systems, computer systems, Company vehicles

and other areas or items belonging to the Company.

Desks and work areas must be kept clean, and are to be used only for work-related purposes. Company property is

subject to inspection at any time, with or without prior notice. Prior authorization must be obtained before any Company

property may be removed from the premises.

Terminated employees should remove any personal items at the time they leave us. Personal items left in the workplace

by previous employees are subject to disposal if not claimed at the time of your termination.

LEGAL COMPLIANCE

Western Global Airlines is committed to ensuring our Company exhibits high standards of ethical business conduct and

complies with all applicable laws and regulations. The airline industry is highly regulated, and it is important that we

work together as a team to ensure compliance with our legal obligations. As part of our commitment to maintaining a

culture of compliance, every employee has an obligation to:

 Comply with all applicable governmental laws, rules and regulations and Company policies in the performance

of their job duties;

 Be sensitive to situations that could lead to unlawful or unethical business conduct and avoid engaging in such

conduct;

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 Learn and follow any subject-specific policies and procedures related to your job;

 Promptly raise any concern that you or others may have about possible violations of law or procedure;

 Understand the options every employee has for raising compliance concerns; and

 Cooperate with any investigations by the Company or its legal counsel into concerns about a possible violation

of law or policy.

If you would like assistance in understanding this policy or the laws and policies that apply to you in your work, please

contact the Director of Safety at safety@westernglobal.aero and Manager of Human Resources at

HR@westernglobal.aero.

WHISTLEBLOWER AND COMPLAINT POLICY

Western Global Airline’s Whistleblower and Complaint Policy is designed to provide guidance to employees in reporting

known or suspected improper activities. The policy provides employees with confidential, anonymous avenues for

making reports. The policy requires employees to report to their immediate supervisor any and all known and suspected

violations of: (1) laws, governmental rules and regulations (including but not limited to safety-related laws and

regulations); (2) accounting, internal accounting controls and auditing matters; and (3) any Company safety or other

policies or rules. Employees should also report situations where they feel they have been requested to participate in any

of the above conduct or where they have refused to participate in such conduct but are being subject to retaliation for

such refusal. This includes concerns by employees and complaints or reports received from persons outside the

Company. Reports should include as much detail as possible, since the ability to investigate will be largely dependent on

the quality and specificity of the information. In the event that you have a concern or complaint, you should contact the

Director of Safety at safety@westernglobal.aero and Manager of Human Resources and HR@westernglobal.aero.

ENDING THE EMPLOYMENT RELATIONSHIP

Western Global Airlines recognizes the right of any employee to terminate employment with Western Global Airlines on

a voluntary basis. You are encouraged to discuss your impending resignation with your supervisor to ensure that all

options have been considered. As a matter of courtesy, you are asked to give as much notice of your resignation as

possible to your supervisor. At a minimum, we request two weeks advance notice.

Paid Time Off (PTO) will not be included as calendar days during the notice period. The notice period may be extended

by the number of PTO days you take during this time period. Upon separation of employment, employees will be paid for

unused PTO that has been accrued through their last day of work.

Exit Interviews

When you terminate employment with Western Global Airlines, you will have the opportunity to complete an exit

interview with the Manager of Human Resources. The exit interview is important because your impressions and/or

constructive feedback may provide information that could result in the improvement of the working environment.

Returning Company Property

Your Handbook, ID Badge, building key card, phone, laptop computer and any other items issued or provided to you that

are the property of Western Global Airlines must be returned when you terminate employment. You will be subject to a

charge for failing to promptly return such property. You are also responsible for satisfying all outstanding financial

obligations you may have with the Company.

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WORKPLACE SAFETY

SUBSTANCE ABUSE

Western Global Airlines is a drug-free environment. Specifically, the Company is committed to having a workplace free

from the improper use of narcotics and other controlled substances (commonly referred to as illegal drugs), the abuse of

alcohol, and the misuse of legal or prescription drugs. Their sale, use, and abuse, when connected to the work

environment threatens the safety, morale, and public image of both you and the Company. All positions that may be

safety sensitive will be placed in a DOT random pool for random drug and alcohol testing. To the extent of any conflict

between this policy and then applicable DOT requirements and regulations, the DOT requirements and regulations shall

control.

The following practices will be used to ensure a drug free environment:

• Use, presence in the body, sale, distribution or possession of illegal drugs by employees, while present on

Company premises or during scheduled working hours, including break or meal periods, is strictly prohibited

and is grounds for discipline, up to and including termination.

• An employee who is found to be involved in the sale, solicitation, or dealing of illegal drugs will be subject to

termination.

• An employee who is taking prescription medication or other legal drugs that might impair your physical or

mental faculties should provide prompt notice of this fact to his/her supervisor. Employees should not report to

work under the influence of any drug that creates an impairment or a safety risk.

• The use or possession of alcoholic beverages on Company premises, except for authorized events, is also

prohibited.

• Reporting to work or working under the influence of alcohol, illegal drugs, prescription medication or other

legal drugs that might impair your physical or mental faculties is prohibited and is grounds for discipline, up to

and including termination.

• Any current employee who recognizes their own need for counseling or medical assistance due to dependence

upon drugs or alcohol may voluntarily contact their supervisor or the Manager of Human Resources to receive

confidential assistance in determining what options are available and ways in which the Company may support

his/her recovery or you may contact EAP (Employee Assistance Program) at: 800-964-3577, 24 hours/day, 7

days/week.

Western Global Airlines may, at its discretion, conduct substance abuse screening and/or alcohol analysis under any of

the circumstances described below:

• Pre-employment substance abuse screening

• Safety sensitive (including for example):

o Pilot

o Aircraft Mechanic

o Dispatcher

o Loadmaster

o Other safety sensitive position

• After any on-the-job accident where personal injury requiring medical treatment or damage to Company

property occurs.

• Where actions of employees give rise to reasonable suspicion of alcohol or substance abuse; e.g. observed

alcohol or substance abuse, or impaired physical state.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 14

• Direct observation of drug/alcohol use, or the symptoms of being under the influence of a drug or alcohol.

• Abnormal behavior while at work or a significant deterioration in work performance.

• A report of drug or alcohol use, or the symptoms of being under the influence of a drug or alcohol, provided by

a reliable and credible source.

• Evidence that an individual has tampered with a drug test.

• Information that an employee has caused, contributed to, or been involved in an accident while at work.

• Evidence that an employee has used, possessed, sold, or solicited drugs while working or while on the

employer’s premises or while operating the employer’s vehicle, machinery, or equipment.

Substance abuse screening may include testing for some or all of the following drugs:

• Amphetamine

o Also known as: speed

o Pharmaceutical names: Dexedrine, Benzedrine

• Cocaine

o Also known as: coke, crack, rock cocaine

• Marijuana/Cannabinoids

o Also known as: dope, weed, hemp, hash, Colombian, sinsemilla

o Pharmaceutical name: Marinol

• Phencyclidine

o Also known as: PCP, angel dust

o Codeine

• Morphine and/or Heroin

o Also known as: smack, tar, chasing the tiger

o Pharmaceutical names: Duramorph, Roxanol

• Methadone

o Also known as: fizzies

o Pharmaceutical names: Amidone, Dolophine

• Propoxyphene

o Pharmaceutical names: Darvon, Darvocet, Noyopropoxyn

Western Global Airlines will determine the appropriate action, according to the Handbook, should testing indicate

substance abuse or alcohol. If you refuse to participate in substance abuse testing, your employment may be terminated.

Employees should report potential violations of the Company’s Substance Abuse policies to their immediate supervisor,

the Manager of Human Resources, or department head. Reports may be submitted verbally or in writing. Reports may be

anonymous.

Timely Completion of Drug Test

All candidates must take a drug test as part of their conditional offer of employment. All conditional offers of

employment extended to job candidates are contingent upon completion of this requirement within the scheduled time

period. Failure to take the drug test or a confirmed positive result on a drug test will result in revocation of a conditional

job offer or termination.

Option to Re-Test

If a candidate believes a positive drug result is incorrect, he/she may decide to re-test the same specimen at his/her own

expense. The Company will not accept drug results from sources other than those authorized by the Company.

Searches

Western Global Airlines reserves the right to search an employee, an employee’s work area if Western Global Airlines

has reasonable suspicion that the “no alcohol or drugs” policy may have been violated in accordance with applicable law.

Refusal to cooperate in these procedures may result in discipline or termination of employment.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 15

Employee Assistance

Western Global Airlines provides an Employee Assistance Program (EAP) to all employees at no cost that offers

confidential counseling and referral services to employees for assistance with such problems as drug and/or alcohol

abuse or addiction. EAP: 800-964-3577 24 hours/day, 7 days/week.

It is in the best interest of the employee to voluntarily seek assistance from the EAP prior to reaching a point where poor

judgment, performance, or behavior issues may lead to disciplinary action. Employees may contact the Employee

Assistance Program at any time for confidential assistance. Participation in the EAP after disciplinary action has begun

will not have any effect on current or future disciplinary actions.

EDUCATION AND AWARENESS PROGRAM

Western Global Airlines has established a Drug-Free Awareness Program which is designed to inform employees of the

dangers of drug abuse in the workplace, and ensure that they are familiar with the Drug-Free Workplace policy and with

the corrective actions that will result from a violation of this policy.

Occasionally, employees will be asked to attend a Drug-Free Awareness Program session, or otherwise provided with

information about the Program. Employees will be provided with current information about the Company’s Employee

Assistance Program (EAP) and other available programs offering counseling and rehabilitation. FAA-regulated employees

will be educated regarding additional drug and alcohol rules applicable to them.

WORKPLACE VIOLENCE

Western Global Airlines is committed to preventing workplace violence and to maintaining a safe work environment. The

Company has adopted the following guidelines to deal with intimidation, harassment, bullying, or other threats of (or

actual) violence that may occur during business hours or on its premises. All employees, including supervisors,

contractors, and temporary employees, should be treated with courtesy and respect at all times. Employees are

expected to refrain from fighting, “horseplay,” or other conduct that may be dangerous to others. Except where

permitted by state law, firearms, weapons, and other dangerous or hazardous devices or substances are prohibited from

the premises of Western Global Airlines.

Conduct that threatens, intimidates, or coerces another employee, a customer, or a member of the public at any time,

including off-duty periods, will not be tolerated. This prohibition includes all acts of harassment, including harassment

that is based on an individual’s protected status. All threats of (or actual) violence, both direct and indirect, should be

reported as soon as possible to your immediate supervisor, department head, or Manager of Human Resources. This

includes threats by employees, as well as threats by customers, vendors, solicitors, or other members of the public.

When reporting a threat of violence, you should be as specific and detailed as possible.

All suspicious individuals or activities should also be reported as soon as possible to your supervisor. Do not place

yourself in peril. If you see or hear a commotion or disturbance near your work station, do not try to intercede or see

what is happening. The Company will promptly and thoroughly investigate all reports of threats of (or actual) violence

and of suspicious individuals or activities. The identity of the individual making a report will be protected as much as is

practical.

In order to maintain workplace safety and the integrity of its investigation, the Company may suspend employees, either

with or without pay, pending investigation. Anyone determined to be responsible for threats of (or actual) violence or

other conduct that is in violation of these guidelines will be subject to prompt disciplinary action up to and including

suspension or termination of employment.

Western Global Airlines encourages employees to bring their disputes or differences with other employees to the

attention of their immediate supervisor or the Manager of Human Resources before the situation escalates into

potential violence. The Company is eager to assist in the resolution of employee disputes and will not discipline

employees for raising such concerns.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 16

SAFETY

Western Global Airlines is committed to providing a safe work environment for all of our employees. All employees of

the Company are to follow safe work practices. It is the responsibility of the supervisor to enforce safety procedures and

address the safety concerns of their employees.

Reporting Emergencies

In the event of an emergency during normal work hours, please proceed to a safe area and call 911.

Emergency Evacuation

When instructed to evacuate the premises, or you hear the evacuation alarm, you should:

• Stop all work

• Walk to the nearest exit and leave the building

• Await instructions

• Do not re-enter the building until instructed to do so

• Specific procedures may vary from site-to-site

Injuries, Accidents, and Other Reportable Events

If you feel a situation at work presents a safety or health hazard, or creates a safety or health risk, you are required to

report it to your immediate supervisor, as well as to the attention of the Director of Safety at safety@westernglobal.aero

and Manager of Human resources at HR@westernglobal.aero. All work-related injuries, no matter how minor, must be

reported immediately. All employees with knowledge of an injury must provide written details no later than the end of

their next work day. Injured employees are required to submit written details and any required workers’ compensation

paperwork once the injury has been properly treated.

In addition, it is the responsibility of all employees to immediately report any accidents or damage to the property of

Western Global Airlines or others, regardless of the nature or extent of the damage. This is an integral part of the

Company’s commitment to safety. This allows the Company to promptly investigate potential safety concerns and

hazards, and take remedial or other action where appropriate.

You should report any injuries, accidents, and property damage or safety concerns via written notice. Include as much

detail about the situation as possible. The Director of Safety is available to assist you in preparing the written

statements, and to answer questions in regards to whether a particular condition creates a safety concern.

Communicable Diseases

In order to prevent the spread of communicable diseases, if you are (a) diagnosed with an illness that is communicable in

the workplace, such as active Tuberculosis or SARS (Severe Acute Respiratory Syndrome), or (b) if you believe you may

have been exposed to a person with a communicable illness, or (c) if you have recently visited a location in which there

has been an outbreak of such an illness and you do not feel well or are exhibiting any symptoms, you must report this to

the Director of Safety at safety@westernglobal.aero and to Manager of Human Resources at HR@westernglobal.aero.

All reports of such illness will be kept confidential to the extent reasonably possible/required by applicable law; however,

full confidentiality cannot be guaranteed. If a leave of absence is necessary, you will be provided any and all leave

benefits for which you are eligible. The Company will respond promptly to any allegations of harassment or retaliation.

INCLEMENT WEATHER

The Company will make every effort to maintain normal work hours during inclement weather. When severe weather

occurs, it is necessary to initiate a plan of action to ensure adequate office support is available to our customers during

all types of weather. The decision of closed or delayed operations is governed by the affected operations. Headquarters

decisions will be determined by the Manager of Human Resources with the approval of senior leadership. Should the

Company choose to close on a scheduled workday prior to its start; all efforts will be made to make the decision

between 5:00 am and 6:00 am.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 17

In the event of bad weather conditions the following actions will take place:

• Weather updates will be provided by email.

Employees are free to contact their supervisor for more direction.

Should the Company be closed due to extremely harsh weather, all regular full-time employees, contractors, temporary

employees, will be paid for a normal day of work. Once the office reopens for business, all full-time employees,

contractors, and temporary employees will be expected to make reasonable efforts to get to work. However, it is

important to observe weather conditions in his/her area and decide whether it is unduly hazardous to attempt to drive

to work when weather conditions are severe. We do not expect anyone to take an unreasonable risk attempting to drive

to work. If you are unable to report to work, you should call your supervisor to report an absence as early as possible,

but no later than one hour prior to the start of your shift. Non-exempt employees who are not able to report to work will

not be paid for the day. PTO will be taken if available. If PTO is unavailable, hours will be unpaid. Anyone arriving late to

work will be excused, but will be paid only for hours worked. PTO will be taken if total hours worked for the week are

under 40 hours.

If the decision has been made to open the office or facility on a delayed schedule (e.g. 10:00 a.m.), the following payroll

guidelines have been established for non-exempt employees:

• Reporting to work before 10:00 am will receive a full day’s pay.

• Reporting after 10:00 am will be paid for hours worked.

• Those who do not report to work will not be paid for that day. The day will be considered an excused absence

and PTO will be taken if available. If PTO is not taken, the hours will be unpaid.

On days when weather conditions worsen as the day progresses, Human Resources, with senior leadership approval,

may decide to close early. Once the decision has been made, it will be communicated to all employees via email.

Employees will be expected to remain at work until the appointed closing time, unless they receive permission from their

supervisor to do otherwise. If an employee feels they must leave before the office has officially closed, they can do so

provided they coordinate with their supervisors, but must either use PTO if available for the remaining hours left in the

day or for hours under 40 for the week. The time will be unpaid if PTO is unavailable. Departments that have employees

who work from home will be expected to work that day as usual. If you are provided the option to remain home during

inclement weather, the Company will not be responsible for any personal injuries or property damage if you attempt to

arrive at work. You should use your best judgment in deciding whether it is reasonable for you to attempt to get to work.

SMOKING

The Company maintains a smoke- and tobacco-free office. No smoking or other use of tobacco or similar products

(including, but not limited to, cigarettes, pipes, cigars, snuff, e-cigarettes/“vaping”, or chewing tobacco) is permitted

while on Company business, while in transit between work locations or assignments, while driving Company owned or

leased vehicles, while at client locations, while in any part of a Company building, or within 25 feet of the entire exterior

perimeter surrounding such Company building.

There are no designated smoking areas inside or on Company premises, nor does the Company allow smoking breaks

during the workday; i.e., no additional breaks beyond those allowed under the Company's break policy may be taken for

the purpose of using tobacco or similar products. If returning from a meal break during which you have used tobacco or

similar products, do not leave cigarette butts or other traces of litter or tobacco use on the ground or anywhere else.

Dispose of any litter properly in the receptacles provided for that purpose. All employees are expected to abide by this

policy in all respects while at work and violations of this policy will result in disciplinary action, up to and including

termination of employment.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 18

SECURITY

The Federal Aviation Administration Standard Security Program governs the Company for many purposes. It is

everyone’s responsibility to help keep our workplace secure from unauthorized intruders. It is the responsibility of all

Company employees and contractors to report any known network or privacy or security policy violation. Any suspected

privacy or security violation shall be reported immediately to the Director of Safety and/or Manager of Human

Resources.

After-hours access to the workplace is limited to those employees and contractors who need to work late. If you are

going to be working past our usual closing time, please let your supervisor know.

Company Identification Badges

It is the policy of the Company that each employee or contractor of the Company is required to display an identification

badge in work places located in, on, or around the grounds of the Company. Badges must be visibly displayed above the

waist at all times. It is the responsibility of each department to coordinate with the Manager of Human Resources to

arrange a time for new employees or contractors to have their picture taken and card issued by their first day of

employment. Lost, stolen or misplaced badges must be reported within 24 hours after the fact to the Manager of Human

Resources. The employee or contractor is responsible for the $25.00 replacement fee. ID badges that are damaged in the

course of normal usage will be replaced at no charge. ID badges are the property of the Company and must be

surrendered upon request of the Company and upon termination of employment.

Visitors in the Workplace

To provide for the safety and security of all employees, contractors, part-time employees, and the facilities, only

authorized visitors are allowed in the workplace. Restricting unauthorized visitors helps maintain safety standards,

protects against theft, ensures security of equipment, protects confidential information, safeguards the Company

welfare, and avoids potential distractions and disturbances.

Employees should wear their Company-issued and other required airport badges and are encouraged to challenge those

who are not wearing a badge.

Visitors must wear an identification badge or be escorted at all times when they are in our workplace. It is recommended

that visitors be escorted to their destination for safety and security reasons. They must return the visitors badge when

they leave Company premises. Employees are responsible for the conduct and safety of their visitors.

Delivery personnel will be permitted to make their deliveries to the appropriate areas without a badge or pass provided

they do not go outside normal areas of pick-up and delivery.

WORKPLACE EXPECTATIONS

CONFIDENTIALITY

All non-public information about Western Global Airlines and its affiliates should be considered confidential information.

It is very important to Western Global Airlines that we protect our confidential business information and trade secrets.

Confidential information means any and all information that is not available to the general public. It includes, but is not

limited to, the following:

• compensation data

• computer processes

• computer programs and codes

• customer lists

• customer preferences and related information

• employee information and data

• financial information

• marketing strategies

Western Global Airlines Employee Handbook, May 2018 Edition Page | 19

• new materials research

• standard operating procedures

• pending projects and proposals

• proprietary production processes

• strategic plans and processes

• any company contracts and agreements

• vendor and supplier information and data

It is the responsibility of all Western Global Airlines’ employees and business associates to protect the interests and

privacy of Western Global Airlines, their coworkers, and customers. You may not inappropriately discuss, solicit,

disclose, or use for your personal benefit information in company records, files, databases, employee/customer

correspondence, internal company correspondence, personnel files or work schedules. All employees will be asked to

sign a Confidentiality, Non-Solicitation/-Disparagement, and Title to Work Product Acknowledgement (Appendix B) as a

condition of employment. If you improperly use or disclose a trade secret or confidential business information, you will

be subject to disciplinary action, including termination of employment and legal action. This applies even if you do not

receive any benefit from releasing the information.

STANDARDS OF CONDUCT

Ethical Standards

The successful business operation and reputation of the Company is built upon the principles of fair dealing and ethical

conduct of our employees. The Company has an excellent reputation for conducting its business activities with integrity,

fairness, and in accordance with the highest ethical standards.

The continued success of the Company is dependent upon our employees’, customers’ and suppliers’ trust and we are

dedicated to preserving that trust. Employees owe a duty to the Company, customers, shareholders and the community

to act in a way that will merit the continued trust and confidence of the public.

The Company is committed to conducting its business in accordance with the highest ethical standards. Compliance with

legal requirements and restrictions represents only a minimum level of acceptable conduct. Where appropriate, you

must do more than merely act within the law; your conduct must withstand the closest scrutiny. Employees must

carefully avoid any actions or relations which would create even the appearance of compromising ethical standards and

report any such activities to their supervisors or department heads and the Manager of Human Resources. The Company

expects that all its business transactions will be the result of legal, open, and honest competition and its business will be

conducted in an ethical and moral manner.

In general, the use of good judgment, based on high ethical principles, will guide you with respect to lines of acceptable

conduct. If a situation arises where it is difficult to determine the proper course of action, the matter should be discussed

openly with your immediate supervisor at the Company. No one will be asked or expected to compromise these

standards.

Code of Conduct

When groups of people work together, reasonable rules are necessary to conduct an orderly business and make working

conditions more pleasant for everyone. Western Global Airlines has in effect the following standards of conduct in

addition to those addressed elsewhere in this Handbook. If you fail to work within these guidelines, you will subject

yourself to disciplinary action, up to and including termination and legal action. Any other types of unacceptable

behavior not specifically addressed, or violation of the business standards below, may also result in disciplinary action.

The following list of unacceptable behaviors is not intended to be all-inclusive, but merely illustrates the various types of

prohibited conduct that may result in disciplinary action:

• Violation of Company policies, safety standards or practices; or creating unsafe/unsanitary conditions.

• Reporting to work under the influence of drugs, alcohol, or in an unfit condition to work.

• Use of drugs or alcohol on Company property while conducting Company business.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 20

• Misrepresentation or falsification of Company records or paperwork including time/work records; furnishing

false information in an investigation.

• Unauthorized access of Company records, use of Company property or disclosure of proprietary information.

• Disruptive work behavior.

• Obscene or abusive language toward any manager, employee or customer; indifference or rudeness towards a

customer or fellow employee; any disorderly/antagonistic conduct on Company premises.

• Insubordination; refusing to obey instructions properly issued by your manager pertaining to your work; refusal

to help out on a special assignment.

• Willful acts or threats resulting in risk to actual injury to another employee or damage to Company property.

• Theft, misappropriation of funds or concealment of Company property from fellow colleagues, the Company or

clients.

• Smoking in prohibited areas.

• Any act of harassment, sexual, racial, or other; telling sexist or racist jokes; making racial or ethnic slurs.

• Possession of dangerous or unauthorized materials, such as explosives or firearms, in the workplace.

• Excessive absenteeism or any absence without notice; failure to report an absence or late arrival, or

unauthorized absence from work station during the workday; sleeping or loitering during working hours.

• Unauthorized use of telephones, mail system, or other Company-owned equipment.

• Originating, spreading, and taking part in malicious gossip or rumors about employees of the Company.

• Unauthorized disclosure of business "secrets" or confidential information; giving confidential or proprietary

information to competitors or other organizations or to unauthorized Company employees; breach of

confidentiality of personnel or Company information.

• Unsatisfactory or careless work; failure to meet production or quality standards as explained to you by your

manager.

• Speeding or careless driving of Company vehicles.

• Failure to immediately report any damage or accident involving Company equipment and vehicles.

• Failure or refusal to comply with instructions of Management or insubordination.

• Violating any employment policy or procedure, whether contained in this Handbook or not.

• Violation of the Company’s Code of Conduct & Ethics.

• Excessive attendance problems, such as absences, tardiness, or leaving work early; failure to report absences

properly.

• Failure to follow established policy or procedure or to comply with a reasonable request from your Supervisor.

These are only examples of violations that may result in discipline, suspension, or immediate discharge. Other situations

of a similar nature may arise and these too may result in discipline, discharge, and/or legal action

Duty to Avoid Conflicts of Interest

A conflict of interest arises when an individual’s personal interest, or that of a family member or friend, interferes in any

way, or even appears to interfere, with what is in the best interest of Western Global Airlines. All employees must, at all

times, conduct their activities, both business and personal, in such a manner that there is no conflict of interest with

their duties to Western Global Airlines. This includes but is not limited to conflicts of interest in hiring, employment of

relatives, selection of suppliers, supplier benefits, and misadministration of contracts.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 21

Each employee is expected to avoid any investment, interest or association which interferes, or might interfere, with the

independent exercise of his/her judgment in the best interests of the Company.

Each employee is expected to refrain from engaging in any course of conduct or transaction detrimental to, or in conflict

with, the interest of the Company.

A conflict of interest exists when an employee’s duty to give his/her undivided loyalty to the Company can be prejudiced

by actual or potential benefit from another source.

Conflict of Interest Policy

It is the policy of the Company and its affiliates that its operations are conducted according to the highest standard of

business integrity, and that its employees avoid situations which might conflict with their responsibilities on behalf of the

Company.

Situations involving conflicts of interest may not always be clear-cut. This policy contains guidelines which are intended

to assist employees in making decisions on behalf of the Company and avoiding conflicts of interest. An employee faced

with deciding a difficult situation should consider whether he or she would feel uncomfortable if the decision became

public knowledge. If the answer is yes, the decision must comply with this policy and be disclosed to the department

head, the Manager of Human Resources, and the CEO/President.

Employees should not hesitate to ask their supervisor if they have questions concerning this policy. The Manager of

Human Resources should also be consulted if there are further questions regarding interpretation or applicability of this

policy in general, or with regard to a specific situation.

Disclosure of Significant Financial Interests

If an employee owns, directly or beneficially, a significant financial interest (> 3%) in an actual or potential supplier,

competitor, corporation, firm or business with which the Company conducts, or is considering conducting any business

transaction, such employee shall immediately disclose the relevant facts in the manner described in the relevant

paragraph below.

If an employee is in a position to influence decisions of an actual or potential supplier, competitor, corporation, firm or

business with which the Company conducts, or is considering conducting, any business transaction, such employee shall

immediately disclose the relevant facts in the manner described in the relevant paragraph below.

No such employee will be assigned to any position where he or she may influence decisions with respect to any such

supplier, or competitor or such business transaction, without the prior written approval of the CEO and the Manager of

Human Resources.

Ownership of any significant financial interest, whose acquisition is governed by this policy, shall be disclosed in writing

in the manner described below, regardless of whether such interest was acquired before the effective date of this policy

or acquired subsequently in any manner.

Prohibition of Certain Financial Interests

Unless approved by the CEO and Manager of Human Resources of the Company, no employee shall purchase, directly or

indirectly, a significant financial interest (>3%) in (a) any actual or potential supplier, or direct/indirect competitor of the

Company or (b) any corporation, firm or business in which the Company has any financial interest.

No employee shall acquire any interest in any corporation, firm or business, when he/she knows, or has reason to

believe, that the Company or one of its affiliates is interested in acquiring a significant portion of its capital stock. No

existing significant financial interest prohibited from being acquired hereunder shall be increased after the effective date

of this policy, and any such interest should be eliminated as soon as practicable.

Director, Officer, Etc. of Another Company

An employee shall obtain, in writing, the approval of the CEO and the Manager of Human Resources before serving as a

board member, director, officer, partner, employee, consultant, agent, representative of any corporation, firm or

Western Global Airlines Employee Handbook, May 2018 Edition Page | 22

business in addition to Western Global Airlines, and in no case serve in any of these capacities at a supplier or

competitor.

Acceptance of Commissions, Fees, Benefits or Privileges

No commission, payment, service, benefit, gain, loan or promise of future benefit shall be accepted by any employee or

member of his/her family, from any actual or potential customer, supplier or competitor of the Company.

Insignificant gifts (other than money which is not permitted to be accepted), such as advertising novelties, may be

accepted by employees from a customer, supplier, or competitor of the Company so long as such gifts do not obligate

the employee and are not being provided as a quid pro quo for services or special considerations. Any gift having a value

in excess of fifty dollars ($50.00) must be reported in writing to the employee’s immediate supervisor and department

head with a copy forwarded to the Manager of Human Resources for filing in the employee’s personnel file.

No employee, while employed by the Company, shall seek or accept employment from any actual or potential customer,

supplier, competitor (direct or indirect), firm, business or persons engaged in the same or similar type services as the

Company or conduct any business with such entities or persons outside of the Company.

This policy is not intended to prohibit the participation in customary business luncheons or dinners or other

entertainment which is normal in the everyday course of business and is reasonable, subject to pre-approval in writing

by the department head.

All employees of the Company must ensure that, to the best of their ability, family members and associates conform to

this policy.

Procedure for Disclosing Information / Granting Approvals and Exceptions

Disclosures of personal interests or other circumstances which might constitute conflicts of interest, as defined in this

Handbook, are to be made promptly, in writing, to the employee’s immediate supervisor, Departmental Vice President,

and the Manager of Human Resources, who will hold the matter in confidence and will give such advice and direction as

appropriate. If appropriate, approvals or exceptions may be granted.

Each employee affected by this policy will, if requested, from time to time acknowledge in writing in the form distributed

by or on behalf of the Company that he/she understands this policy and practice, and is in compliance with it, noting any

relevant exceptions that have been approved, and will adhere to its provisions.

CRIMINAL CONVICTIONS

Employees must inform the Manager of Human Resources within five (5) days if they are convicted of a crime involving

drug and alcohol-related activity. A conviction is defined as a finding of guilt, including a plea of guilty or no contest, or

imposition of sentence, by any judicial body.

ATTENDANCE

Punctuality and regular attendance are essential to ensure operational reliability. In order for the Company to achieve its

goals, employees are required to maintain a satisfactory record of attendance. Employees are expected to be punctual

and regular in attendance. Any tardiness or absence causes problems for your fellow employees and your supervisor.

When you are absent, your workload must be performed by others, just as you must assume the workload of others who

are absent.

Employees are expected to report to work as scheduled, on time, and prepared to start work. Employees are also

expected to remain at work for their entire work schedule, except for meal periods or when required to leave on

authorized Company business. Late arrival, early departure, or other absences from scheduled hours are disruptive and

must be avoided.

Punctuality and attendance are taken into consideration during a performance review and are also factors which may

warrant termination of employment. Repeated absenteeism or tardiness (whether excused or not) will not be tolerated.

Continuing patterns of absences, early departures, or tardiness—regardless of the exact number of days—may warrant

disciplinary action, up to and including termination of employment. Emergency or extraordinary circumstances

Western Global Airlines Employee Handbook, May 2018 Edition Page | 23

concerning an absence or tardiness will be considered and the organization reserves the right to make an exception to

this policy if, in its sole discretion, an exception is warranted. Repeated car failures, missing the bus, consistently failing

to arrange back up childcare or oversleeping do not constitute an emergency or extraordinary circumstances. The

Company reserves the right to determine what is considered excessive absenteeism.

Definitions:

Unscheduled Absence

Failure to report to work on a scheduled workday or working less than half of a scheduled workday due to tardiness or

leaving early without a written and approved time off request from at least the previous day. Absences on consecutive

days for the same reason will count as one unscheduled absence under this policy. Some examples of unscheduled

absences include absences due to car trouble, caring for a family member who has the flu, and home emergency.

Scheduled Absence

A scheduled absence occurs when an employee requests time off in a timely manner in accordance with Company’s Paid

Time Off Policy. Some examples of scheduled absences include approved vacation, holidays, jury duty, military related,

bereavement leave, and FMLA leave.

Tardy

Failure to report to an employee’s assigned work area within 15 minutes of the scheduled start time, including returning

from breaks and meal periods.

Pattern Absences

Unscheduled absences the day before or after a scheduled holiday, or vacation; on a desirable day off, a specific day of

the week, or a weekend; a specific or unique work day; or other paid time off is accrued.

No call/no show

An unscheduled absence without proper notification to the employee’s supervisor or department. If you fail to report to

work without any notification to your supervisor and your absence continues for a period of three (3) days, the Company

will consider that you have abandoned your job and have voluntarily terminated your employment.

Excessive Absenteeism

Refers to repeated occurrences of unscheduled absence(s) and/or tardiness that are unrelated to approved time off.

Notification of any unscheduled absence or tardiness must be made as far in advance as possible. An employee who will

be unable to report to work as scheduled, tardy, or leaving early must contact his/her supervisor or the department’s

designee as far in advance as possible and at the latest prior to the start of the shift. Notification of an absence or

tardiness will not excuse it.

Excessive absenteeism or tardiness (excused or not) may be grounds for discipline (up to and including termination of

employment), depending on the circumstances. Each situation of excessive absenteeism or tardiness will be evaluated

on a case-by-case basis. However, even one no call/no show absence may be considered excessive.

If an employee is absent for three or more consecutive days due to illness or injury, and no prior approval was granted

for the absence, a physician’s statement may be requested verifying the reason for the absence and its beginning and

expected end dates.

PERSONAL APPEARANCE

One of Western Global Airlines’ primary objectives is to have employees project a professional image, promote a

productive work environment and comply with health and safety standards while taking advantage of casual and relaxed

clothing. Our business appearance and image are important to us, however, we respect individual preference and choice

in dress and appearance, and therefore promote a business casual work environment. We are confident that employees

will use their best judgment in following our dress and attire guidelines. We ask that all employees make certain that

their appearance is well groomed and clean, and that clothing is appropriate, neat, clean and well-fitting. While relaxed

business attire is acceptable within the stated guidelines, we want to ensure that our environment does not jeopardize

professionalism, productivity or safety.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 24

Western Global Airlines employees who interact with clients, prospective clients, and the community outside of the

Company as part of business activities represent the organization to the public. In such instances, a higher level of

professionalism in dress is required, and relaxed business attire must be replaced with professional attire such as

dresses, suits, slacks, pantsuits, skirts, blouses, collared shirts, blazers, and dress shoes.

General Hygiene and Personal Appearance

• Hair should be clean, managed neatly, and not extreme in color or style.

• Facial hair must be kept neat and well-trimmed.

• Makeup should be conservative.

• Nails should be clean and trimmed to a reasonable length.

• Jewelry may be worn with discretion and consideration of safety precautions. Dangling chains, necklaces, rings,

earrings, and bracelets could be dangerous. Excessive or unprofessional jewelry is not appropriate in the

workplace.

• Fragrances must be used sparingly as many individuals have allergies or sensitivities.

Dress and Apparel

• Clothing should be appropriate for the job and must be clean, neat, and in good repair.

• Clothing displaying pictures or comments must not be worn to work. While pictures or comments may not be

offensive to the wearer, they may be offensive to others.

• Modest dress is required. Revealing or excessively tight clothing is unacceptable. Spaghetti strap shirts, belly

shirts, tank tops, tube tops, bare midriffs, and deep U or V necks are not appropriate for the work environment.

• Shorts, t shirts or sweat suits are not allowed.

• Dresses and skirts should be of modest length.

• Headwear (baseball caps, sweatbands, sweatshirt hoods, etc.) is generally not allowed.

• Flip-flops are not allowed by any staff member.

• Office-acceptable denim pants/jeans are permitted on Friday of each week and should be accompanied by a

neat, professional, dressy-style shirt/top/blouse/jacket/pullover, etc.

• Office acceptable denim pants/jeans must be clean, neat, and in good repair and are further defined as: dark or

colored denim that is NOT distressed, cut off, ripped, paint-splattered, stained, skintight, excessively baggy,

sequined/bejeweled, faded, or frayed, and does not contain holes, cutouts, or patchwork.

Western Global Airlines designates those departments in which a standard uniform is mandatory. Anyone working in a

department with a standard uniform is required to wear the designated uniform at all times while on Duty.

Business casual dress may be pre-empted by the Company for customer visits or any other events.

Specific – Employees who are in doubt, or have questions about the specific personal appearance standards or dress

code should consult their supervisor or Manager of Human Resources. Any employee who, in the supervisor’s sole

discretion, appears for work in a manner that does not conform to the Company’s standards may be required to return

home to obtain appropriate attire, and the period of absence may be treated as unpaid leave. Repeated violations of this

policy will result in disciplinary action, up to and including termination of employment.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 25

ELECTRONIC MEDIA AND COMMUNICATIONS

The Company’s computer systems, voice mail, electronic mail (email), fax machines, text messages, instant messages

and/or any other similar business devices should only be used for business purposes. Any information transmitted by,

received from, or stored in such equipment is also the Company’s property. Employees should use these systems for

legitimate business purposes to advance the Company’s business interests. We reserve the right to listen to voice mail

messages (land line and Company cellphones), access email and text messages, and check computer and/or desk

contents to ensure compliance with this rule, without notice to you and/or in your absence. Passwords are “on loan” to

employees and, at all times, remain the property of the Company.

You have no individual privacy rights with regard to any information on the Company computers and/or

computer networks or other Company property. The Company reserves the right to monitor, access,

intercept, review and disclose the contents of all computer files, email messages, voice mail messages

and internet usage on the Company’s computers and/or computer networks.

During working time, you may not use electronic communication systems (including email, voice over internet systems,

and PDAs) to solicit for commercial ventures, religious or political causes, outside organizations, or other non-job related

solicitations, socializing, or social networking. While using the Company’s electronic communication systems, you should

respect all applicable copyright, trademark, or trade secrets laws. Installation of software may only be performed by

authorized employees of the Company.

The signature block and any other information/bylines on employees’ email address is standardized and must be

provided by the Company, and may not be altered.

Social Communications

We respect the right of employees to write a blog or post information on other blogs or websites on their personal time

using personal computer equipment. Employees may not post on a blog or social networking site during their working

time or at any time using Company equipment, Company email accounts, or Company property. If you identify yourself

as our employee on any website or blog, engage in blogging for any business-related purpose, or discuss our

organization, you must act in accordance with the following guidelines:

• Always add a disclaimer to the effect that "the views expressed on this site are the author's and do not reflect

the views of my employer."

• Do not post any material that is abusive, discriminatory, untrue, harassing, hateful, obscene, malicious, or

threatening to another person or entity, including the Company.

• Do not discuss our confidential information or our trade secrets or any internal business matters not generally

known outside our organization. Any confidential information that cannot be disclosed through an email, a

conversation, or a note also cannot be disclosed on a blog or social networking site.

• Respect all copyright and other intellectual property laws. For the Company’s protection as well as your own, it

is critical that you show proper respect for the laws governing copyright, fair use of copyrighted material owned

by others, trademarks and other intellectual property, including the Company’s own copyrights, trademarks

and brands.

Any conduct which is impermissible under the law if expressed in any other form or forum is impermissible if expressed

through a social networking site.

For example, the publication or posting of discriminatory, defamatory, or libelous information is forbidden. The

Company’s policies, including but not limited to the Equal Opportunity Policy and Harassment apply equally to employee

comments on social networking sites even if done on nonworking time. Employees are encouraged to review those

sections of the Handbook for further guidance.

All incidents relating to violation of this Company policy will be noted in the personnel file of the involved employee(s).

Repeated minor incidents, or misconduct that is more serious, will result in discipline up to and including termination.

Any conduct that violates local, state, or federal laws may result in the immediate loss of all computer privileges, and/or

termination of employment, and will be referred to appropriate law enforcement authorities. This includes the illegal

Western Global Airlines Employee Handbook, May 2018 Edition Page | 26

duplication of software and its related documentation. If you are aware that there has been a violation of this Company

policy, please notify the Manager of Human Resources.

Press Releases, Public Relations and General Communications

All public disclosures, materials or broadcasts must be properly reviewed, preapproved and coordinated in advance with

the Company prior to publication, dissemination or disclosure of information. Employees shall refrain from any

discussions with the media and will refer any request to the Company’s CEO, President and Senior VP of Operations.

Commenting on Rumors

It is the Company’s policy not to confirm or deny rumors or speculation about the Company or its business, except to

correct factually inaccurate information, so long as it is clear that the Company is not the source of the rumor.

CELL PHONE USAGE/TEXTING

Personal Cell Phones

The use of personal cellular phones, including text messaging, shall be limited during the work day, and Company cellular

phones shall be utilized for business purposes only and in a safe manner. During paid work time, employees are expected

to exercise discretion in using personal cellular phones. Excessive personal calls, including text messaging, during the

work day, regardless of phone used, can interfere with employee productivity and be distracting to others. The Company

encourages employees to limit personal calls during work time.

Employees are expected to make personal calls on non-work time whenever possible and to ensure that friends and

family members are aware of the Company’s policy. Flexibility will be provided in circumstances demanding immediate

personal phone use, but this immediate need should be communicated to and cleared with an employee’s supervisor. If

employee use of a personal cell phone causes disruptions, safety concerns or loss in productivity, the employee may

become subject to disciplinary action, up to and including termination.

Cell Phone Usage and Driving

Employees whose job responsibilities include regular or occasional driving should refrain from using a cellular phone

while driving. Safety must come before all other concerns. Employees are expected to regard all state driving regulations

for cell phone use by drivers as well. Provided there are no state specific restrictions, allow voice mail or your passenger

to handle calls when possible. Regardless of the circumstances, including slow or stopped traffic, employees are strongly

encouraged to pull off to the side of the road and safely stop the vehicle before placing or accepting a call.

Under no circumstances are employees allowed to place themselves at risk to fulfill business needs. Text messaging,

reading emails, and writing emails while driving is not allowable under any circumstance. Employees who are charged

with traffic violations resulting from the use of a cellular phone while driving on duty may be subject to disciplinary

action and personal liability resulting from such traffic violations. Repeated violations of this policy will result in

disciplinary action, up to and including discharge termination of employment.

SOLICITATION AND DISTRIBUTION

Every effort will be made to prevent interference with employees at work. Unauthorized solicitation and/or distribution

of any kind by employees during working time, which in any way interferes with work, is prohibited. Violations of this

rule will be subject to discipline, up to and including termination.

For the purposes of this rule, solicitation includes personal solicitations or soliciting on behalf of any organization support

for membership or participation in, or subscriptions of pledges to that organization. Solicitation also includes the

circulation of petitions or conducting any personal activities during working time. Working time is the time when you, or

the person who is soliciting you, are expected to be properly engaged in the performance of your work responsibilities

and tasks.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 27

EMPLOYEE RECORDS

Western Global Airlines maintains an official record for each employee. Master files are located in Human Resources.

These files contain Western Global Airlines’ records, including but not limited to, employment applications, employee

change forms, performance assessments, and counseling/disciplinary notices.

Additionally, federal laws impose certain recordkeeping requirements on employers. These documents are considered

confidential. Access is restricted to those individuals with a “need-to-know” status, such as your immediate supervisor or

Management. While you are at Western Global Airlines, if you wish to see your file, you should make your request

through Human Resources. An appointment will be arranged at a mutually convenient time.

It is important that your records be kept up-to-date. Changes in your personal status can affect whether or not you

receive Western Global Airlines mailings, whether or not the proper deductions are made from your paycheck, and

whether or not your dependents are covered by Western Global Airlines benefits. You should use the Company’s

communication system, ADP, to update your information in the event of a life event. The Manager of Human Resources

will receive notification from ADP when changes are made, such as:

• Marriage or divorce

• Birth or adoption of a child

• Change in dependent custody

• Death of a dependent

• Loss of medical coverage by a spouse

• Termination or commencement of a spouse’s employment

• Significant change in your spouse’s health coverage due to an employment change

• Address or telephone number change

• Legal name change

• Change in beneficiary for life insurance

In addition, please promptly update your information in the ADP self-service website whenever there are any changes as

indicated above.

EMPLOYMENT REFERENCES

Western Global Airlines’ policy in regards to references for employees who have left the Company is to disclose only the

dates of employment and the title of the last position held. The Company will provide a prospective employer with the

amount of the salary or wage last earned only with a written request. Exiting employees may provide a signed form

authorizing the Company to release reference information to potential employers.

It is the Company’s policy that only Human Resources is authorized to respond to requests for employee references and

verification of employment from financial institutions, etc. No other employee is authorized to provide references for

current or former employees. As an employee of Western Global Airlines, do not under any circumstances respond to

any requests for information regarding another employee unless it is part of your assigned job responsibilities. If it is not,

please forward the information request to your supervisor and the Manager of Human Resources.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 28

COMPENSATION

SAFE HARBOR

It is our policy and practice to compensate employees for all time worked and to do so in compliance with all applicable

state and federal laws. To ensure that you are paid properly for all time worked and that no improper deductions are

made, you must record correctly all work time and review your paychecks promptly to identify and to report all errors.

No one who is eligible for overtime should perform any work that is not authorized and recorded on his or her time card.

Review Your Pay Statement

We make every effort to ensure our employees are paid correctly. Occasionally, however, inadvertent mistakes can

happen. When mistakes do happen and are called to our attention, we promptly will make any corrections that are

necessary. Please review your pay statement when you receive it to make sure it is correct. If you believe a mistake has

occurred (including any improper deductions, under-reported hours of work or other error) or if you have any questions,

please use the reporting procedure outlined below.

Non-Exempt Employees

If you are classified as a non-exempt employee (which means that you are eligible for overage pay), you must maintain a

record of the total hours you work each day on your time card. Each employee must accurately maintain his/her time

card and verify that the reported hours worked are complete and accurate. Your time card must accurately reflect all

regular and overtime hours worked, any absences, late arrivals, early departures and meal breaks.

At the end of each pay period, your supervisor will review and approve your timecard. If your time card is not accurate,

notify your supervisor immediately. When you receive each pay check, please verify immediately that you were paid

correctly for all regular and overtime hours worked each work week. Unless you are authorized by your supervisor, you

should not work any hours that are not authorized. Do not start work early, finish work late, work during a meal break or

perform any other extra or overtime work unless you are authorized to do so and that time is recorded on your time

card.

Employees are prohibited from performing any "off-the-clock" work. "Off-the-clock" work means work you perform but

fail to report on your time card. Any employee who fails to report or inaccurately reports any hours worked will be

subject to disciplinary action, up to and including discharge.

It is a violation of the Company's policy for any employee to falsify a time card or to alter another employee's time card.

It is also a serious violation of Company policy for any employee at any level to instruct another employee to incorrectly

or falsely report hours worked or to alter another employee's time card to under- or over-report hours worked or to fail

to report any such misconduct. If any employee at any level instructs you to (1) incorrectly or falsely under- or over-

report your hours worked, (2) alter another employee's time records to inaccurately or falsely report that employee's

hours worked, or (3) conceal any falsification of time records or to violate this policy, you should report it immediately to

the Manager of Human Resources.

Exempt Employees

If you are classified as an exempt salaried employee, you will receive a salary which is intended to compensate you for all

hours you may work for the Company. This salary will be established at the time of hire or when you are classified as an

exempt employee. While your base salary may be subject to review and modification from time to time, the salary will

be a predetermined amount that will not be subject to deductions for variations in the quantity or quality of the work

you perform. Under federal and state law, your salary is subject to certain deductions. For example, absent contrary

state law requirements, your salary can be reduced for the following reasons (if authorized by state law and any

applicable contract):

• Full day absences for personal reasons.

• Full day absences for sickness or disability.

• Full day disciplinary suspensions for major safety violations or significant infractions of important written

workplace conduct rules.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 29

• Family and Medical Leave absences (either full or partial day absences).

• To offset amounts received as payment for jury and witness fees or military pay.

• The first or last week of employment in the event you work less than a full week.

• Any full work week in which you do not perform any work.

Your salary may also be reduced for certain types of deductions such as your portion of health, dental or life insurance

premiums; state, federal or local taxes, social security; or, voluntary contributions to a 401k plan. In any work week in

which you performed any work, your salary will not be reduced for any of the following reasons:

• Partial day absences for personal reasons, sickness, vacation or disability, unless the leave is FMLA-protected.

• Your absence on a day because the facility is closed on a scheduled work day.

• Absences for jury duty, attendance as a witness, or military leave in any week in which you have performed any

work.

• Any other deductions prohibited by state or federal law.

Please note: It is not an improper deduction to reduce an employee’s accrued paid time off for full or partial day

absences for personal reasons or sickness. Pursuant to our paid time off policies, employees who are absent for all or

part of a work day must apply accrued paid time off to that missed work time. After all paid time off is exhausted, no

partial day deductions will be made from the salary of a salaried exempt employee.

To Report Concerns or Obtain More Information

If you have questions about deductions from your pay or your wages, please immediately contact your supervisor or

Human Resources. If you believe you have been subject to any improper deductions or your pay does not accurately

reflect your time worked, you should immediately report the matter to your supervisor. If the supervisor is unavailable

or if you believe it would be inappropriate to contact that person (or if you have not received a prompt and fully

acceptable reply), you should immediately contact the Manager of Human Resources, or any other supervisor in the

Company with whom you feel comfortable.

Every report will be fully investigated and corrective action will be taken where appropriate, up to and including

discharge for any employee(s) who violates this policy. The Company will not allow any form of retaliation against

individuals who report alleged violations of this policy or who cooperate in the Company’s investigation of such reports.

Retaliation is unacceptable, and any form of retaliation in violation of this policy will result in disciplinary action, up to

and including termination.

PAYMENT OF WAGES

You will receive your paycheck on the 6

and 20

of each month (i.e., semi-monthly). The pay received on the 6

is for

the 15

through the last day in the prior month, and pay received for the 20

is for the 1

through the 15

. The pay

received on the 20

will also include any earned Per Diem pay and overage from the full month prior to the pay period.

If a payday is a holiday, every effort will be made to issue your paycheck the business day before the holiday. Your

paycheck will be direct deposited into your checking or savings account at the bank of your choice. There is no charge for

this service, and you will receive a complete payroll record of your earnings and deductions every payday. In addition,

you can access the ADP self-service website to view your pay history. To commence direct deposit, complete a Direct

Deposit Form and return it to the Manager of Human Resources. When changes are made to direct deposit accounts,

you are responsible for the accurate entry and submission of the account information. You can update your direct

deposit information via the ADP self-service website. Western Global Airlines is not responsible for late posting of your

direct deposit. It is always your responsibility to verify availability of funds before writing checks.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 30

RECORDING TIME WORKED

Western Global Airlines must comply with applicable laws that require records to be maintained of the hours worked by

employees. To ensure that accurate records are kept of the hours a non-exempt employee works (including overtime

hours where applicable), of the accrued paid-time off time an employee has taken, the amount of unscheduled time off,

and that employees are paid in a timely manner, employees and their department are required to maintain accurate

time and attendance records.

Time entry shall be completed by the employee on a daily basis. Employees have the responsibility for ensuring that their

actual hours worked, and time off/absences, are recorded accurately. Falsifying recorded time is an act of misconduct

and will be subject to corrective action, up to and including termination and legal action.

OVERTIME

When operating requirements or other business needs cannot be met during regular working hours, employees may be

scheduled to work overtime. Whenever possible, notification of these assignments will be provided with sufficient

notice. Overtime assignments will be distributed as equitably as practical to all employees qualified to perform the

required work. Non-exempt employees are eligible for overtime pay in accordance with applicable state and federal law.

Overtime will only be computed based on the number of hours you actually work. While you may be paid for time not

worked, such as holidays and PTO, these hours will not be included for the purposes of computing overtime. All overtime

must be requested and approved in advance by your supervisor and Departmental Vice President in accordance with

Company policy.

WORK WEEK, BREAKS, AND MEAL PERIODS

Standard work week in the office is 40 hours per week from 8:30 to 5:30 which includes a one hour unpaid meal break.

Business needs may necessitate changes in schedules, variations in starting and ending times, days of the week worked,

as well as variations in the total hours that may be scheduled each day and week. Because of the nature of our business,

your work schedule may vary depending on a department’s business needs. Supervisors will advise employees of their

schedules, which will include a ½-hour to 1-hour allocated to lunch.

Western Global Airlines recognizes the importance of breaks during the workday. Full-time employees will receive meal

and break periods according to state regulations of the state in which you work. If no state regulations exist, you will

receive a ½-hour to 1-hour unpaid meal period and up to two 15-minute paid breaks per day – one in the morning and

one in the afternoon. Breaks may not be scheduled during the first or last hour of work. From time to time, business

situations may arise that prevent you from taking a break. Your workday will not be shortened to compensate for missed

breaks. Additionally, breaks may not be taken in conjunction with the meal period.

WESTERN GLOBAL WAY (WGW) BONUS PROGRAM

All Western Global Airlines full time employees will be eligible for the WGW Companywide Bonus based on Company

performance (under development at time of implementation of this Handbook).

EMPLOYEE TRAVEL POLICY

Company Travel includes air transportation, lodging, and ground transportation.

Travel Approval and Bookings

All company travel must booked by the Crew Scheduling Department in accordance with the approved Company travel

policy.

Air travel will either be on the Company aircraft or Economy Class on commercial air carriers as scheduled and selected

by the Company. The travel will be arranged and paid for by the Company or a customer.

Western Global has defined Employee Travel into two distinct categories:

• Essential Travel: Any travel in support of specific live flight.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 31

• Nonessential Travel: Any travel not in support of a specific live flight.

Essential Employee Travel

Essential Travel includes anyone in direct support of a specific flight leg. This may be revenue or non-revenue.

Department leaders will provide Crew Scheduling with a crew roster or planned crew composition. Travel for these

individuals will be booked directly by Crew Scheduling in support of the specific live flight.

Nonessential Employee Travel

Nonessential Travel includes office personnel, mechanics travelling to perform required checks or maintenance for

aircraft not scheduled for any flying, travel required for training, etc.

Nonessential Travel will require a completed and approved Travel Request Form prior to submission to Crew

Scheduling for booking. This form is available on the Company shared drive, and must be submitted to and

approved, as designated on the Form, prior to any travel being booked.

Conference/Continuing Education Attendance Request

All requests to attend/register for conferences, continuing education, etc. will require a completed and approved

Conference Attendance Request Form. This form is available on the Company shared drive, and must be submitted and

approved, as designated on the Form, prior to registration to attend the event and any travel being booked. In addition,

supporting documentation such as an itinerary, meeting schedule or detailed course description, copy of invitation, copy

of agenda or other relevant documentation must be included when submitting the Form for approval.

Travel Reimbursements

Western Global Airlines will reimburse travelers for reasonable and necessary out of pocket expenses incurred in

connection with approved travel on behalf of the Company. All requests must be completed and submitted for approval

on a Travel Expense Form with details of the expenses incurred. In addition, supporting documentation such as receipts

must be included when submitting the Form for approval.

As a reminder, all Company reimbursed travel must be booked by the Crew Scheduling Department. The Crew

Scheduling Department will book travel only once it receives the appropriate and correctly completed request

forms. Travelers should verify that planned travel/attendance is approved before making any commitments to travel or

attend.

Travel Management System

Each Western Global Airlines traveler will have a profile within our Travel Booking System. Each traveler should go into

his or her profile to ensure the information Western Global Airlines has on file is correct: Make certain that your first,

middle and last names are identical to your Passport and your frequent traveler accounts. For those of you who have a

Global Entry Number, which is strongly recommended, please enter it under the TSA information, to ensure it will be

passed onto your travel reservations.

Frequent Traveler Programs

NOTE: Any points or miles earned are yours and can be used for your own personal travel.

In order to personally benefit from airline/hotel/car rental miles and points, improve traveler status, upgrade potential,

and potential for seat assignment priority, the Company strongly recommends that all travelers make sure that all their

frequent traveler programs and accurate numbers are notated in their travel profile. (Instructions for creating a log in

will be emailed to each employee’s Company email). Travelers may contact Crew Scheduling with any questions, at

crewscheduling@westernglobal.aero).

Air

Airline frequent traveler miles status will help you when Crew Scheduling books your tickets, as your status may unlock

seats not available to those without it at the time of booking, may waive baggage fees, raise boarding priority, upgrade

seats, etc. To benefit, please enter all your airline frequent traveler numbers in your profile. We recommend you join all

the various airline programs, and require that at a minimum you sign up for American, United, and Delta Airlines. When

Western Global Airlines Employee Handbook, May 2018 Edition Page | 32

entering these numbers in your profile, make sure to check the box stating “my status qualifies me for premium seating,”

so more seating options will be shown to Crew Scheduling when your flights are being booked. You may also set other

preferences such as: aisle/window seats, in front of/behind the wing, etc. Please note that preferences are not

guaranteed, but are taken into consideration at the time of booking. The system will also continue to search for a seat

that better fit your preferences after the booking has been made, if one becomes available.

Voluntary Denied Boarding is not permitted – When traveling on a Company purchased ticket, travelers may not

voluntarily give up their seats or accept compensation associated with a voluntary bump.

Hotel

Please be sure to join hotel frequent traveler programs. The more points you earn within hotel chains, the more rewards

you can possibly get, which include: room upgrades, free breakfast, and sometimes dinner/drinks, etc. Western Global

Airlines has relationships with many Hilton properties, so we strongly recommend you sign up for Hilton, as well as

Marriott and Wyndham Reward s. Be sure to enter as many hotel frequent traveler programs as you wish in your profile.

You may also set other preferences such as preferences for a smoking room (we will always book nonsmoking rooms), a

room away from elevators or ice machines, a room not on the first floor, etc. Please note that preferences are not

guaranteed, but are taken into consideration at the time of booking, and are also passed directly onto the hotel in your

reservation.

Rental Cars

Rental car points can possibly reward you with car upgrades, free rentals etc., and some airlines, rental car companies

and hotels have agreements with each other, so that if you earn points with one, you will gain with another as well.

Western Global Airlines has one agreement with Enterprise and National, as they are sister companies, but each has its

own program.

‘Emerald Club’ is a free loyalty program for the National brand which will link your membership directly to Western

Global Airlines’ account with them, allowing you to create a hard-coded profile to help streamline the rental process, and

to give you the ability to earn rental credits and a better selection of vehicles.

It is required that all travelers enroll in this free loyalty program. It provides value, such as bypass counters, free choice

and upgrades: http://www.nationalcar.com/offer/XZ35110

Crew Scheduling will book the rental as a ‘midsize class’. As an Emerald Club Member, when you arrive at the airport,

you will bypass the counter, head straight to where the rental cars are, proceed to the aisle marked ‘Emerald Aisle’, and

select any car in that aisle. You then drive away, stopping at the kiosk on the way out for some quick paperwork! (*see

below the Travel Policy regarding rental cars and other ground transportation options). We require (not recommend)

that all travelers to sign up with National’s Emerald Club, and have a profile with them linked to Western Global Airlines’

account with their Company credit card.

When renting a car, do not select the prepaid option for fuel, nor return it empty. Both can result in a much higher,

unnecessary cost of fuel. Please make sure these preferences are unchecked in your National Emerald Club profile to

avoid unknowingly selecting this option automatically.

Ground Transportation

Employees should utilize hotel shuttles whenever possible, between hotels and airports. If there is no hotel

transportation available, and the transportation is local (between the hotel and airport), Uber, Lyft or equivalent should

be utilized when available, as it is more cost effective, and often quicker, than using a taxi service. Taxis may be utilized

when Uber, Lyft, or the equivalent is not available. In addition, employees are encouraged to carpool and to use

Company-owned vehicles when available. Car rentals require specific Company approval prior and will only be booked

by Crew Scheduling. All receipts should be saved and uploaded into the Company’s expense reporting tool, SmartData.

At no time is it approved to utilize the Company credit card or submit expense reimbursement for personal

transportation.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 33

EMPLOYEE EXPENSE REIMBURSEMENT POLICY

The following is a comprehensive guide to the Western Global Airlines expense policy and procedures for the reporting

and reimbursement of expenses.

Currency

All expenses will be paid in US Dollars.

Expenses incurred in other currencies must list at least the local currency amount on the Travel Expense Form.

You may insert the exchange rate you incurred and make the calculations based on that number. If you use an exchange

rate higher than the published rate on the day expenses are due, you must either provide documentation of the

exchange rate you incurred or, Western Global Airlines reserves the right to recalculate based on the current exchange

rate.

If the exchange rate is left blank, the exchange will be computed by Western Global Airlines using the published

exchange rate on the day that the expenses are due.

Receipts

Copies of receipts for the charges listed on the Travel Expense Form must be submitted with the Travel Expense Form.

Any charges without receipts will not be paid.

Original receipts must be furnished upon request.

Due Dates

The Travel Expense Form must be submitted on or before the 5th of each month for expenses actually incurred during

the previous calendar month.

Expenses submitted on or before the 5th of the month will be reimbursed with the paycheck distributed on the 20th of

the next month.

Expenses submitted after the 5th will be reimbursed during the next subsequent month’s reimbursement schedule.

Expenses incurred more than 90 days prior to the submission due date will not be paid.

Approved Expenses

The following expenses may be submitted without specific pre-approval, receipts are still required:

• Cost of a Taxi to/from the Company-provided hotel if other transportation is not available.

• Internet if not provided by Company agreement with hotel (Limit $20 per day)

• Breakfast at hotel if not provided by Company agreement with hotel (Limit $12 per day Domestic and $20

per day International)

• Western Global Airlines shall reimburse Employee for the reasonable costs and expenses actually incurred

by Employee to acquire any required visas or permits as mandated by any applicable governing authority

that may be required for the performance of employee’s duties. Western Global Airlines will also

reimburse for Visa pictures, a second passport, and extra passport pages.

• Vaccinations on Western Global Airlines approved List

• With prior approval, Employee may be eligible for up to $200 emergency assistance in case of lost or stolen

luggage during travel, not the result of negligence by traveler, if it is not reimbursed by the airline or by the

employee’s insurance. Proper documentation must be submitted for reimbursement, such as police

report or Airport Authority report.

Medical Exams

No reimbursement.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 34

TIME OFF

HOLIDAYS

Regular, full-time employees are eligible for paid Company-observed holidays. Temporary and part-time employees are

not eligible for paid holidays. The Company will observe the following holidays:

Observed Holidays (each Holiday day is equivalent to 8 hours of work)

• New Year’s Day

• Memorial Day

• Independence Day

• Labor Day

• Thanksgiving Day

• Day after Thanksgiving

• Christmas Day

The specific dates for the observation of holidays will be announced each year by the Manager of Human Resources and

posted on the ADP self-service website. If a holiday falls on a Saturday, the Company will observe the holiday on the

Friday prior to the holiday; if a holiday falls on a Sunday, the Company will observe the holiday on the Monday following

the holiday.

• Full-time employees not scheduled to work on the holiday due to their normal schedule will not be

compensated for the holiday.

• Full-time or part-time employees that work on the holiday will be awarded floating time off their regularly

scheduled hours in their time-off bank.

• Employees that regularly work 10-hour shifts will be compensated at 8 hours for the holiday where applicable

Time Off for Holiday Worked/Non-Scheduled Days

Equal time off (not to exceed regularly scheduled hours), at the mutual convenience of the employee and the supervisor,

may be given if regular and probationary exempt/nonexempt/hourly employees are required to work on an observed

Company holiday or non-scheduled work day. The alternative equal time off is to be taken within one month of when the

holiday or non-scheduled work day occurs and must be approved in advance by the department supervisor, the HR

Manager and the President.

Overtime for Non-Exempt/Hourly Employees

• Overtime pay will be calculated based on an employee’s regular hourly rate of pay.

• Holiday hours are excluded as time worked in the computation of overtime.

PAID TIME OFF (PTO)

PTO is a benefit which provides all full-time employees paid time away from work that can be used for vacation, personal

time, personal illness or time off to care for dependents. With the exception of an unexpected illness or injury, PTO must

be scheduled in advance in accordance with Company guidelines, have supervisor and department head approval, and

be submitted to the Manager of Payroll. PTO is paid at the employee’s base pay rate at the time of absence. It does not

include overtime or any special forms of compensation. In the event state laws differ from these guidelines, those laws

will prevail in the administration of the PTO policy.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 35

Paid Time Off is a benefit provided to employees who work 30 or more hours a week. Full-time employees begin

accruing PTO from the first day of employment according to the following schedule.

Eligibility / PTO Accrual

The accrued PTO is available for use on the first day of the month after ninety (90) days of employment. Temporary and

part-time employees working less than thirty (30) hours per week are not eligible for PTO. PTO is to be used for all

scheduled and unscheduled absences.

The PTO accrual schedule is indicated in the following table:

Years of Service Accrual Rate per Month (4 on 4 off accrual rate*) Annual Accrual (4 on 4 off accrual rate*)

0 – 4 years

6.66 hours or .832 Days per month

*8 hours or .667 Days per month

10 days (80 hours)

*8 days (96 hours)

5 – 9 years

10 hours or 1.25 Days per month

*12 hours or 1 Day per month

15 days (120 hours)

*12 days (144 hours)

10 plus years

13.33 hours or 1.67 Days per month

*16 hours or 1.33 Days per month

20 days (160 hours)

*16 days (192 hours)

Employees during their first year of employment may carry over a maximum of one (1) week of PTO into their second

year of employment. All other employees may carry over a maximum of two weeks of PTO from one year to the next

during their employment. For clarification, one week is comprised of 5 work days, or 40 hours, for 5 day per week

employees. For 4 days on 4 days off employees, one week is comprised of 4 days, or 48 hours.

Upon separation of employment, employees will be paid by the Company up to the maximum of forty (40) hours

or five (5) days of earned and unused PTO time, if applicable. Final paychecks for employees will include PTO pay

or deductions for any negative balance upon termination, if applicable.

PTO Requests

Employees shall provide as much notice as possible in submitting requests for PTO so that the Company may schedule

work requirements and plan accordingly, and submit such requests prior to making travel plans. It is important to note

that all requests for using scheduled PTO must have the prior approval of the immediate supervisor and department

head. In addition, all requests for PTO must be submitted and approved in ADP.

PTO must be used for unscheduled absences. However, unscheduled absences must adhere to the Company’s standards

of attendance. If an employee fails to notify their supervisor, the absence may not be approved for pay. It may also result

in corrective action.

FAMILY AND MEDICAL LEAVE ACT (FMLA)

Western Global Airlines provides leave to eligible employees in accordance with the Federal Family and Medical

Leave Act (“FMLA”). The FMLA applies to all employers who employ 50 or more workers within a 75-mile radius. The

FMLA applies to all eligible employees. This policy may change, without notice, periodically to be consistent with the

minimum leave required by law.

FMLA requires that eligible employees be provided with continuation of health benefits as if the employee still was at

work and on the payroll. Employees are entitled to one 12-week period of continued health benefits in each 12-month

period. Western Global Airlines uses the “rolling” method to determine employee eligibility, whereby one counts

backward 12 months from the day of the requested leave to determine the employee’s eligibility and eligibility period.

Eligibility for FMLA Leave

If you have been employed by the Company for at least 12 months and you have worked at least 1,250 hours during the

12 months immediately preceding your leave, you are covered by the provisions of FMLA. If you are an employee

returning from fulfilling your National Guard or Reserve military obligation, you will be credited with the hours of service

that would have been performed but for the period of such military service in determining whether you have worked the

Western Global Airlines Employee Handbook, May 2018 Edition Page | 36

necessary 1,250 hours in accordance with the Uniformed Services Employment and Reemployment Rights Act

(“USERRA”).

Types of Leaves that are covered under FMLA

FMLA guarantees covered employees the right to take an unpaid leave for a maximum of 12 work weeks of leave in a 12-

month period for any one or more of the following reasons:

1. The birth of a child and in order to care for that child;

2. The placement of a child for adoption or foster care and to care for the newly placed child;

3. To care for a spouse, child or parent with a serious health condition (described below);

4. The serious health condition (described below) of the employee; or

5. Qualifying exigency leave for families of members of the National Guard or Reserves or of a regular component

of the Armed Forces when the covered military member is on covered active Duty or called to cover active

Duty.

An employee whose spouse, son, daughter or parent either has been notified of an impending call or order to covered

active military Duty or who is already on covered active Duty may take up to 12 weeks of unpaid leave for reasons

related to or affected by the family member’s call-up or service. The qualifying exigency must be one of the following:

a) short-notice deployment;

b) military events and activities;

c) child care and school activities;

d) financial and legal arrangements;

e) counseling;

f) rest and recuperation;

g) post-deployment activities; and

h) additional activities that arise out of active Duty, provided that the employer and employee agree, including

agreement on timing and duration of the leave.

Eligible employees are entitled to FMLA leave to care for a current member of the Armed Forces, including a member of

the National Guard or Reserves, or a member of the Armed Forces, the National Guard or Reserves who is on the

temporary disability retired list, who has a serious injury or illness incurred in the line of Duty on active Duty for which he

or she is undergoing medical treatment, recuperation, or therapy; or otherwise in outpatient status; or otherwise on the

temporary disability retired list. Eligible employees may not take leave under this provision to care for former members

of the Armed Forces, former members of the National Guard and Reserves, and members on the permanent disability

retired list.

In order to care for a covered service member, an eligible employee must be the spouse, son, daughter, or parent, or

next of kin of a covered service member.

As referenced in this paragraph:

• A “son or daughter of a covered service member” means the covered service member's biological, adopted, or

foster child, stepchild, legal ward, or a child for whom the covered service member stood in loco parentis, and

who is of any age.

• A “parent of a covered service member” means a covered service member's biological, adoptive, step or foster

father or mother, or any other individual who stood in loco parentis to the covered service member. This term

does not include parents “in law.”

Western Global Airlines Employee Handbook, May 2018 Edition Page | 37

• Under the FMLA, a “spouse” means a husband or wife, including those in same-sex marriages, which were

made legal in all 50 United States as of June 26, 2015.

The “next of kin of a covered service member” is the nearest blood relative, other than the covered service member's

spouse, parent, son, or daughter, in the following order of priority: blood relatives who have been granted legal custody

of the service member by court decree or statutory provisions, brothers and sisters, grandparents, aunts and uncles, and

first cousins, unless the covered service member has specifically designated in writing another blood relative as his or her

nearest blood relative for purposes of military caregiver leave under the FMLA. When no such designation is made, and

there are multiple family members with the same level of relationship to the covered service member, all such family

members shall be considered the covered service member's next of kin and may take FMLA leave to provide care to the

covered service member, either consecutively or simultaneously. When such designation has been made, the designated

individual shall be deemed to be the covered service member's only next of kin. For example, if a covered service

member has three siblings and has not designated a blood relative to provide care, all three siblings would be considered

the covered service member's next of kin. Alternatively, where a covered service member has a sibling(s) and designates

a cousin as his or her next of kin for FMLA purposes, then only the designated cousin is eligible as the covered service

member's next of kin.

An employer is permitted to require an employee to provide confirmation of covered family relationship to the covered

service member pursuant to 29 CFR §825.122(k).

• “Covered active Duty” means:

o “Covered active Duty” for members of a regular component of the Armed Forces means Duty during

deployment of the member with the Armed Forces to a foreign country.

o “Covered active Duty” or “call to covered active Duty status” in the case of a member of the Reserve

components of the Armed Forces means Duty during the deployment of the member with the Armed

Forces to a foreign country under a Federal call or order to active Duty in support of a contingency

operation, in accordance with 29 CFR 825.102.

The leave may commence as soon as the individual receives the call-up notice. Son or daughter for this type of FMLA

leave is defined the same as for child for other types of FMLA leave except that the person does not have to be a minor.

This type of leave would be counted toward the employee’s 12-week maximum of FMLA leave in a 12-month period.

Military caregiver leave (also known as covered service member leave) to care for a service member or veteran with

serious injury or illness: An employee whose son, daughter, parent or next of kin is a covered service member may take

up to 26 weeks in a single 12-month period to take care of leave to care for that service member. Next of kin is defined

as the closest blood relative of the injured or recovering service member.

• The term “covered service member” means:

(a) a 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

(b) a veteran who is undergoing medical treatment, recuperation, or therapy, for a serious injury or

illness and who was a member of the Armed Forces (including a member of the National Guard or

Reserves) at any time during the period of 5 years preceding the date on which the veteran undergoes

that medical treatment, recuperation, or therapy.

• The term “serious injury or illness” means:

(a) in the case of a member of the Armed Forces (including a member of the National Guard or

Reserves), an injury or illness that was incurred by the member in line of Duty on active Duty in the

Armed Forces (or existed before the beginning of the member’s active Duty and was aggravated by

service in line of Duty on active Duty in the Armed Forces) and that may render the member medically

unfit to perform the duties of the member’s office, grade, rank, or rating; and

(b) in the case of a veteran who was a member of the Armed Forces (including a member of the

National Guard or Reserves) at any time during a period when the person was a covered service

Western Global Airlines Employee Handbook, May 2018 Edition Page | 38

member, a qualifying (as defined by the Secretary of Labor) injury or illness incurred by a covered

service member in the line of Duty on active Duty that may render the service member medically unfit

to perform the duties of his or her office, grade, rank or rating.

• Outpatient status, with respect to a covered service member, means the status of a member of the Armed

forces assigned to either a military medical treatment facility as an outpatient; or a unit established for the

purpose of providing command and control of members of the Armed Forces receiving medical care as

outpatients.

Serious Health Condition

An employee may take leave because of a serious health condition that makes the employee unable to perform the

functions of the employee's position. The law defines serious health condition as an illness, injury, impairment, or

physical or mental condition that involves:

• Inpatient treatment (i.e., an overnight stay in a hospital, hospice, or residential medical care facility including

any period of incapacity or any subsequent treatment in connection with such inpatient care), or

• “Continuing Treatment by a Health Care Provider.” Such treatment includes one or more of the following:

o A period of incapacity for more than three consecutive calendar days provided that the condition also

involved:

(i) at least two visits to a health care provider within 30 days of the first day of incapacity, or

(ii) one visit and a regimen of continuing treatment;

• Any period of incapacity due to pregnancy or for prenatal care. This entitles employee to FMLA leave.

• Any period of incapacity or treatment for such incapacity due to a chronic serious health condition (i.e.,

requires periodic visits for treatment by a health care provider or nurse; continues over an extended period of

time; and may cause episodic incapacity);

• A period of incapacity which is permanent or long-term (i.e., requiring the continuing supervision, but not

necessarily the active treatment by, a health care provider); or

• Conditions requiring multiple treatments.

Additionally, if you feel your condition is permanent and may qualify for accommodations under the ADA, please contact

the Manager of Human Resources.

Notice and Certification

Employees seeking to use FMLA leave are required to provide 30-day advance notice of the need to take

FMLA leave when the need is foreseeable and such notice is practical. Notice must be made in writing and submitted to

the Manager of Human Resources.

Employees must provide sufficient information to allow the Company to determine if the leave qualifies for FMLA

protection, and the anticipated timing and duration of the leave. Sufficient information may include: evidence of the

date on which the serious health condition started; evidence that the employee is unable to perform the job functions;

evidence that the covered family member is unable to perform daily activities; evidence of the need for hospitalization

or continuing treatment by a health care provider; and/or evidence on the circumstances supporting the need for

military leave.

Employees must also inform the Company if the requested leave is for a reason for which FMLA leave was previously

taken or certified. Employees may also be required to provide a certification and periodic recertification supporting the

need for leave.

Intermittent Leave

FMLA leave does not have to be taken all at once. However, the employee must provide 30 days advance notice of the

need to take FMLA leave when the need is foreseeable. An employee can take the FMLA leave on an intermittent basis

Western Global Airlines Employee Handbook, May 2018 Edition Page | 39

due to an “unpredictable” serious health condition. For intermittent leave, the employee must provide as much

advanced notice as practicable and generally must comply with the call-in procedures for the employee’s department.

Applying for Leave

If possible, an employee should give at least 30 days’ notice when requesting an FMLA leave and must complete and

return a Western Global Airlines Request for Leave of Absence form to the Manager of Human Resources, along with any

other medical certification documentation that may be necessary. You should make a “reasonable effort”, if possible, to

schedule leave so as to not disrupt unduly Western Global Airlines operations. Please contact the Manager of Human

Resources for further information.

Job Restoration

Upon return from FMLA leave, an employee will be restored to the employee’s original job, or to an equivalent job with

equivalent pay, benefits, and other terms and conditions of employment. When returning to work after an FMLA leave

(other than for pregnancy), the employee must provide certification from his/her medical provider that he/she is able to

safely perform all of the essential functions of his/her position with or without reasonable accommodation and/or any

restrictions.

Integration with Other Benefits

FMLA leave is unpaid. An employee who is taking FMLA leave because of the employee's own serious health condition or

the serious health condition of a family member must use all personal leave prior to being eligible for unpaid leave.

Workers' compensation leave (to the extent that it qualifies), will be designated as FMLA leave and will run concurrently

with FMLA. For example, if the Company provides six weeks of pregnancy disability leave, the six weeks will be

designated as FMLA leave and counted toward the employee's 12-week entitlement. The employee may then be

required to substitute accrued (or earned) paid leave as appropriate before being eligible for unpaid leave for what

remains of the 12-week entitlement.

An employee who is taking leave for the adoption or foster care of a child must use all paid time off prior to being eligible

for unpaid leave. An employee who is using military FMLA leave for a qualifying exigency must use all paid time off prior

to being eligible for unpaid leave. An employee using FMLA military caregiver leave must also use all paid time off prior

to being eligible for unpaid leave.

Employees will not accrue Paid Time Off nor be paid for holidays while out on FMLA leave.

Substitute Paid Leave for Unpaid FMLA Leave

Employees must use any accrued paid time prior to taking unpaid FMLA leave. The substitution of paid time for unpaid

FMLA leave time does not extend the length of FMLA leave and the paid time will run concurrently with an employee’s

FMLA entitlement. Leaves of absence taken in connection with a workers’ compensation injury/illness shall run

concurrently with any FMLA leave entitlement. Upon written request, the Company will allow employees to use accrued

paid time off to supplement any paid disability benefits.

Pay Employees’ Share of Health Insurance Premiums

As noted above, during FMLA leave, employees are entitled to continued group health plan coverage under the same

conditions as if they had continued to work. Unless the Company notifies employees of other arrangements, whenever

employees are receiving pay from the Company during FMLA leave, the Company will deduct the employee portion of

the group health plan premium from the employee’s paycheck in the same manner as if the employee was actively

working. If FMLA leave is unpaid, employees must pay their portion of the group health premium. Contact the Manager

of Human Resources to make payment arrangements.

Questions and/or Complaints about FMLA Leave

If you have questions regarding this FMLA policy, please contact the Manager of Human Resources. The Company is

committed to complying with the FMLA and, whenever necessary, shall interpret and apply this policy in a manner

consistent with the FMLA. The provisions set forth above are a brief summary of the entitlements and requirements

under the FMLA. The Notice of Employee Rights is included at the end of this Handbook.

The FMLA makes it unlawful for employers to: 1) interfere with, restrain, or deny the exercise of any right provided

under FMLA; or 2) discharge or discriminate against any person for opposing any practice made unlawful by FMLA or

Western Global Airlines Employee Handbook, May 2018 Edition Page | 40

involvement in any proceeding under or relating to FMLA. If employees believe their FMLA rights have been violated,

they should contact the Manager of Human Resources immediately. The Company will investigate any FMLA complaints

and take prompt and appropriate remedial action to address and/or remedy any FMLA violation. For more information

about the FMLA, please view the Employees Rights and Responsibilities Information Sheet, which is (at minimum) posted

in the break/kitchen area of the Company location and included in the Appendix to this Handbook.

BEREAVEMENT LEAVE

Western Global Airlines provides bereavement leave to employees who need to take time off due to the death of an

immediate family member to attend memorial/funeral services and tend to other related family matters. Full-time

employees will receive paid leave for up to two (2) regular workdays missed due to the death of an immediate family

member. For bereavement leave, "immediate family" means your mother, father, spouse, child, brother, sister,

grandmother, grandfather, and grandchild.

Bereavement pay will be calculated on the employee’s base pay rate times the number of hours the employee would

otherwise have worked on the day of absence (up to a maximum of 8 or 10 hours per day). Bereavement pay is excluded

as time worked for the purposes of calculating overtime pay.

The Company will permit bereavement leave unless there are serious operations requirements that require the

employee to be at work. With supervisor's approval, employees can use any available paid leave benefits you have, such

as Paid Time Off, if more time off is needed.

JURY DUTY LEAVE

Western Global Airlines encourages employees to fulfill their civic responsibilities by serving jury Duty when required.

Full-time employees may request up to two (2) days of paid jury duty leave per calendar year. Jury duty pay will be

calculated on the employee’s base pay rate times the number of hours the employee would otherwise have worked on

the day of absence (up to a maximum of 8 or 10 hours per day).

If employees are required to serve on jury duty beyond the period of paid jury leave, they may use any available paid

time off or may request an unpaid jury duty leave of absence. Employees must provide a copy of the jury duty summons

to their supervisor as soon as possible after receiving the summons so that the supervisor may make arrangements to

accommodate their absence. Employees are expected to report to work whenever the court schedule permits, including

partial days. Either Western Global Airlines or the employee may request an excuse from jury duty if, in the Company’s

judgment, the employee’s absence would create serious operations difficulties.

VOTING LEAVE

Western Global Airlines also encourages all employees to fulfill their civic responsibilities by voting in all official public

elections. Generally working hours are such that employees will have ample time to cast their vote before or after

working hours. However if there is insufficient time to vote due to overtime work etc., please discuss the matter with

your supervisor. The Company will comply with all applicable voting time laws of the states and municipalities in which

its facilities and offices are located.

MILITARY LEAVE OF ABSENCE

Upon request, employees are eligible for a leave of absence to serve in the active or reserve military services of the

United States in accordance with applicable law. Western Global Airlines will comply with the Uniform Services

Employment and Re-employment Rights Act (“USERRA”). This act applies to all employees who perform services in the

Armed Forces, Army National Guard, Public Health Services, or any other category of service designated by the

President in time of war or emergency. The following guidelines will be followed for an employee requesting a leave of

absence:

• Employees are required to give their employers advanced written or verbal notice of an absence for military

service unless circumstances make it unreasonable or impossible to do so.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 41

• Employees may use any accrued time off or other available paid leave during the military leave.

• After the conclusion of their military service, employees must report to their employers, or submit an

application for re-employment within a prescribed timeframe, which varies depending on the length of the

leave of absence.

• Employees are entitled to take a cumulative leave of absence due to military service for up to five (5) years.

(This includes previous leave absences)

Employees eligible for Paid Time Off should contact the Manager of Human Resources for specific details.

Health Insurance for Military Leave:

Employees who are currently enrolled in Company offered health plans will have their benefits continued for up to 31

days from the leave of absence date. If the leave extends beyond 31 days, you may elect to continue your coverage

under COBRA for up to eighteen (18) months, however, you may be required to pay all or part of the premium for the

continuation of COBRA coverage. Please ask the Manager of Human Resources for specific information.

Return from Military Duty:

Re-employment and/or reinstatement of employment will be made in accordance with applicable law. Employees should

contact their supervisor for specific information regarding return to work procedures.

BENEFITS

BENEFITS OVERVIEW

Western Global Airlines believes in the health and well-being of its employees and their families. We proudly offer a rich

benefits package of medical and supplemental benefits plans, from leading benefit providers.

• Medical Plan

•

Dental and Vision plans

•

Voluntary Life and AD&D.

• Basic Life and AD&D free to all eligible employees.

• Voluntary 401k plan. Contributions by the Company, under development at time of implementation of this

Handbook.

Full-time and part-time employees working at least 30 hours per week are eligible to enroll in these plans. Dependent

and domestic partner coverage is also available, with dependents receiving extended age coverage for all offerings. A

detailed description of Western Global Airline's Health Benefits, Life Insurance Benefits, and 401k Benefits is provided to

each employee. Western Global Airlines anticipates continuing to make the benefits described in this section and

elsewhere available to its employees, but benefits, plans, and programs may be modified, added or terminated at any

time by the insurance company or benefit provider, per the terms of the plan, or by Western Global Airlines, at its sole

discretion.

On occasion, we may have a temporary need for additional staff. These temporary employees will be hired by the

Company’s temporary agency partners. The Company requires these temporary agencies to comply with all aspects of

the Affordable Care Act (ACA), including offering coverage to their temporary employees that is both affordable and

meets the ACA’s minimum value requirement. All temporary agencies contracted with the Company must have a current

ACA compliant statement on file with Human Resources. If a regular full time position becomes available, temporary

employees may apply for the open position. If hired, they will be eligible for benefits offered to full time employees.

Contact the Manager of Human Resources for plan booklets that explain the eligibility requirements and details

regarding benefit coverage. The terms of the benefit will be controlled by the carrier’s plan description. In addition, you

can visit the ADP self-service website for benefit information.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 42

COBRA

The federal Consolidated Omnibus Budget Reconciliation Act (COBRA) helps employees and their dependents continue

their health insurance even if they are no longer eligible under our health plan. COBRA lets an eligible employee and

dependents choose to continue their health insurance when a "qualifying event" happens. Qualifying events include the

employee's resignation, termination, leave of absence, shorter work hours, divorce, legal separation, or death. Another

qualifying event is when a dependent child stops being eligible for coverage under your health insurance.

If you continue your insurance under COBRA, you will pay the full cost of the insurance at Western Global Airlines group

rates plus an administration fee. When you become eligible for our health insurance plan, you will receive a written

notice describing your COBRA rights. Because the notice contains important information about your rights and what to

do if you need COBRA, be sure to read it carefully.

HIPPA

The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) limits exclusions for preexisting conditions;

prohibits discrimination against employees and their dependents based on their health status; guarantees renewability

and availability of health coverage to certain employers and individuals; and protects many workers who lose health

coverage by providing better access to individual health insurance. The special enrollment rights apply without regard to

the dates on which an individual would otherwise be able to enroll under the plan. Special enrollment periods apply to

you and/or your dependent(s), if you have a new dependent as a result of marriage, birth, adoption or the placement for

adoption (i.e., a “qualifying event”). Under these rules, a group health plan is required to provide the opportunity for

special enrollment for these individuals should they make the request within 30 days of the date the qualifying event

occurred.

If you decline enrollment under Western Global Airlines’ plan for yourself or your dependents (including your spouse)

and state in writing that you and/or your dependents have coverage under another group health plan or health

insurance coverage as the reason for declining to enroll, you may also have special enrollment rights. Special enrollment

rights may apply to you and/or your dependents in the event that you and/or your dependents are no longer eligible for

this other coverage. Your plan may offer an Annual Open Enrollment giving you the opportunity to enroll yourself and/or

your dependents if you have previously declined/waived coverage for you and/or dependents.

WORKERS COMPENSATION INSURANCE

Employees who are injured or become ill because of work may be eligible to receive insurance benefits as provided

under applicable state Workers’ Compensation laws. The Company pays all costs of providing this insurance protection.

Workers’ Compensation covers any injury or illness sustained on the job that requires medical, surgical, or hospital

treatment. Subject to applicable legal requirements, Workers’ Compensation Insurance provides benefits after a short

waiting period or, if the employee is hospitalized, immediately.

Employees who sustain work-related injuries or illnesses must inform their supervisor immediately. No matter how

minor an on-the- job injury may appear, it is important that it be reported immediately. This will enable an eligible

employee to qualify for coverage as quickly as possible.

Workers' Compensation covers only work-related injuries and illnesses. Neither Western Global Airlines nor its insurance

carrier will pay Workers' Compensation benefits for injuries that might happen if you voluntarily participate in an off-

duty recreational, social, or athletic activity that the Company might sponsor.

Western Global Airlines Employee Handbook, May 2018 Edition Page | 43

APPENDIX A – EMPLOYEE RIGHTS AND RESPONSIBILIITES UNDER THE FAMILY AND MEDICAL LEAVE ACT

(WHD Publication 1420)

Basic Leave Entitlement

FMLA requires covered employers to provide up to 12 weeks of unpaid, job-protected leave to eligible employees for the following

reasons:

• for incapacity due to pregnancy, prenatal medical care or child birth;

• to care for the employee’s child after birth, or placement for adoption or foster care;

• to care for the employee’s spouse, son, daughter or parent, who has a serious health condition; or

• for a serious health condition that makes the employee unable to perform the employee’s job.

Military Family Leave Entitlements

Eligible employees whose spouse, son, daughter or parent is on covered active Duty or call to covered active Duty status may use

their 12-week leave entitlement to address certain qualifying exigencies. Qualifying exigencies may include attending certain military

events, arranging for alternative childcare, addressing certain financial and legal arrangements, attending certain counseling

sessions, and attending post-deployment reintegration briefings.

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. A covered service member 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 veteran who was discharged or released under conditions other than dishonorable at any time during the five-year period prior

to the first date the eligible employee takes FMLA leave to care for the covered veteran, and who is undergoing medical treatment,

recuperation, or therapy for a serious injury or illness.*

*The FMLA definitions of “serious injury or illness” for current service members and veterans are distinct from the FMLA

definition of “serious health condition”. Benefits and Protections during FMLA leave, the employer must maintain the

employee’s health coverage under any “group health plan” on the same terms as if the employee had continued to work. Upon

return from FMLA leave, most employees must be restored to their original or equivalent positions with equivalent pay, benefits, and

other employment terms. Use of FMLA leave cannot result in the loss of any employment benefit that accrued prior to the start of an

employee’s leave.

Eligibility Requirements

Employees are eligible if they have worked for a covered employer for at least 12 months, have 1,250 hours of service in the

previous 12 months*, and if at least 50 employees are employed by the employer within 75 miles.

*Special hours of service eligibility requirements apply to airline flight crew employees.

Definition of Serious Health Condition A serious health condition is an illness, injury, impairment, or physical or mental condition

that involves either an overnight stay in a medical care facility, or continuing treatment by a health care provider for a condition that

either prevents the employee from performing the functions of the employee’s job, or prevents the qualified family member from

participating in school or other daily activities. Subject to certain conditions, the continuing treatment requirement may be met by a

period of incapacity of more than 3 consecutive calendar days combined with at least two 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.

Use of Leave

An employee does not need to use this leave entitlement in one block. Leave can be taken intermittently or on a reduced leave

schedule when medically necessary. Employees must make reasonable efforts to schedule leave for planned medical treatment so

as not to unduly disrupt the employer’s operations. Leave due to qualifying exigencies may also be taken on an intermittent basis.

Substitution of Paid Leave for Unpaid Leave

Employees may choose or employers may require use of accrued paid leave while taking FMLA leave. In order to use paid leave for

FMLA leave, employees must comply with the employer’s normal paid leave policies.

Employee Responsibilities

Employees must provide 30 days advance notice of the need to take FMLA leave when the need is foreseeable. When 30 days’

notice is not possible, the employee must provide notice as soon as practicable and generally must comply with an employer’s

normal call-in procedures. Employees must provide sufficient information for the employer to determine if the leave may qualify for

FMLA protection and the anticipated timing and duration of the leave. Sufficient information may include that the employee is unable

to perform job functions, the family member is unable to perform daily activities, the need for hospitalization or continuing treatment

by a health care provider, or circumstances supporting the need for military family leave. Employees also must inform the employer

if the requested leave is for a reason for which FMLA leave was previously taken or certified. Employees also may be required to

provide a certification and periodic recertification supporting the need for leave.

Employer Responsibilities

Covered employers must inform employees requesting leave whether they are eligible under FMLA. If they are, the notice must

specify any additional information required as well as the employees’ rights and responsibilities. If they are not eligible, the employer

must provide a reason for the ineligibility. Covered employers must inform employees if leave will be designated as FMLA-protected

Western Global Airlines Employee Handbook, May 2018 Edition Page | 44

and the amount of leave counted against the employee’s leave entitlement. If the employer determines that the leave is not FMLA-

protected, the employer must notify the employee.

Unlawful Acts by Employers

FMLA makes it unlawful for any employer to:

• interfere with, restrain, or deny the exercise of any right provided under FMLA; and

• discharge or discriminate against any person for opposing any practice made unlawful by FMLA or for involvement in any

proceeding under or relating to FMLA.

Enforcement

An employee may file a complaint with the U.S. Department of Labor or may bring a private lawsuit against an employer. FMLA

does not affect any Federal or State law prohibiting discrimination, or supersede any State or local law or collective bargaining

agreement which provides greater family or medical leave rights.

FMLA section 109 (29 U.S.C. § 2619) requires FMLA covered employers to post the text of this notice. Regulation 29 C.F.R.

§ 825.300(a) may require additional disclosures.

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Western Global Airlines Employee Handbook, May 2018 Edition Page | 45

ACKNOWLEDGMENT (EMPLOYEE COPY)

I have received a copy of the Employee Handbook (version revised May 2018) and have read

or had it read to me. If I have any questions regarding this Handbook, I understand that it is

my responsibility to ask my supervisor, department head, or Manager of Human Resources

about them. I recognize it is my responsibility to review the policies, practices, standards,

and rules this Handbook contains, and I agree to comply with them during my employment.

I understand the information in this Handbook is intended to acquaint employees with

general policies, principles, standards, and procedures, and does not represent a contractual

commitment by Western Global Airlines (“the Company”) concerning terms of employment or

other matters. The Company is free to act according to its the best business judgment and to

change, interpret, withdraw, or add to the policies, procedures, and standards described in

this Handbook at any time without prior notice, consideration, or approval by an employee. I

further understand that the discussion of benefits in this Handbook is intended solely as an

overview and, accordingly, if there is any conflict between the terms in this Handbook and

the terms of the applicable plan, the conflict is unintended and the terms of the plan will

prevail. Further, nothing in this Handbook shall be deemed to interfere with employee

disclosure rights protected by law.

I UNDERSTAND THAT NOTHING CONTAINED IN THIS HANDBOOK, OR IN

ANYTHING ELSE PROVIDED TO ME, IS INTENDED TO CREATE, NOR SHALL BE

CONSTRUED AS CREATING, AN EXPRESS OR IMPLIED CONTRACT OR

GUARANTEE OF EMPLOYMENT FOR A DEFINITE OR INDEFINITE TERM.

I UNDERSTAND THAT I AM AN AT-WILL EMPLOYEE. AS SUCH, I HAVE THE

RIGHT TO TERMINATE MY EMPLOYMENT, AND THE COMPANY HAS THE RIGHT

TO TERMINATE MY EMPLOYMENT, AT ANY TIME, WITH OR WITHOUT CAUSE OR

NOTICE, FOR ANY REASON OR NO REASON.

By signing below, I hereby acknowledge that I have read, and understand, the provisions

contained in this Handbook.

_________________________________________

Team Member’s Printed Name Employee Number

_________________________________________ ______________________

Team Member’s Signature Date

Western Global Airlines Employee Handbook, May 2018 Edition Page | 46

ACKNOWLEDGMENT (HUMAN RESOURCE COPY)