Principles

Criminal History Disclosure Requirements

Pre-Employment Disclosure

As a condition of employment, applicants must truthfully disclose criminal convictions as permitted by law and may be subject to background checks where required by law or customer contract.

Criminal history will be evaluated in compliance with applicable laws, including the Fair Credit Reporting Act (FCRA) and EEOC guidance, considering:

• Nature and seriousness of the offense
• Time elapsed
• Relationship to job duties and customer access requirements

Ongoing Duty to Disclose Open or Pending Criminal Matters

Employees are required to notify Northeast Data immediately (no later than 48 hours) if, during employment, they:

• Are arrested, charged, cited, summoned, or named as a defendant
• Have an open, pending, or newly filed case in any Magisterial District Court, municipal court, state court, or federal court
• Become subject to probation, court supervision, or criminal restrictions

This obligation applies to summary offenses, misdemeanors, and felonies.

Failure to disclose may result in disciplinary action up to and including termination, independent of case outcome.

Evaluation of Open or Pending Matters

An open or pending criminal case does not automatically result in termination. However, Northeast Data reserves the right to take appropriate action when the matter:

• Conflicts with job duties
• Impacts customer site eligibility
• Creates safety, security, or reputational risk
• Violates customer requirements

Temporary reassignment, suspension, or removal from customer sites may occur pending resolution.

Customer Site Compliance and Access Requirements

Customer Rules Supremacy

Many Northeast Data customers enforce strict site-access, ethics, and security requirements. While on customer premises or assigned to customer projects, customer rules supersede Company policies.

Violation of customer rules constitutes a violation of Northeast Data policy.

Zero-Tolerance Conduct at Customer Sites

Certain conduct is expressly prohibited by customer policies, including but not limited to:

• Theft or attempted theft
• Fraud or misrepresentation
• Dishonesty or misappropriation of property
• Security violations
• Ethical misconduct

Loss or Revocation of Customer Site Access

If an employee:

• Is charged with, convicted of, or has an open criminal matter involving theft, fraud, dishonesty, or moral turpitude; or
• Engages in conduct that violates customer site rules

the customer may immediately revoke or deny site access, regardless of case status or final disposition.

Customer access determinations are final and binding.

Employment Impact of Loss of Site Access

Because customer site access is an essential function of many positions:

• Loss or denial of site access may render the employee unable to perform job duties
• Northeast Data may take action including reassignment, suspension, or termination

Loss of customer site access shall be considered a legitimate, non-disciplinary business reason for termination, independent of criminal case outcome.

Convictions Automatically Voiding Site Authorization

Any conviction for theft, fraud, or dishonesty automatically voids authorization to access customer sites that prohibit such conduct.

Northeast Data cannot override customer access decisions and is not required to hold positions open while access issues are unresolved.

Section I – Serious Misconduct (Up to and Including Discharge)

Employees may be disciplined up to and including discharge for:

• Neglect of duty
• Insubordination (excluding unsafe directives)
• Immoral, indecent, or unethical conduct
• Conviction of a felony
• Conviction of a misdemeanor involving moral turpitude
• Violation of local, state, or federal law impacting job credibility or Company reputation
• Falsification of Company records
• Theft, destruction, or defacing of Company, customer, or employee property
• Endangering safety or instigating violence
• Alcohol or illegal drug use on duty
• Reporting to work under the influence
• Admitting unauthorized persons to restricted or customer-controlled areas

Off-duty conduct may result in discipline when it impacts job performance, customer trust, safety, or Company reputation.

Section II – Progressive Discipline

Unless immediate termination is warranted, discipline may progress as follows:

1. Verbal Warning
2. Written Reprimand
3. Suspension (up to one workweek)
4. Discharge

Receipt of four (4) written warnings within six (6) consecutive months may result in termination upon issuance of the fourth warning.

Management reserves the right to bypass progressive discipline when warranted.

Legal Compliance

This policy shall be applied in compliance with all applicable federal, state, and local laws.