2026 RÖDL Policy Manual

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Employee Acknowledgement Form This firm policy manual and employee handbook describes important information about Rödl Management Inc., and I understand that I should consult the Human Resources Manager regarding any questions not answered in the handbook. I have entered into my employment relationship with Rödl Management Inc. voluntarily and acknowledge that there is no specified length of employment. Accordingly, either Rödl Management Inc. or I can terminate the relationship at will, with or without cause, at any time, for any reason, with or without advance notice, so long as there is no violation of applicable federal or state law. Since the information, policies, and benefits described here are necessarily subject to change, I acknowledge that revisions to the handbook may occur, except to Rödl Management Inc.'s policy of employment-at-will. All such changes will be communicated through official notices, and I understand that revised information may supersede, modify, or eliminate existing policies. Only the Executive Committee of Rödl Management Inc. has the ability to adopt any revisions to the policies in this handbook. Furthermore, I acknowledge that this handbook is neither a contract of employment nor a legal document. I have received the handbook, and I understand that it is my responsibility to read and comply with the policies contained in this handbook and any revisions subsequently made to it. EMPLOYEE’S NAME (printed) EMPLOYEE'S SIGNATURE: DATE:

1.1 1.2 1.3 Employee Acknowledgement Form Employee Welcome Message Organization Description Introductory Statement 2.1 2.2 2.3 2.4 2.5 2.6 2.7 Nature of Employment Employee Relations & Open Door Policy Equal Employment Opportunity Disability Accommodation Business Ethics and Conduct Hiring of Relatives Immigration Law Compliance o2.7.1 Immigration & Permanent Residence Fees Paid By the Firm 2.8 2.9 2.9.1 Code of Professional Ethics................................................................................. o2.9.2 Training & Development........................................................................................ o2.9.3 CPA Examination and Bonus.............................................................................. o2.9.4. Tuition Reimbursement........................................................................................ o2.9.5. Membership in Professional Organization.................................................... Conflicts of Interest Professional Considerations 2.10 2.11 2.12 2.13 2.14 2.15 Unfamiliar Accounting & Reporting Issues Employee Duties & Responsibilities Confidential Matters of the Client Confidential Matters of the Firm Use of the Firm Name Independence, Integrity and Objectivity Policy Regarding Consultation When Dealing with Complex, Unusual or 2.16 Policy Regarding Accepting Prospective Clients and the Continuance of Current Clients 2.17 2.18 2.19 2.20 Personal Telephone Calls at Client's Office Work at the Client's Office Public Communication Relations with Client's Employees 2.21 Outside Work 2.22 Out-of-Town Travel and Local Transportation Expenses 2.23 Client Entertainment 1 2 3 3 3 4 5 6 6 6 7 8 8 8 9 10 10 11 11 11 12 12 13 15 15 15 16 16 16 16 16 1 2 INTRODUCTION EMPLOYMENT Table of Content 3 1

ĺĹ 4.1 Employee Benefits ĺĹ 4.2 PTO (Paid Time Off) ĺĹ 4.3 Holidays ĺļ 4.4 Workers' Compensation Insurance 2Ľ 4.5 Time Off to Vote 2Ľ 4.6 Bereavement Leave 2ľ 4.7 Jury Duty 2ľ 4.8 Benefits Continuation (COBRA) 2Ŀ 4.9 Health, Dental and Vision Insurance 2Ŀ 4.10 Life Insurance 2Ŀ 4.11 Voluntary Additional Life Insurance 2ŀ 4.12 Long-Term Disability 2ŀ 4.13 Short Term Disability 2ŀ 4.14 401(k) Savings Plan 2ŀ 4.15 Flexible Benefits Plans 2Ł 4.16 Employee Referral Program 2Ł 5 LEAVES OF ABSENCE Ļĸ 5.1 Medical Leave Ļĸ 5.1.1 Pregnancy-Related Absences ............................................................. Ļĸ 5.2 Family Leave 3Ĺ 5.3 Personal Leave 3ĺ 5.4 Military Leave 3ĺ 5.4.1 Military Family Leave Entitlements ..................................................... ĻĽ 6.1 Paydays 3Ŀ 6.2 Pay Deductions 3Ŀ 6 TIMEKEEPING/PAYROLL 3Ŀ 4 EMPLOYEE BENEFIT PROGRAMS 3 EMPLOYMENT STATUS & RECORDS ĹĿ ĹĿ Ĺŀ 18 18 19 19 3.1 Employment Categories 3.2 Access to Personnel Files 3.3 Personnel Data Changes 3.4 Employment Applications 3.5 Performance Evaluation 3.6 Background Checks

8.5 Attendance and Punctuality Ľĸ 8.6 Personal Appearance Ľĸ 8.7 Return of Property ĽĹ 8.8 Employment Termination / Resignation 5Ĺ 8.9 Progressive Discipline 5ĺ 9.1 Life-Threatening Illnesses in the Workplace 5Ļ 10 INFORMATION TECHNOLOGY & SOCIAL MEDIA 5ļ 10.1 Overview 5ļ 10.2 Computer, E-Mail and Messaging Usage 5ļ 10.3 Computer Policy 5Ľ 10.4 Social Media 5Ľ 10.4.1 Firm Social Media and Employee Privacy ......................................... 5Ľ 8.4 The Genetic Information Nondiscrimination Act Ľĸ 9 MISCELLANEOUS 5Ļ 8.1 Employee Conduct and Work Rules 4ĺ 8.2 Drug and Alcohol Use 4ĺ 8.3 Sexual and Other Unlawful Harassment & Discrimination 4Ļ 8.3.2 Complaint Procedure ............................................................................ 4Ŀ 8 EMPLOYEE CONDUCT & DISCIPLINARY ACTION 4ĺ 7 WORK CONDITIONS & HOURS 3Ł 7.1 Work Schedules 3Ł 7.1.1 Flexible Work Arrangements ............................................................... 3Ł 7.2 ļĸ 7.3 ļĸ 7.4 ļĸ 7.5 ļĸ 7.6 Use of Mail Systems Smoking Emergency Closings Business Travel Expenses and Regulations Office Appearance Policy ļĹ 8.3.1 Disability Harassment .......................................................................... 4Ŀ

1 INTRODUCTION 1.1 Employee Welcome Message We are delighted to have you as a valued team member at Rödl Management Inc. and we wish you every success here! We believe that each employee contributes directly to Rödl Management Inc.’s growth and success, and we hope you will take pride in being a member of our team. This handbook was developed to describe some of the expectations of our team and to outline the policies, programs, and benefits available to eligible employees. You should familiarize yourselves with the contents of the employee handbook as soon as possible, for it will answer many questions about employment with Rödl Management Inc. We hope that your experience here will be challenging, enjoyable, and rewarding. Again, welcome! Sincerely, Nico Swart 1

2 1.2 Organization Description Rödl Management Inc. is a corporation originally organized in 1976 as May & Langford. In 1991, the name of the Firm was changed to Langford de Kock & Co. In January 2001, 50% of the shares of Langford de Kock & Co. were purchased by Rödl & Partner LLC, and the name of the corporation was changed to Rödl Management Inc. Rödl Management Inc. is the General Partner of Rödl Langford de Kock LP and serves as the co-employer of Rödl Langford de Kock LP, Rödl Langford de Kock LLP, and Langford de Kock LLP employees (collectively referred to as “the Firm”). Rödl Langford de Kock LLP and Langford de Kock LLP (only for Charlotte) are the Certified Public Accounting Firms that were established after Rödl & Partner LLC’s entrance to comply with State Accounting Board rules. This Firm policy manual also applies for these entities. Any references to “Partners” in this document will refer to Partners of Rödl Langford de Kock LLP whose relationship to the other entities is discussed above. 1.3 Introductory Statement This handbook is designed to acquaint the employees with Rödl Management Inc. and provide them with information about working conditions, employee benefits, and some of the policies affecting your employment. No employee handbook can anticipate every circumstance or question about policy. As Rödl Management Inc. continues to grow, the need may arise and Rödl Management Inc. reserves the right to revise, supplement, or rescind any policies or portion of the handbook from time to time as it deems appropriate, in its sole and absolute discretion. The only exception to any changes is our employment-at-will policy permitting you or Rödl Management Inc. to end our relationship for any reason at any time. Employees will, of course, be notified of such changes to the handbook as they occur. Employees will be notified of changes to the handbook, and all changes will be posted on the Firm’s intranet site, GRIPS, for future reference.

3 2 EMPLOYMENT 2.1 Nature of Employment This handbook is intended to provide employees with a general understanding of our personnel policies. Employees are encouraged to familiarize themselves with the contents of this handbook, for it will answer many common questions concerning employment with Rödl Management Inc. However, this handbook cannot anticipate every situation or answer every question about employment. It is not an employment contract and is not intended to create contractual obligations of any kind. Neither the employee nor Rödl Management Inc. is bound to continue the employment relationship if either chooses at its will to end the relationship at any time. In order to retain necessary flexibility in the administration of policies and procedures, Rödl Management Inc. reserves the right to change, revise, or eliminate any of the policies and/or benefits described in this handbook, except for its policy of employment-at-will. The only recognized deviations from the stated policies are those authorized and signed by the chief executive officer of Rödl Management Inc. Changes to policies will be communicated to employees and posted on our intranet site, GRIPS. 2.2 Employee Relations & Open Door Policy Rödl Management Inc. believes that the work conditions, wages, and benefits it offers to its employees are competitive with those offered by other employers in the geographic areas in which it operates and in this industry. If employees have concerns about work conditions they are encouraged to voice these concerns openly and directly to their supervisors. Our experience has shown that when employees deal openly and directly with supervisors, the work environment can be excellent, communications can be clear, and attitudes can be positive. We believe that Rödl Management Inc. amply demonstrates its commitment to employees by responding effectively to employee concerns. Most problems can and should be solved in discussion with the employee’s immediate supervisor; this is encouraged as the first effort to solve a problem. But our open-door policy means that employees may also discuss their issues and concerns with the next level of management and/or Human Resources or any Partner in the Firm if they are not able to resolve the situation at the first level. 2.3 Equal Employment Opportunity In order to provide equal employment and advancement opportunities to all individuals, employment decisions at Rödl Management Inc. will be based on merit, qualifications, and abilities. Rödl Management Inc. does not discriminate in employment opportunities or practices on the basis of race, color, religion, sex, national origin, age, disability, sexual orientation, gender identity or any other characteristic protected by law.

4 Rödl Management Inc. will make reasonable accommodations for qualified individuals with known disabilities or for religious purposes unless doing so would result in an undue hardship to Rödl Management Inc. This policy governs all aspects of employment, including selection, job assignment, compensation, discipline, termination, and access to benefits and training. Additional information on accommodations for individuals with disabilities is provided in Section 2.4 below. Any employee with questions or concerns about any type of discrimination in the workplace are encouraged to bring these issues to the attention of their immediate supervisor, Human Resources Manager, any Partner in the Firm or the CEO. Employees can raise concerns and make reports without fear of reprisal or retaliation. Anyone found to be engaging in any type of unlawful discrimination will be subject to disciplinary action, up to and including termination of employment. Please refer to policies 8.3 Sexual and Other Harassment, 8.3.1 Disability Harassment, 8.3.2 Complaint Procedure and 8.4 GINA for more information. 2.4 Disability Accommodation Rödl Management Inc. is committed to complying fully with the Americans with Disabilities Act (ADA) and providing equal opportunity in employment for qualified persons with disabilities. All employment practices and activities are conducted on a non-discriminatory basis. The Firm has reviewed its hiring procedures and provide persons with disabilities meaningful employment opportunities. Pre-employment inquiries are made only regarding an applicant's ability to perform the duties of the position. Unless it would be an undue hardship on Rödl Management Inc. or would create a substantial risk of harm to the individual or others, reasonable accommodation is available upon written request to the Human Resources Department to all employees with disabilities, where their disability affects the performance of essential job functions. All employment decisions are based on the merits of the situation in accordance with defined criteria, not the disability of the individual. Qualified individuals with disabilities are entitled to equal pay and other forms of compensation (or changes in compensation) as well as in job assignments, classifications, organizational structures, position descriptions, lines of progression, and seniority lists. Leave of all types will be available to all eligible employees on an equal basis. Rödl Management Inc. is also committed to not discriminating against any qualified employees or applicants because they are related to or associated with a person with a disability. Rödl Management Inc. will follow any applicable state or local law that provides individuals with disabilities greater protection than the ADA. Employees who request accommodations are expected to cooperate in this interactive process, including providing requested information regarding his or her disability or impairment in a timely manner and/or requesting his or her healthcare provider such information. All information will be retained in confidence by the Company. Retaliation against employees who present requests for accommodation under this policy is strictly prohibited.

5 The Company will determine the feasibility of the requested accommodation and whether such accommodation(s) may constitute an undue hardship on the Company, considering various factors including but not limited to, the nature and cost of the accommodation, the availability of tax credits and deductions, outside funding, the Company’s overall financial resources and the accommodation’s impact on the operation of the Company, including its impact on the ability of other employees to perform their duties and the Company’s ability to conduct business. Remote work may potentially be considered as a reasonable accommodation for an employee with a disability; however, in-person attendance may be an essential job function for certain positions. All employees, regardless of disability status, are expected to perform the essential functions of their jobs. This policy is neither exhaustive nor exclusive. Rödl Management Inc. is committed to taking all other actions necessary to ensure equal employment opportunity for persons with disabilities in accordance with the ADA and all other applicable federal, state, and local laws. Please refer to polices 8.3.1 Disability Harassment, 8.3.2 Complaint Procedure and 8.4 GINA for more information. 2.5 Business Ethics and Conduct The successful business operation and reputation of Rödl Management Inc. is built upon the principles of fair dealing and ethical conduct of our employees. Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulous regard for the highest standards of conduct and personal integrity. The continued success of Rödl Management Inc. is dependent upon our clients' trust, and we are dedicated to preserving that trust. Employees owe a duty to Rödl Management Inc., its clients, and Partners to act in a way that will merit the continued trust and confidence of the public. Rödl Management Inc. is committed to complying with all applicable laws and regulations and expects its directors, officers, and employees to conduct business in accordance with the letter, spirit, and intent of all relevant laws and to refrain from any illegal, dishonest, or unethical conduct. In general, the use of good judgment, based on high ethical principles, will guide the employee 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 the employee’s immediate supervisor and, if necessary, with the Human Resources Manager, any Partner or the CEO for advice and consultation. Compliance with this policy of business ethics and conduct is the responsibility of every Rödl Management Inc. employee. Disregarding or failing to comply with this standard of business ethics and conduct could lead to disciplinary action, up to and including possible termination of employment.

6 2.6 Hiring of Relatives Although Rödl Management Inc. has no prohibition against hiring relatives of existing employees, we are committed to monitoring situations in which relatives work in the same office, service line, or practice group (collectively “area”). In case of actual or potential problems, Rödl Management Inc. will take prompt action. This can include reassignment or, if necessary, termination of employment for one or both of the individuals involved. The employment of relatives in the same area may cause serious conflicts and problems with favoritism and employee morale. In addition to claims of partiality in treatment at work, personal conflicts from outside the work environment can be carried into day-to-day working relationships. For the purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage. 2.7 Immigration Law Compliance Rödl Management Inc. is committed to employing only United States citizens and aliens who are authorized to work in the United States and does not unlawfully discriminate based on citizenship or national origin. In compliance with the Immigration Reform and Control Act of 1986, each new employee, as a condition of employment, must complete the Employment Eligibility Verification Form I-9 and present documentation establishing identity and employment eligibility. Former employees who are rehired must also complete the form if they have not completed an I-9 with Rödl Management Inc. within the past three years, or if their previous I-9 is no longer retained or valid. Employees may raise questions or complaints about immigration law compliance without fear of reprisal. 2.7.1 Immigration & Permanent Residence Fees Paid by the Firm The Firm will pay the legal fees and application fees of employer based non-immigrant work visas (H, E, TN, L or other visas) for employees requiring work authorization in the U.S. Such visa applications will be handled by an immigration lawyer or law firm that the firm designates. The Firm will also reimburse employees for reasonable travel expenses to renew their visas. U.S. immigration law provides foreign nationals with a variety of ways to become lawful permanent residents through employment in the United States (GREEN CARD PROCESS). The Firm may, on a case-by-case basis, agree to initiate a Green Card Process for an eligible employee. Generally, the Firm will consider a visa holder eligible based on the following schedule

Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This policy establishes only the framework within which Rödl Management Inc. wishes the business to operate. The purpose of these guidelines is to provide general direction so that employees can seek further clarification on issues related to the subject of acceptable standards of operation. Contact the CEO or a Managing Partner for more information or questions about conflicts of interest. An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain, or the avoidance of a personal loss, for that employee or for a relative as a result of Rödl Management Inc.'s business dealings. For the 7 v ĝĹ’•ĝĺĚ„‰—ˆ••ˆ‘ˆš„’‰—‹ˆ‰Œ•–—™Œ–„—ˆ•݆˜••ˆ‘—œĽœˆ„•–ı v ĝĹĚ„‰—ˆ••ˆ‘ˆš„’‰—‹ˆ–ˆ†’‘‡™Œ–„—ˆ•݆˜••ˆ‘—œĽœˆ„•–ı v ĝĹĚ„‰—ˆ••ˆ‘ˆš„’‰—‹ˆ‰Œ•–—™Œ–„—ˆ•݆˜••ˆ‘—œĻœˆ„•–ı v ĝĹĚ„‰—ˆ••ˆ‘ˆš„’‰—‹ˆ‰Œ•–—™Œ–„—ˆ•݆˜••ˆ‘—œĻœˆ„•–ı v Ě„‰—ˆ•Ľœˆ„•– ŒŠŒ…ˆ ˆ“’œˆˆ– –‹’˜‡ „Žˆ —‹ˆŒ• ‡ˆ–Œ•ˆ —’ “˜•–˜ˆ „ Š•ˆˆ‘ †„•‡ Ž‘’š‘ —’ —‹ˆŒ• „‘„ŠŒ‘Š „•—‘ˆ• š‹’ ‹„– —‹ˆ –’ˆ ‡Œ–†•ˆ—Œ’‘ š‹ˆ—‹ˆ• —’ Œ‘Œ—Œ„—ˆ „ •ˆˆ‘ „•‡ •’†ˆ––Ę ’• ‘’—ě ‹ˆ ›ˆ†˜—Œ™ˆ ’Œ——ˆˆ ˜–— „““•’™ˆ „‘œ •ˆˆ‘ „•‡ •’†ˆ–– Œ‘Œ—Œ„—ˆ‡ ‰’• „‘ ˆ“’œˆˆ š‹’ ‹„– ‘’—œˆ—•ˆ„†‹ˆ‡—‹ˆ•ˆ”˜Œ•ˆ‡‹’‡Œ‘Š“ˆ•Œ’‡Œ–—ˆ‡„…’™ˆ…„–ˆ‡’‘—‹ˆŒ•™Œ–„†„—ˆŠ’•œě ‹ˆ•ˆ„•ˆ—‹•ˆˆ„Œ‘–—ˆ“–—’’…—„Œ‘„‘ˆ“’œˆ‘—ĝ…„–ˆ‡Š•ˆˆ‘†„•‡Ě Ĺě „…’•ˆ•—Œ‰Œ†„—Œ’‘İ––ˆ––ˆ‘—’‰š‹ˆ—‹ˆ•’•‘’——‹ˆ•ˆ„•ˆ”˜„Œ‰Œˆ‡ěěš’•Žˆ•–ıě “’œˆˆ–†„––Œ‰Œˆ‡„–ĝĹ„•ˆ„…ˆ—’’Œ——‹Œ––—ˆ“ě ĺě ĝĹļĸˆ—Œ—Œ’‘ݐ“’œˆ•“ˆ—Œ—Œ’‘‰’•“ˆ•„‘ˆ‘—‰’•ˆŒŠ‘š’•Žˆ•ı Ļě ĝļŀĽ‡˜–—’‰—„—˜–„““Œ†„—Œ’‘ě‹Œ––—ˆ“„œŒ‘†˜‡ˆ„‘„““Œ†„—Œ’‘‰’•„‡™„‘†ˆ“„•’ˆ İ„…ŒŒ—œ —’ ˆ„™ˆ —‹ˆ †’˜‘—•œı „‘‡ ˆ“’œˆ‘— „˜—‹’•Œ„—Œ’‘ İ„…ŒŒ—œ —’ š’•Ž š‹Œˆ š„Œ—Œ‘Šı ‰ŒŒ‘Š–ě ‹ˆ Œ• šŒ “„œ ‰’•  ‰ˆˆ– ݏˆŠ„ „‘‡ ‰ŒŒ‘Š ‰ˆˆ–ı „––’†Œ„—ˆ‡ šŒ—‹ —‹ˆ  “•’†ˆ––Ę ĝĹļĸ “ˆ—Œ—Œ’‘Ę„‘‡—‹ˆ ĝļŀĽ„““Œ†„—Œ’‘ě ‰„‘ˆ“’œˆˆ™’˜‘—„•œ—ˆ•Œ‘„—ˆ–—‹ˆŒ•ˆ“’œˆ‘—’•„•ˆˆ—Š’Ĥ ’•„˜–ˆĥ„‘‡„…„‘‡’‘– —‹ˆ •ˆˆ‘ „•‡ •’†ˆ–– …ˆ‰’•ˆ Œ––˜„‘†ˆ ’‰ —‹ˆŒ• “ˆ•„‘ˆ‘— •ˆ–Œ‡ˆ‘†œĘ —‹ˆœ šŒ •ˆŒ…˜•–ˆ —‹ˆ Œ•‰’•„†’–——‹„——‹ˆ Œ•Œ‘†˜••ˆ‡„––’†Œ„—ˆ‡šŒ—‹—‹ˆ ĝĹļĸ„‘‡ ĝļŀĽ‰ŒŒ‘Š–ě ‹ˆ Œ• „œ „–’Ę ’‘ „ †„–ˆĝ…œĝ†„–ˆ …„–Œ–Ę „Š•ˆˆ —’ “„œ „ ’• †ˆ•—„Œ‘ ˆ›“ˆ‘–ˆ– ‰’• „‘ ˆ“’œˆˆš‹’“˜•–˜ˆ–„ •ˆˆ‘„•‡—‹•’˜Š‹„••Œ„Šˆ…„–ˆ‡’‘—‹ˆ–„ˆ–†‹ˆ‡˜ˆ…œ™Œ–„—œ“ˆ „– –—„—ˆ‡ „…’™ˆě ‹ˆ „‘„ŠŒ‘Š „•—‘ˆ• ‹„– —‹ˆ –’ˆ ‡Œ–†•ˆ—Œ’‘ š‹ˆ—‹ˆ• —‹ˆ Œ• –‹’˜‡ •ˆŒ…˜•–ˆ —‹ˆ ˆ“’œˆˆ ‰’• —‹ˆ †’–— „––’†Œ„—ˆ‡ šŒ—‹ —‹ˆ •ˆˆ‘ „•‡ •’†ˆ––Ę ’• ‘’—ě ‹ˆ ›ˆ†˜—Œ™ˆ ’Œ——ˆˆ ˜–— „““•’™ˆ „‘œ •ˆˆ‘ „•‡ •’†ˆ–– Œ‘Œ—Œ„—ˆ‡ ‰’• „‘ ˆ“’œˆˆ š‹’ ‹„– ‘’—œˆ—•ˆ„†‹ˆ‡—‹ˆ•ˆ”˜Œ•ˆ‡‹’‡Œ‘Š“ˆ•Œ’‡Œ–—ˆ‡„…’™ˆ…„–ˆ‡’‘—‹ˆŒ•™Œ–„†„—ˆŠ’•œě 2.8 Conflicts of Interest

8 „ı …ı “’œˆˆ–„•ˆˆ›“ˆ†—ˆ‡„‘‡ˆ‘†’˜•„Šˆ‡—’„——ˆ‘‡•ˆˆ™„‘——•„Œ‘Œ‘Š’‰‰ˆ•ˆ‡…œ—‹ˆ‰Œ•ě  ˆ“’œˆˆ– šŒ—‹ „ “•’‰ˆ––Œ’‘„ ‡ˆ–ŒŠ‘„—Œ’‘ ˜–— †’“œ šŒ—‹ —‹ˆ „““Œ†„…ˆ Œ‘Œ˜•ˆ”˜Œ•ˆˆ‘—–’‰—‹ˆŒ•†ˆ•—Œ‰Œ†„—Œ’‘ě‹ˆ Œ•“•’™Œ‡ˆ–Œ‘ĝ‹’˜–ˆ—•„Œ‘Œ‘Š „‘‡’‘„•ˆŠ˜„•…„–Œ–„‘‡„††ˆ––—’’‘Œ‘ˆ—•„Œ‘Œ‘Š†’˜•–ˆ–Ęš‹Œ†‹šŒ„––Œ–—Œ‘ ˆˆ—Œ‘Š—‹ˆ•ˆ”˜Œ•ˆ‡‹’˜•–ě purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage. No "presumption of guilt" is created by the mere existence of a relationship with outside firms. However, if employees have any influence on transactions involving purchases, contracts, or leases, it is imperative that they disclose to an officer of Rödl Management Inc. as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties. Personal gain may result not only in cases where an employee or relative has a significant ownership in a firm with which Rödl Management Inc. does business, but also when an employee or relative receives any kickback, bribe, substantial gift, or special consideration as a result of any transaction or business dealings involving Rödl Management Inc. 2.9 Professional Considerations The continuing success of the Firm depends upon our adherence to high standards of conduct and service. These standards apply to all employees of the Firm. 2.9.1 Code of Professional Ethics All employees that are Certified Public Accountants should be familiar with and conform to the Code of Ethics of the American Institute of Certified Public Accountants and the State Board of Accountancy of the employee’s appropriate state, and with the code of conduct of any other applicable licensing boards relevant to the employee’s professional designation. 2.9.2 Training & Development The State Board of Accountancy of and employee’s appropriate state requires a specific number of hours of continuing professional education (CPE) during a specified time frame for individuals who hold active CPA certificates. It is the employee’s responsibility to be aware of and follow the requirements set by the appropriate State’s Board. Likewise, it is the responsibility of the employee to be aware of and follow all requirements for other relevant certifications including but not limited to Enrolled Agent (EA), Steuerberater (StB), Wirtschasftprüfer (WP), etc. Firm records are maintained for each individual within the Firm to monitor the CPE requirements for US CPAs to be certain that all professionals qualify. Our procedures with respect to continuing professional education are as follows:

 c) d) It is expected that all accountants will take the responsibility to be in attendance at these sessions. If additional CPE is required at the end of the year in order to satisfy th e requirement because of non-attendance at these sessions, the cost of such education will be at the individual’s expense unless approved by the CEO or a Managing Partner. On occasion, the Firm may suggest certain additional outside training for an individual. Likewise, there may be certain training that a State Board requires the employee to take outside of the Firm. The Firm will pay for such training. Any such training should be approved by the CEO or a Managing Partner. 2.9.3 CPA Examination and Bonus CPA Examination: The Firm anticipates that all the professional accounting staff will actively pursue attaining the CPA Certificate. The Firm will provide time off on the days the exam is taken for all candidates. If additional time is needed, the Firm will try and arrange for a candidate to use PTO time if they so wish. In addition, the Firm will be open to consider requests from candidates for taking unpaid time off to provide time for studying for the exam, but the Firm will consider client service needs as a priority. The fee for the examination will be the responsibility of each individual; however, the Firm will reimburse the cost of a review course for the CPA exam up to the maximum annual amount applicable to tuition reimbursement contingent on passing the exam. If an employee purchases a complete review course covering all four portions of the exam and only takes one portion of the exam, the Firm will reimburse them one-quarter of the amount of the total cost of the review course upon presentation of a copy of the results showing a passing grade on the exam and a copy of the cost of the course. This reimbursement will only be made if the employee passes each exam portion on the first attempt. If the employee purchases only one portion of the review course, the cost of this portion will be reimbursed after completing and passing that portion on the first attempt. All parts of the exam need to be passed within a two-year period for reimbursement of these costs. The annual tuition reimbursement limit applies to both educational courses and the CPA review course and any non-reimbursed portion does not carry to the following calendar year. It is the individual's responsibility to be certain that timely registration is affected so that they may sit for the exam. Bonus: After successfully completing all parts of the CPA exam, the Firm will grant a $5,000 Achiever’s Bonus to an employee once they are fully licensed as a CPA in the U.S. If an employee leaves the Firm voluntarily within two years of receiving the bonus, they will repay th e Firm for the full amount of the bonus.

10 2.9.4 Tuition Reimbursement Rödl Management Inc. will reimburse a portion of an employee’s costs incurred for tuition, books, fees and required supplies up to a predetermined maximum (Please see the Human Resources Manager for further details). The following conditions must be met for an employee to be entitled to reimbursement: 1. Must be a full-time employee 2. Must have a bachelor’s degree before they are eligible for any reimbursement 3. Prior to registering for the class, a Partner agrees that the class will enhance the employee’s ability to perform their job for the Company 4. Classes will be taken during non-working hours and will not diminish or interfere with the employee’s job performance 5. Employee agrees to provide proof that a grade of B or higher was obtained to qualify for reimbursement 6. Employee agrees to have six months of future service for each class or portion of each class for which tuition is reimbursed by the Firm (i.e. when an employee receives reimbursement for two classes, they agree to 1 year of future service with the Firm) The maximum dollar amount that will be reimbursed will be determined each year by the Firm. No reimbursement will be provided for any classes taken by audit staff during Busy Season, January 1 through April 15,. Busy season reimbursements for non-audit staff will be approved on a case-by-case basis according to business need. Any non-reimbursed tuition expenses do not carry over to the following calendar year. If a termination of employment occurs (voluntary or involuntary) before any future service requirement has been fulfilled, the employee authorizes the Company to repay a prorated portion of any tuition reimbursement amount previously received (calculated on a monthly basis) for any unfulfilled future service. The employee also agrees to have such repayment amount deducted from the employee's paychecks that are issued after the termination decision occurs. To be eligible for reimbursement, the employee and Partner must both sign off on the Tuition Reimbursement Confirmation Statement and Agreement located on our GRIPS page prior to enrollment in the course work. Completed Agreements should be forwarded to the HR Manager. 2.9.5 Membership in Professional Organization Employees are encouraged to join and take an active interest in those professional organizations whose primary purpose is the enhancement of knowledge to enable the employee to become a better professional. Such organizations include the American Institute of CPA's, the State Society of CPAs of the appropriate state, local CPA chapters, and other organizations. When approved by a Partner, the Firm pays the full cost of membership and attendance at periodic meetings.

11 2.10 Employee Duties & Responsibilities All employees are expected to use good judgment in discussions with clients and are expected to bring sensitive and discrete topics to the attention of their supervisor in advance of such discussion with the client. Those in charge of an assignment, as well as the Partner responsible, should be kept informed of the progress of the work. Any unusual developments, requests for additional services or unforeseen time requirements must be reported to the immediate supervisor. The discovery by an employee of evidence indicating a possible client defalcation, or other fraud, must be reported at once to their immediate supervisor. The matter should not be disclosed to or discussed with officials or employees of the client, except as instructed by the appropriate Partner. 2.11 Confidential Matters of the Client All information and documents, which in any way relate to client matters, must be held in strictest confidence. Discussion by employees of the details of client's financial statements or other confidential information must not be held within hearing of the client employees. The business of a client must not be discussed with outsiders or in public places. Work papers are considered confidential information, and appropriate safeguards should be taken to protect this information. Work papers and other client materials removed from our office or the clients' office should be adequately protected and must not be carried loosely. Electronic media includes external drives, flash drives, USB sticks, client or other unencrypted cloud-based file sharing services, etc. The Firm portal is secure and therefore does not require the use of document level password protection and is the preferred method of sending client information. Please refer to GRIPS for the most recent BDMaC press on this subject for more details on protecting client information and for RITE’s most recent information on general password guidelines. 2.12 Confidential Matters of the Firm Confidential matters of the Firm, such as compensation, fees and billing rates, may not be discussed with the client or their employees except by Partners or with the approval of a Partner. Reports or records which show billing rates or salary information of the Firm's personnel are to be made available only to Partners and others specifically authorized by a Partner.

12 2.13 Use of the Firm Name Partners of Rödl Langford de Kock LP, Rödl Langford de Kock LLP, and Langford de Kock, LLP are responsible for final decisions on all matters affecting relations with clients. They are the only ones entitled to sign the Firm name. Others are authorized to sign letters of transmittal and general topics, based upon discussion with Partners. Please refer to latest BDMaC on GRIPS “Use of the Firm Name and Authorized Signatures” 2.14 Independence, Integrity and Objectivity It is the policy of our Firm that all professional personnel be familiar with and adhere to the independence, integrity, and objectivity rules, regulations, interpretations, and rulings of the AICPA, the State Board of Accountancy of the employee’s appropriate state, the Society of CPAs of the appropriate state, state statutes, and other regulatory agencies where applicable. In this regard, any transaction, event, circumstance, or action that would impair the Firm’s independence or violates its integrity and objectivity policy, on a compilation, review, audit, forecast, projection, or attestation (including forecast and projection) engagement is prohibited. Although not necessarily all-inclusive, the following are considered to be prohibited transactions: a. Investments as an owner in a client’s business. b. Investments by any owner with a client, or with client personnel. c. Borrowing from or loans to a client, or client’s personnel. d. Accepting cash or gifts from a client (with the exception of noncash token gifts of nominal value). e. Family relationships between professional personnel and client personnel. (Consult the Managing Partner for a ruling on these.) Notwithstanding the preceding policy and list of prohibited transactions, at the Managing Partner’s discretion, certain prohibitions can be waived if it is deemed by Management to be in the best interest of the Firm. However, in so doing, the engagement service performed for the client must be limited as allowed by the AICPA, the State Board of Accountancy of the appropriate state, the Society of CPAs of the appropriate state, state statutes, and other regulatory agencies where applicable. The procedures listed below are followed to ensure compliance with this policy: 1. All professional personnel are required to sign a representation letter when hired (and annually thereafter) that acknowledges their familiarity with the Firm’s independence, integrity, and objectivity policy and procedures. 2. All professional personnel are required to notify the Managing Partner of any potential prohibited transaction or violation of an independence, integrity or objectivity rule as soon as they become aware of such a situation. To acknowledge that responsibility, all

1 professional personnel are required when hired (and annually thereafter) to sign a representation letter and to list situations they know of that could impair our Firm’s independence or that violate its integrity and objectivity policy. (The Firm library contains the authoritative rules on independence, integrity, and objectivity that govern our Firm. That literature and the advice of the Managing Partner should be consulted when an employee is not sure if a transaction, event, circumstance, or action should be reported.) 3. All professional personnel are required to review the Firm’s client list annually for possible violations. The list of clients is maintained and updated on a timely basis. When hired (and annually thereafter), all professional personnel are required to sign a representation that confirms this responsibility. 2.15 Policy Regarding Consultation When Dealing with Complex, Unusual or Unfamiliar Accounting & Reporting Issues It is the policy of our Firm that personnel refer to authoritative literature or other sources when appropriate. Our Firm also recognizes the need for a constant exchange of ideas and opinions about technical issues on all professional engagements, and it is our policy that all professional personnel seek consultation, on a timely basis, within or outside the Firm whenever they are uncertain about the answer to a technical question; the application of a professional procedure or standard; the application of a rule, regulation, or procedure of a tax or other regulatory agency; or the application of a Firm policy. The procedures listed below are followed to ensure compliance with this policy. 1. The Firm maintains ready access to an adequate and up-to-date research tools that include materials related to clients served and that should be consulted to assist professional staff in their research of technical issues, both tax and accounting. 2. While the Firm recognizes that it is impossible to list all situations that might require referral to authoritative literature or other sources or that might require consultation, the following situations, due to their complexity, may require consultation. a) Any engagement in which a qualified or nonstandard report is likely to be issued b) Any engagement involving material litigation c) Application for the first time, of new or complex technical pronouncements d) Industries with special accounting, auditing, or reporting requirements e) Emerging practice problems f) Choices among alternative generally accepted accounting principles upon initial adoption or when an accounting change is made

14 g) Re-issuance of a report, consideration of omitted procedures after a report has been issued, or subsequent discovery of facts that existed at the time a report was issued h) Filing requirements of regulatory agencies 3. When an issue arises that requires consultation, the issue should first be discussed with the engagement partner. If, in the engagement partner’s opinion, the issue is resolved at this level of consultation, additional consultation is not necessary. However, if any member of the engagement team disagrees with the resolution, the procedure in Step 7 should be followed. 4. If the engagement partner believes additional consultation beyond that of the engagement team is necessary, the issue should be discussed with the Chair of the appropriate Committee (Audit, Tax, BPO, Transaction Services, Quality Control). If, in the engagement partner’s opinion, the issue is resolved at this level of consultation, additional consultation is not necessary. However, if any member of the engagement team or other individuals who consulted on the issue disagrees with the resolution, the procedure in Step 7 should be followed. 5. If the engagement partner believes that additional consultation beyond that available within the Firm is necessary, the issue should be discussed with an outside specialist. Outside specialists include, but are not limited to, the AICPA technical information services, Center for Plain English Accounting, and CPAs or tax attorneys in other Firms. In determining the professional qualifications and reputations of the outside specialists, the Firm should consider, among other things, the following matters: a. The professional certification, license, or other recognition of the competence of the specialist in their areas of expertise, as appropriate b. The reputation and standing of the specialist in the views of their peers and others familiar with their capability of performance c. The relationship, if any, of the specialist to the client If, in the engagement partner’s opinion, the issue is resolved, additional consultation is not necessary. However, if any member of the engagement team or other individual in the Firm who consulted on the engagement disagrees with the resolution, the procedure in Step 7 should be followed. 6. Certain accounting, audit, examination, attestation, tax or consulting engagements may require the Firm to consult with non-accounting specialist such as actuaries, appraisers, attorneys, engineers, and geologists. The Firm should follow the guidance in AICPA Professional Standards when such consultations are necessary. If any member of the Firm or engagement team disagrees with the advice of a nonaccounting consultant, the procedure in Step 7 should be followed.

5 Ŀě ‰‡Œ‰‰ˆ•ˆ‘†ˆ–’‰’“Œ‘Œ’‘ˆ›Œ–—šŒ—‹Œ‘—‹ˆ Œ•„–—’—‹ˆ•ˆ–’˜—Œ’‘’‰„†’‘–˜—„—Œ’‘Œ––˜ˆĘ —‹ˆ ›ˆ†˜—Œ™ˆ ’Œ——ˆˆ šŒ •ˆ–’™ˆ „‘œ ‡Œ–“˜—ˆ– „– —’ —‹ˆ “•’“ˆ• †’˜•–ˆ ’‰ „†—Œ’‘ —„Žˆ‘…œ—‹ˆ Œ•’‘—‹ˆŒ––˜ˆŒ‘”˜ˆ–—Œ’‘ě‘œ“„•—œ—’—‹ˆ†’‘–˜—„—Œ’‘š‹’‡Œ–„Š•ˆˆ – šŒ—‹ —‹ˆ †’‘†˜–Œ’‘ ‹„– —‹ˆ ’“—Œ’‘ ’‰ “•ˆ“„•Œ‘Š „ ˆ’•„‘‡˜ „‘‡ ‰ŒŒ‘Š Œ— Œ‘ —‹ˆ š’•Ž“„“ˆ•–ě ŀě —ˆ†‹‘Œ†„•ˆ–ˆ„•†‹„‘‡†’‘–˜—„—Œ’‘–—‹„—„•ˆ˜‘˜–˜„Ę†’‘—•’™ˆ•–Œ„Ę’•†’“ˆ›„‘‡ „—ˆ•Œ„Œ‘‘„—˜•ˆ–‹’˜‡…ˆ‡’†˜ˆ‘—ˆ‡Œ‘„ˆ’•„‘‡˜—’—‹ˆš’•Ž“„“ˆ•–ě 2.16 Policy Regarding Accepting Prospective Clients and the Continuance of Current Clients Prospective clients Before accepting an engagement for a new client, the Firm must become comfortable that the Firm has a reasonable basis for success and that management is of good character. Before accepting any assurance clients, the Partner must and comply with the Firm’s assurance “new client acceptance checklist” located in the latest Firm’s standard assurance binders. Before accepting any tax only client, please refer to the BDMaC “Tax Client Acceptance and Continuance Key Considerations”, as revised. Current Clients If situations ever occur where we become uncomfortable with client management, the matter should be discussed with one of our Partners. In certain situations, it may be deemed advisable to resign from the engagement. 2.17 Work at the Client’s Office Rules in the client's office should be followed, particularly with respect to work hours, lunch hours and dress codes. If, for any reason, it is necessary to work past the client's regular hours, arrangements should be made with the client in advance. 2.18 Public Communication Articles for publication, speeches and lecture notes which relate to the technical aspects of the profession should be reviewed with a Partner, prior to publication or presentation, to protect both the individual and the Firm. Approval must be received from a Partner prior to writing an article for publication or making a speaking commitment.

16 2.19 Relations with Client’s Employees Employees of the client should be treated with the utmost consideration and respect. 2.20Personal Telephone Calls at Client’s Office The use of cell phones, either calls or texts, for personal reasons while at a client site should be restricted to emergencies. 2.21 Outside Work Employees are not permitted to undertake any tax, accounting, data processing, or management services work on their own account, or any work of any type for compensation, fee or profits, or active participation in the management of an enterprise, without approval from the Partners. This requirement is not intended to apply to work for civic and religious institutions, clubs or similar activities undertaken without compensation. 2.22 Out-of-Town Travel and Local Transportation Expenses Employees traveling out of town overnight on Firm business are reimbursed for business expenses incurred. The Firm will pay for reasonable air, auto, lodging, meals and incidental expenses. Please refer to section 7.5 in this manual and also our intranet site (GRIPS) for a more detailed and up-to-date explanation of our Business Travel Expenses Policy. 2.23 Client Entertainment It is often appropriate for employees to entertain members of a client organization or other business associates at lunch, dinner or other occasions. When Firm interests involve a person in such business entertainment, the costs are reimbursable by the Firm. Refer to 7.5 – Business, Travel Expenses and Entertainment. Individual good judgment is to be used in determining the appropriateness of business entertainment, subject to the guidance provided by one's supervisors. The Firm wishes to be reasonable, but not extravagant, and depends upon all employees to judge each situation in its proper perspective. An employee’s Partner’s decision on what is “reasonable” is final and Partner approval should be obtained before larger expenses are incurred.

1 3 EMPLOYMENT STATUS & RECORDS 3.1 Employment Categories It is the intent of Rödl Management Inc. to clarify the definitions of employment classifications so that employees understand their employment status and benefit eligibility. These classifications do not guarantee employment for any specified period of time. Accordingly, the right to terminate the employment relationship at will at any time is retained by both the employee and Rödl Management Inc. Each employee is designated as either NONEXEMPT or EXEMPT from federal and state wage and hour laws. NONEXEMPT employees are entitled to overtime pay under the specific provisions of federal and state laws. EXEMPT employees are excluded from specific provisions of federal and state wage and hour laws. An employee's EXEMPT or NONEXEMPT classification may be changed only upon written notification by Rödl Management Inc. management. Only hours actually worked count toward weekly overtime calculations for non-exempt employees. For instance, PTO, holidays, other kinds of paid or unpaid leave, and unpaid breaks, are not counted in determining any weekly overtime. The majority of employees other than hourly employees are EXEMPT. The Firm will identify any NONEXEMPT employee at the time of hire or when a formerly EXEMPT employee moves into a NONEXEMPT role. It will be the responsibility of the NONEXEMPT employee to ensure that they do not work any overtime hours without getting prior Partner approval. In addition to the above categories, each employee will belong to one other employment category: REGULAR FULL-TIME employees are those who are not in a temporary or part-time status and who are regularly scheduled to work Rödl Management Inc.'s full-time schedule of 30 hours or more per week. Generally, they are eligible for Rödl Management Inc.'s benefit package, subject to the terms, conditions, and limitations of each benefit program. REGULAR PART-TIME employees are those who are not assigned to a temporary or full-time status and who are regularly scheduled to work less than 30 hours per week. While they do receive all legally mandated benefits (such as Social Security and workers' compensation insurance), they are not eligible for most of Rödl Management Inc.'s other benefit programs, with the exception of the 401(k) Retirement Savings Plan, paid parking/commuter reimbursement and mobile phone reimbursement. TEMPORARY employees are those who are hired as interim replacements, to temporarily supplement the work force, or to assist in the completion of a specific project. Employment assignments in this category are of a limited duration not to exceed 90 days. Employment beyond any initially stated period does not in any way imply a change in employment status. Temporary employees retain that status unless and until notified of a change. While temporary

18 employees receive all legally mandated benefits (such as workers' compensation insurance and Social Security), they are not eligible for any of Rödl Management Inc.'s other benefit programs. INTERN is an employee who works in a temporary position with an emphasis on on-the-job training rather than merely employment. An internship may be paid or unpaid and they may be part-time, full-time, hourly or salaried. An intern has no guarantee of permanent placement at the end of their internship. While interns receive all legally mandated benefits (such as workers' compensation insurance and Social Security), they are primarily not eligible for any of Rödl Management Inc.'s other benefit programs, with the exception paid parking/commuter reimbursement for all interns and PTO and paid holidays which may be granted to interns on a salaried internship with the Firm. 3.2 Access to Personnel Files Rödl Management Inc. maintains a personnel file on each employee. The personnel file includes such information as the employee's job application, resume, records of training, documentation of performance appraisals and salary increases, and other employment records. All records after June 2020 are in a digital format. Employees hired before June 2020 may have some records in a paper file. Personnel files are the property of Rödl Management Inc., and access to the information they contain is restricted. Generally, only partners of Rödl Langford de Kock LLP and Officers of Rödl Management Inc. who have a legitimate reason to review information in a file are allowed to do so. Employees who wish to review their own file should contact the Human Resources Manager. With reasonable advance notice, employees may review their own digital personnel file in a video conference with the HR Manager or Coordinator. To view a paper file, employees may review their own file in Rödl Management Inc.'s offices and in the presence of a representative of the Human Resources Department or Managing Partner of that office. 3.3 Personnel Data Changes It is the responsibility of each employee to promptly notify Rödl Management Inc. of any changes in personnel data. Personal mailing addresses, telephone numbers, number and names of dependents, individuals to be contacted in the event of an emergency, educational accomplishments, and other such status reports should be accurate and current at all times. Employees are able to update most of their own personal information through our current Human Resource Information System (HRIS). A link to our HRIS is on the Firm’s intranet site (GRIPS). Employees should contact either the HR Manager or HR Coordinator with any personal information that they are not able to update through the self-service feature in our HRIS. 3.4 Employment Applications Rödl Management Inc. relies upon the accuracy of information contained in the employment application, as well as the accuracy of other data presented throughout the hiring process and

1 companies, including dates of employment, position held and additional information available pertaining to performance rating, reason for departure and eligibility for rehire. This verification will be run on the past two employers or the previous five years, whichever comes first. factors will be considered for applicants with a criminal history: o The nature of the crime and its relationship to the position. o The time since the conviction. o The number (if more than one) of convictions. o Whether hiring, transferring or promoting the applicant would pose an unreasonable risk to the business, its employees or its customers and vendors. The following additional background searches will be required if applicable to the position: requested. This search will be run when driving is an essential requirement of the position. employment. Any misrepresentations, falsifications, or material omissions in any of this information or data may result in Rödl Management Inc.'s exclusion of the individual from further consideration for employment or, if the person has been hired, termination of the individual's employment. 3.5 Performance Evaluation Supervisors and employees are strongly encouraged to discuss job performance and goals on an informal, day-to-day basis. This is the primary evaluation tool used at Rödl Management Inc. Additional formal performance evaluations are conducted at least semi-annually to provide both supervisors and employees the opportunity to discuss job tasks, identify and correct weaknesses, encourage and recognize strengths, and discuss positive, purposeful approaches for meeting goals. 3.6 Background Checks The Firm reserves the right to make offers of employment for certain positions contingent upon clear results of a thorough background check for final candidates hired from outside of the Firm and current employees who may be promoted into a key position, or as otherwise deemed necessary and appropriate. Background checks may include: x Social Security Verification: validates the applicant's Social Security number, date of birth and former addresses. x Prior Employment Verification: confirms applicant's employment with the listed x Personal and Professional References: calls will be placed to individuals listed as references by the applicant. x Educational Verification: confirms the applicant's claimed educational institution, including the years attended and the degree/diploma received. x Criminal History: includes review of criminal convictions and probation. The following x Motor Vehicle Records: provides a report on an individual's driving history in the state

20 x •ˆ‡Œ— Œ–—’•œĚ†’‘‰Œ•–†„‘‡Œ‡„—ˆň–†•ˆ‡Œ—‹Œ–—’•œě‹Œ––ˆ„•†‹šŒ…ˆ•˜‘‰’•“’–Œ—Œ’‘– —‹„— Œ‘™’™ˆ „‘„Šˆˆ‘— ’‰ ݇ „‘„Šˆˆ‘— ‘†ě ī ݇ „‘Š‰’•‡ ‡ˆ ’†Ž ‰˜‘‡– „‘‡ī’•‹„‘‡Œ‘Š’‰†„–‹’•†•ˆ‡Œ—†„•‡–ě •’†ˆ‡˜•ˆ Œ‘„†„‘‡Œ‡„—ˆ–˜–—†’“ˆ—ˆ„…„†ŽŠ•’˜‘‡†‹ˆ†Ž„˜—‹’•Œ„—Œ’‘‰’•„‘‡•ˆ—˜•‘Œ——’ ˜„‘  ˆ–’˜•†ˆ–ě ˜„‘ˆ–’˜•†ˆ–šŒ’•‡ˆ•—‹ˆ…„†ŽŠ•’˜‘‡†‹ˆ†Ž˜“’‘•ˆ†ˆŒ“—’‰—‹ˆ–ŒŠ‘ˆ‡•ˆˆ„–ˆ‰’•Ę „‘‡ ˆŒ—‹ˆ• Œ‘—ˆ•‘„ –—„‰‰ ’•„‘ ˆ“’œˆ‘— –†•ˆˆ‘Œ‘Š –ˆ•™Œ†ˆ šŒ †’‘‡˜†——‹ˆ †‹ˆ†Ž–ě ‡ˆ–ŒŠ‘„—ˆ‡ •ˆ“•ˆ–ˆ‘—„—Œ™ˆšŒ•ˆ™Œˆš„•ˆ–˜—–ě ‹ˆ  •ˆ“•ˆ–ˆ‘—„—Œ™ˆ šŒ ‘’—Œ‰œ —‹ˆ ‹Œ•Œ‘Š „‘„Šˆ• •ˆŠ„•‡Œ‘Š —‹ˆ •ˆ–˜—– ’‰ —‹ˆ †‹ˆ†Žě ‘ Œ‘–—„‘†ˆ–š‹ˆ•ˆ‘ˆŠ„—Œ™ˆ’•Œ‘†’“ˆ—ˆŒ‘‰’•„—Œ’‘Œ–’…—„Œ‘ˆ‡Ę—‹ˆ„““•’“•Œ„—ˆ„‘„Šˆˆ‘— „‘‡—‹ˆ‡Œ•ˆ†—’•’‰ ˜„‘ˆ–’˜•†ˆ–šŒ„––ˆ––—‹ˆ“’—ˆ‘—Œ„•Œ–Ž–„‘‡Œ„…ŒŒ—Œˆ–•ˆ„—ˆ‡—’ —‹ˆ’…ň–•ˆ”˜Œ•ˆˆ‘—–„‘‡‡ˆ—ˆ•Œ‘ˆš‹ˆ—‹ˆ•—‹ˆŒ‘‡Œ™Œ‡˜„–‹’˜‡…ˆ‹Œ•ˆ‡ě ‰„‡ˆ†Œ–Œ’‘‘’— —’‹Œ•ˆ’•“•’’—ˆ„†„‘‡Œ‡„—ˆŒ–„‡ˆ…„–ˆ‡’‘—‹ˆ•ˆ–˜—–’‰„…„†ŽŠ•’˜‘‡†‹ˆ†ŽĘ—‹ˆ•ˆ„œ …ˆ †ˆ•—„Œ‘„‡‡Œ—Œ’‘„ „Œ• •ˆ‡Œ— ˆ“’•—Œ‘Š †— İ ı •ˆ”˜Œ•ˆˆ‘—– —‹„— šŒ …ˆ ‹„‘‡ˆ‡ …œ ˜„‘ˆ–’˜•†ˆ–Œ‘†’‘˜‘†—Œ’‘šŒ—‹—‹ˆˆ“’œˆ‘—–†•ˆˆ‘Œ‘Š–ˆ•™Œ†ˆİŒ‰„““Œ†„…ˆıě „†ŽŠ•’˜‘‡†‹ˆ†ŽŒ‘‰’•„—Œ’‘šŒ…ˆ„Œ‘—„Œ‘ˆ‡Œ‘„‰Œˆ–ˆ“„•„—ˆ‰•’ˆ“’œˆˆ–ň“ˆ•–’‘‘ˆ ‰Œˆ–‰’•„Œ‘Œ˜’‰‰Œ™ˆœˆ„•–ě ‹ˆ Œ••ˆ–ˆ•™ˆ–—‹ˆ•ŒŠ‹——’’‡Œ‰œ—‹Œ–“’Œ†œ„—„‘œ—ŒˆšŒ—‹’˜—‘’—Œ†ˆě

 4 EMPLOYEE BENEFIT PROGRAMS x 401(k) Savings Plan including a Safe Harbor direct match of up to 5% x Health Insurance x Dental Insurance x Vision Insurance x FSA Plan (Flexible Spending) x Health Savings Accounts (HSA) x Life Insurance x Voluntary Additional Life Insurance x Long-Term Disability x Voluntary Short-Term Disability x Membership Dues x Parking/Public Transportation x Mobile Phone Reimbursement x Profit Sharing x PTO Benefits x Holidays x Voting Time Off x Jury Duty Leave x Bereavement Leave x Employee Referral Program x Employee Assistance Program (EAP) 4.1 Employee Benefits Eligible employees at Rödl Management Inc. are provided a wide range of benefits. A number of the programs (such as Social Security, workers' compensation, state disability, and unemployment insurance) cover all employees in the manner prescribed by law. Benefits eligibility is dependent upon a variety of factors, including employee classification. The Human Resources Manager can identify the programs for which the employee is eligible. Details of many of these programs can be found elsewhere in the employee handbook. The following benefit programs are available to eligible employees: Some benefit programs require contributions from the employee, but most are fully paid by Rödl Management Inc. 4.2 PTO (Paid Time Off) Rödl Management Inc. believes that employees should have opportunities to enjoy time away from work to help balance their lives. Recognizing that employees have diverse needs for time

22 off from work, a Paid Time Off (PTO) policy has been established to meet their needs. The benefit of PTO is that it promotes a flexible approach to time off. Employees are accountable and responsible for managing their own PTO hours to allow for adequate reserves if there is a need to cover vacation, illness, appointments, emergencies or other needs that require time off from work. All time other than working time, CPE, holidays, jury duty and bereavement leave, and time off to vote will be taken as PTO. PTO must be scheduled in advance for time off for vacations or personal appointments. It is subject to Partner approval, team staffing needs and workloads. Unscheduled absences will be monitored. In addition, Rödl Management Inc. will allow same day make-up for up to three hours for excused absences. If, for instance, an Employee needs to schedule a doctor or dental appointment or have personal errands to handle, they can make up the additional hours (up to three hours) the same day the appointment occurred. It is subject to partner approval, team staffing needs and workloads. This will not count against PTO time. The Firm also offers Flexible Work Arrangements (FWA) as discussed in Policy 7.1.1. Regular full-time employees and *Salaried Interns (**Regular part-time employees and hourly interns where required by law) are eligible to earn and use PTO time as described in this policy. Effective January 1, 2025, all full-time employees will be eligible for 25 days of PTO per year. For employees working 40 hours or more per week, a “day” shall be eight hours, and the hourly equivalent will be 200 hours per year. For full-time hourly employees who average 35-39 hours per week, a day shall be seven hours long, and the hourly equivalent of PTO will be 175 hours per year. Likewise, for full-time hourly employees averaging 30-34 work hours per week a day shall be six hours long, and the hourly equivalent of PTO will be 150 hours per year. *PTO benefits will accrue at 1 day (8 hours) per month for all salaried interns, except where state or local ordinance may require more time off. Any additional time off will be taken without pay. PTO for salaried interns is awarded based on the anticipated length of their J-1 internship defined in their DS-7002 and does not expire or reset at the end of the calendar year. **When required by State or Local law, part time employees are eligible for Sick Time or other paid time off in compliance with applicable law. Eligible employees will receive one full week (40, 35 or 30 hours depending on classification) of PTO at the beginning of each calendar year (“front loading”). Employees will accrue PTO monthly for the rest of the calendar year until they reach their maximum annual PTO allowance. Employee who are hired or transition to a PTO eligible position after January 15th of each year will receive a pro-rated allowance, including prorated front loading. PTO time off is paid at the employee's base pay rate at the time of use. It does not include any special forms of compensation such as incentives or bonuses.

23 To take PTO time, employees should request advance approval from their supervisors in Paylocity (or any future HRIS used by the Firm). Additional information on Time Off Requests in Paylocity is available on GRIPS. Requests will be reviewed based on a number of factors, including business needs and staffing requirements. No PTO should be scheduled during a department’s Busy Season. Employees who are unable to report to work due to illness or injury should notify their supervisor before the scheduled start of their workday if possible. They must also contact their supervisor on each additional day of absence. Employees should submit a PTO request in Paylocity for the unplanned absence as soon as reasonably possible and no later than their first day back to work. When an employee takes less PTO than originally scheduled (i.e. it is necessary for them to do some work on behalf of the Firm while on scheduled PTO), they should contact the Human Resources Department at HR@roedlusa.com to correct the time recorded in Paylocity. It is the responsibility of the employee to accurately report the PTO taken and approved in Paylocity and TimeCapture (or any future timekeeping system designated by the Firm) , and to ensure accuracy in both systems. Please reference information GRIPS under Time Off Requests in Paylocity on updating or cancelling requests. Paylocity is the official record for PTO allowances and balances. The HR department conducts a monthly reconciliation between Paylocity and TimeCapture. Any discrepancies in an Employee’s PTO requests in Paylocity and the time recorded in TimeCapture will result in a correction to the balance reported in Paylocity. The Employee’s PTO balance is indicated in Paylocity. This is the number of hours they have left of PTO for the remainder of the current year. This is updated as soon as the supervisor approves a time off request. Any additional time off in excess of Employee’s PTO allowance will be taken without pay. There is no carryover of PTO time except as required by State or Local Law. If it is not used by the end of the calendar year it is forfeited (except as noted above for salaried interns on a J1 visa).

24 4.3 Holidays Rödl Management Inc. will grant holiday time off to all FT regular employees and salaried interns on a J1 visa on the holidays listed below: New Year's Day After Busy Season Holiday Memorial Day Independence Day (January 1) (April 16 or Floating) (last Monday in May) (July 4) Addtl. Day at Independence Day (to be designated each year) (first Monday in September) (fourth Thursday in November) (fourth Friday in November) (December 25) Labor Day Thanksgiving Day after Thanksgiving Christmas Additional Day atChristmas  Charity Day Floating Day (to be designated each year) (Day of Service) (Day after the April tax day or floating) The Firm will observe Holidays that fall on a Saturday on the preceding Friday and holidays that all on a Sunday on the following Monday. Rödl Management Inc. will grant paid holiday time off to all employees immediately upon assignment to an eligible employment classification (Regular Full Time Employees/Salaried Interns). Holiday pay will be calculated based on the employee's straight-time pay rate (as of the date of the holiday) times the number of hours the employee would otherwise have worked on that day. Employees who regularly work 40 hours per week or more will receive 8 hours of pay. Employees who average 35-39 hours will receive 7 hours of pay, and employees averaging 30-34 hours per week will receive 6 hours of holiday pay.After Busy Season / Floating Holiday – While the offices of Rödl Management Inc. will be open on April 16th (or the day after the April tax deadline if it falls on another day other than the 15th), employees may take this day off as an additional holiday to relax after the Busy Season. Alternately, employees may “float” this holiday and take it any time before the end of the calendar year; the Holiday will not rollover to the next calendar year. As this Holiday is meant to be a post Busy Season event, employees generally will not be able to schedule this Holiday before the end of Busy Season. At the Partner’s discretion, some employees who are not involved in audit work may be able to schedule their floating holiday on Martin Luther King Day, so long as the employee has already worked through one full prior Busy Season.Charity Day - In the spirit of giving back to the community, the “Charity Day” is meant to give the employee paid time off to give back to the community and support the charity or public service of their choice. The Charity Day is a floating holiday to be scheduled at the employee’s discretion and with the Partner’s approval. The employee must be volunteering for a bona fide charitable organization or public service, and the Firm, at its discretion, may require the employee to provide proof of the charitable service. An employee must have worked at least one full Busy Season to be eligible for Charity Day. The Charity Day should generally be

25 scheduled after Busy Season. At the Partner’s discretion, some employees who are not involved in audit work may be able to schedule their Holiday prior to April 15th. The Charity Day should not be tacked onto other PTO time. Employees will request time off for the After Busy Season Holiday and Charity Day in Paylocity through the Employee Programs option on the Time Off tab and record the time off in TimeCapture (or any future timekeeping system) as 953 – Holiday with a note in the description field identifying the holiday. Employees are not permitted to schedule either the After Busy Season Holiday or the Charity Day once they have tendered their resignation with the Firm. The Firm will cancel any previous requests submitted before the employee turned in their notice that may fall during the notice period. If a recognized holiday falls during an eligible employee's paid or unpaid absence, other than vacation (e.g., leave of absence, etc.), the employee will be ineligible for holiday pay. If eligible nonexempt employees work on a recognized holiday, they will receive holiday pay plus wages at their regular rate for the hours worked on the holiday or, at Rödl Management Inc.’s discretion, take another day off in lieu of the holiday. If a nonexempt employee opts to receive holiday pay plus wages, they must, with a Partner’s approval, enter the holiday hours in the timekeeping system on another day that they otherwise did not work in the same payroll period (such as a Saturday or Sunday). Exempt employees will be able to take another day off in lieu of the holiday at the Firm’s discretion. 4.4 Workers' Compensation Insurance Rödl Management Inc. provides a comprehensive workers' compensation insurance program at no cost to ALL employees. This program covers any injury or illness sustained in the course of employment 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. Supervisors should then in turn immediately notify the Human Resources Manager. 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. 4.5 Time Off to Vote Rödl Management Inc. encourages employees to fulfill their civic responsibilities by participating in elections. Generally, employees are able to find time to vote either before or after their regular work schedule. If this is not possible, a reasonable amount of time off will be granted for this purpose. A “reasonable amount of time” will typically be two hours or less. A Partner may grant additional time if there are extraordinary circumstances. The Firm will continue the regular pay for all FT regular employees. Other employees may take the approved

26 time as unpaid. 4.6 Bereavement Leave Employees who wish to take time off due to the death of an immediate family member should notify their supervisor immediately. Bereavement Leave will be allowed for a period of up to five days in order to allow for travel to and attendance at the funeral or memorial service. Rödl Management Inc. defines "immediate family" as the employee's spouse/significant other, parent, child, sibling, grandparent or grandchildren; and the employee's spouse's/significant other’s parent, child, sibling, grandparent or grandchildren; and the employee's child's spouse. Employee classifications that qualify for Bereavement Leave are: * Regular full-time employees Full Time Regular Employees may use PTO to attend funerals of friends, acquaintances or more distant family members. 4.7 Jury Duty Rödl Management Inc. encourages employees to fulfill their civic responsibilities by serving jury duty when required. Employees in an eligible classification may request up to one week of paid jury duty leave over any one-year period for most courts. Managing Partners may permit additional time off for employees selected for Grand Jury Duty. The employee's pay while on jury duty will be calculated on the employee's base pay rate times the number of hours the employee would otherwise have worked on the day or days of absence. Employee classifications that qualify for pay while on jury duty are: * Regular full-time employees If employees are required to serve jury duty beyond the period of paid jury duty leave, they may use any available PTO time or may request an unpaid jury duty leave of absence. Employees must notify their supervisor as soon as possible so that the supervisor may arrange to accommodate their absence. Of course, employees are expected to report for work whenever the court schedule permits. Either Rödl Management Inc. or the employee may request an excuse from jury duty if, in Rödl Management Inc.'s judgment, the employee's absence would create serious operational difficulties. Rödl Management Inc. will continue to provide health insurance benefits for the full term of the jury duty absence

27 4.8 Benefits Continuation (COBRA) The federal Consolidated Omnibus Budget Reconciliation Act (COBRA) gives employees and their qualified beneficiaries the opportunity to continue health insurance coverage under Rödl Management Inc.'s health plan when a "qualifying event" would normally result in the loss of eligibility. Some common qualifying events are resignation, termination of employment, death of an employee, a reduction in an employee's hours or a leave of absence, an employee's divorce or legal separation, and a dependent child no longer meeting eligibility requirements. Under COBRA, the employee or beneficiary pays the full cost of coverage at Rödl Management Inc.'s group rates plus an administration fee. Rödl Management Inc. provides each eligible employee with a written notice describing rights granted under COBRA when the employee becomes eligible for coverage under Rödl Management Inc.'s health insurance plan. The notice contains important information about the employee's rights and obligations. 4.9 Health, Dental and Vision Insurance Rödl Management Inc.'s health, dental and vision insurance plans provide Regular Full-Time Employees and their dependents access to medical, dental and vision insurance benefits. Currently, the Firm pays a 70% co-payment for the employee’s own medical and prescription drug premium and 100% of the employee’s own dental insurance premium. Employees pay the full premium for vision coverage and the cost of dependent coverage for all plans. Eligible employees may participate in the health, dental and vision insurance plans subject to all terms and conditions of the agreement between Rödl Management Inc. and the insurance carrier. Details of the health, dental and vision insurance plans are described in their respective Summary Plan Descriptions (SPD). SPDs and information on cost of coverage is provided on our GRIPS page in advance of enrollment to eligible employees. Contact the Human Resources Department for more information about health, dental and vision insurance benefits. 4.10 Life Insurance Life insurance offers the individuals and their family important financial protection. Rödl Management Inc. provides a basic life insurance plan for Regular Full-Time Employees. Accidental Death and Dismemberment (AD&D) insurance provides protection in cases of serious injury or death resulting from an accident. AD&D insurance coverage is provided as part of the basic life insurance plan. Eligible employees may participate in the life insurance plan subject to all terms and conditions of the agreement between Rödl Management Inc. and the insurance carrier.

28 Details of the basic life insurance plan including benefit amounts are described in the Summary Plan Description provided to eligible employees and is available on our GRIPS page. Contact the Human Resources Department for more information about life insurance benefits. 4.11 Voluntary Additional Life Insurance Additional Group Life Insurance is available to Regular Full-Time Employees at their cost who wishes purchase additional life insurance subject to approval by the insurance company. 4.12 Long-Term Disability Rödl Management Inc. provides a long-term disability (LTD) benefits plan to help Regular full- time employees eligible employees cope with an illness or injury that results in a long-term absence from employment. LTD is designed to ensure a continuing income for employees who are disabled and unable to work. Eligible employees may participate in the LTD plan subject to all terms and conditions of the agreement between Rödl Management Inc. and the insurance carrier. 4.13 Short Term Disability Short Term Disability is available to Regular Full-time Employees at their cost who wishes this insurance. Details of the STD benefits plan including benefit amounts, and limitations and restrictions are described in the Summary Plan Description provided on our GRIPS page. Contact the Human Resources Department for more information about STD benefits. 4.14 401(k) Savings Plan Rödl Management Inc. has established a 401(k) savings plan to provide employees the potential for future financial security for retirement. To be eligible to join the 401(k) savings plan an employee must be 21 years of age or older and not classified as an “Intern” or “Temporary” employee. There is no minimum hours requirement for participation and the plan is available to part-time regular as well as full-time regular employees. Employees may join the plan during any quarterly open enrollment period. Eligible employees may participate in the 401(k) plan subject to all terms and conditions of the plan. The 401(k) savings plan allows employees to elect how much salary they want to contribute and direct the investment of their plan account, so they can tailor their own retirement package to meet their individual needs. Employees who contribute to a 401(k) plan with traditional deferrals that are deducted from their pay before federal and state tax withholdings are calculated save tax dollars at the time

29 of the deferral by having their current taxable compensation reduced. Employees who elect to make deferrals through the post-tax Roth option pay federal and state taxes on the current deferral but may experience tax savings on future distributions in retirement. Employees are eligible to make deferrals through both the pre-tax and Roth option. All eligible employees will receive a Safe Harbor Direct Match of up to 5%. Employees will always be 100% vested in their Safe Harbor Contributions. Complete details of the 401(k) savings plan are described in the Summary Plan Description provided on our GRIPS page. Contact the Human Resources Department for more information about the 401(k) plan. 4.15 Flexible Benefits Plans Rödl Management Inc. has established flexible benefits plans for all Regular Full- time Employees including a Flexible Spending Account (FSA), a Health Savings Account (HSA) and a Dependent Care Flexible Spending Account. Under these plans employees are able to pay for certain benefits, such as unreimbursed medical, dental and vision expenses and dependent care, with pre-tax dollars. 4.16 Employee Referral Program Rödl Management Inc. has implemented an Employee Referral Program whereby an employee can earn a cash bonus by referring a qualified candidate for a specific position after the candidate is approved for consideration and ultimately hired. There is also an Intern Ambassador Program for referrals for qualified college juniors and seniors to intern with the Firm. The PEP Team must receive the referral before the candidate is interviewed. This bonus excludes Human Resource / PEP Personnel, Partners, Associate Partners, and close relatives of the candidate. For more specifics on this program, please see the information on the Employee Referral Form available on GRIPS or contact the PEP Team.

30 5 LEAVES OF ABSENCE 5.1 Medical Leave Rödl Management Inc. provides medical leaves of absence without pay to Regular Full-Time Employees & Regular Part-Time Employees (those who have been employed with the Firm for at least a year and worked 1250+ hours in the preceding 12 months) who are temporarily unable to work due to a serious health condition or disability. For purposes of this policy, serious health conditions or disabilities include inpatient care in a hospital, hospice, or residential medical care facility; continuing treatment by a health care provider; and temporary disabilities associated with pregnancy, childbirth, and related medical conditions. Eligible employees should make requests for medical leave to their supervisors at least 30 days in advance of foreseeable events and as soon as possible for unforeseeable events. Eligible employees are normally granted leave for the period of the disability, up to a maximum of 12 weeks within any 12-month period. Any combination of medical leave and family leave may not exceed this maximum limit. If the initial period of approved absence proves insufficient, consideration will be given to a request for an extension with Managing Partner approval. Employees will be required to use any available, unused PTO time available concurrently with unpaid medical leave. Employees who sustain work-related injuries are eligible for a medical leave of absence for the period of disability in accordance with all applicable laws covering occupational disabilities. Subject to the terms, conditions, and limitations of the applicable plans, Rödl Management Inc. will continue to provide health insurance benefits for the full period of the approved medical leave, but the employee must pay their portion of the premium on a monthly basis. So that an employee's return to work can be properly scheduled, an employee on medical leave is requested to provide Rödl Management Inc. with at least two weeks advance notice of the date the employee intends to return to work. When a medical leave ends, the employee will be reinstated to the same position, if it is available, or to an equivalent position for which the employee is qualified. If an employee fails to return to work on the agreed upon return date, without prior notification as to the reason for such delay, Rödl Management Inc. will assume that the employee has resigned. In these cases, the Firm may seek reimbursement from the employee for the employer’s share of the insurance premiums that were paid during their absence. 5.1.1 Pregnancy-Related Absences Rödl Management Inc. will not discriminate against any employee who requests an excused absence for medical disabilities associated with pregnancy. Such leave requests will be

31 evaluated according to the medical leave policy provisions outlined in this handbook and all applicable federal and state laws. Rödl Management Inc. will provide up to twelve (12) weeks of unpaid maternity leave for any Regular Full-time Employee or Regular Part time Employee who has worked for the Firm at least a year and at least 1250 hours in the preceding 12 months. These twelve weeks will be combined to run concurrently with any available, unused PTO time. Requests for time off associated with pregnancy and/or childbirth, such as bonding and childcare, not related to medical disabilities for those conditions will be considered in the same manner as other requests for unpaid family leave. 5.2 Family Leave Rödl Management Inc. provides family leaves of absence without pay to Regular Full-time Employees & Regular Part-time Employees (those who have worked at least 1250 hours in the preceding 12 months) who wish to take time off from work duties to fulfill family obligations relating directly to childbirth, adoption, or placement of a foster child; or to care for a child, spouse, or parent with a serious health condition. A serious health condition means an illness, injury, impairment, or physical or mental condition that involves inpatient care in a hospital, hospice, or residential medical care facility, or continuing treatment by a health care provider. Eligible employees should make requests for family leave to their supervisors at least 30 days in advance of foreseeable events and as soon as possible for unforeseeable events. Employees requesting family leave related to the serious health condition of a child, spouse, or parent may be required to submit a health care provider's statement verifying the need for a family leave to provide care, its beginning and expected ending dates, and the estimated time required. Eligible employees may request up to a maximum of 12 weeks of family leave within any rolling 12-month period. Any combination of family leave and medical leave may not exceed this maximum limit. If the initial period of approved absence proves insufficient, consideration will be given to a request for an extension with Managing Partner approval. Employees will be required to use any available PTO time concurrent with unpaid family leave. Married employee couples may be restricted to a combined total of 12 weeks leave within any 12-month period for childbirth, adoption, or placement of a foster child; or to care for a parent with a serious health condition. Subject to the terms, conditions, and limitations of the applicable plans, Rödl Management Inc. will continue to provide health insurance benefits for the full period of the approved family leave, however, the employee must pay their share of the premium on a monthly basis. So that an employee's return to work can be properly scheduled, an employee on family leave is requested to provide Rödl Management Inc. with at least two weeks advance notice of the date the employee intends to return to work. When a family leave ends, the employee will be

32 reinstated to the same position, if it is available, or to an equivalent position for which the employee is qualified. If an employee fails to return to work on the agreed upon return date, without prior notification as to the reason for such delay, Rödl Management Inc. will assume that the employee has resigned. In these cases, the Firm may seek reimbursement from the employee for the employer’s share of the insurance premiums that were paid during their absence. 5.3 Personal Leave Rödl Management Inc. provides leaves of absence without pay to Regular Full-time Employees & Regular Part-time Employees (those who have worked at least 1250 hours in the preceding 12 months) who wish to take time off from work duties to fulfill personal obligations. Any employee must request, and be approved for, any such personal leave before taking it. As soon as eligible employees become aware of the need for a personal leave of absence, they should request a leave from their supervisor. Personal leave may be granted for a period of up to 30 consecutive calendar days every 3 years (requires approval by a Managing Partner and CEO). If this initial period of absence proves insufficient, consideration will be given to a written request for a single extension of no more than 10 calendar days. An employee will be required to take any available PTO time as part of the approved period of leave. Requests for personal leave will be evaluated based on a number of factors, including anticipated workload requirements and staffing considerations during the proposed period of absence. Subject to the terms, conditions, and limitations of the applicable plans, Rödl Management Inc. will continue to provide health insurance benefits for the full period of the approved personal leave, however, the employee must pay the full cost of premium on a monthly basis. When a personal leave ends, every reasonable effort will be made to return the employee to the same position, if it is available, or to a similar available position for which the employee is qualified. However, Rödl Management Inc. cannot guarantee reinstatement in all cases. If an employee fails to report to work promptly at the expiration of the approved leave period, without prior notification as to the reason for such delay, Rödl Management Inc. will assume the employee has resigned. 5.4 Military Leave A military leave of absence will be granted to employees who are absent from work because of service in the U.S. uniformed services in accordance with the Uniformed Services Employment and Reemployment Rights Act (USERRA). Advance notice of military service is required, unless military necessity prevents such notice, or it is otherwise impossible or unreasonable.

33 • Reemployment The leave will be unpaid. However, employees may use any available paid time off for the absence. Continuation of health insurance benefits is available as required by USERRA based on the length of the leave and subject to the terms, conditions and limitations of the applicable plans for which the employee is otherwise eligible. For employees who are on active duty for a period of more than 31 days, Rödl Management Inc. will continue to provide health insurance benefits during the approved Military Leave for up to 24 months; however, the employee must pay the full cost of the premium on a monthly basis. The group term life/AD&D and disability insurance paid by the Firm will terminate the day the employee becomes active military. Voluntary supplemental life insurance will terminate the day the employee becomes active military. Converting to an individual policy may continue voluntary dependent life insurance coverage. To exercise this conversion option, employees must submit a written application and the first premium payment within 30 days immediately following the termination of coverage. With respect to the Firm’s retirement plan, upon reemployment, employees who have taken military leave will be credited for purposes of vesting with the time spent in military service and will be treated as not having incurred a break in service. Immediately upon reemployment, the employee may, at the employee’s election, make any or all employee contributions that the employee would have been eligible to make had the employee's employment not been interrupted by military service. Such contributions must be made within a period that begins with the employee's reemployment and that is not greater in duration than three times the length of the employee's military service. Employees will receive all associated Firm match for such contributions. An employee on military leave may, but is not required to, use available PTO while on leave. Upon an employee's prompt application for reemployment (as defined below), an employee will be reinstated to employment in the following manner depending upon the employee's period of military service: 1. Less than 91 days of military service - (i) in a position that the employee would have attained if employment had not been interrupted by military service; or (ii) if found not qualified for such position after reasonable efforts by the Firm, in the position in which the employee had been employed prior to military service. 2. More than 90 days and less than 5 years of military service - (i) in a position that the employee would have attained if employment had not been interrupted by military service or a position of like seniority, status and pay, the duties of which the employee is qualified to perform; or (ii) if proved not qualified after reasonable efforts by the Firm, in the position the employee left, or a position of like seniority, status and pay, the duties of which the employee is qualified to perform. 3. Employee with a service-connected disability - if after reasonable accommodation efforts by the Firm, an employee with a service-connected disability is not qualified for employment in the position he or she would have attained or in the position that he or she left, the employee will be employed in (i) any other position of similar seniority, status and pay for which the employee is qualified or could become qualified with reasonable efforts by the Firm; or (ii) if no such position exists, in the nearest approximation consistent with the circumstances of the employee's situation.

34 • Application for Reemployment An employee who has engaged in military service must, in order to be entitled to the reemployment rights set forth above, submit an application for reemployment according to the following schedule: 1. If service is less than 31 days (or for the purpose of taking an examination to determine fitness for service) - the employee must report for reemployment at the beginning of the first full regularly scheduled working period on the first calendar day following completion of service and the expiration of eight hours after a time for safe transportation back to the employee's residence. 2. If service is for 31 days or more but less than 181 days - the employee must submit an application for reemployment with Human Resources no later than 14 days following the completion of service. 3. If service is over 180 days - the employee must submit an application for reemployment with Human Resources no later than 90 days following the completion of service. 4. If the employee is hospitalized or convalescing from a service-connected injury - the employee must submit an application for reemployment with Human Resources no later than two years following completion of service. • Exceptions to Reemployment In addition to the employee's failure to apply for reemployment in a timely manner, an employee is not entitled to reinstatement as described above if any of the following conditions exist: 1. The Firm’s circumstances have so changed as to make reemployment impossible or unreasonable 2. Reemployment would pose an undue hardship upon the Firm. 3. The employee's employment prior to the military service was merely for a brief, non- recurrent period and there was no reasonable expectation that the employment would have continued indefinitely or for a significant period. 4. The employee did not receive an honorable discharge from military service. • General Benefits Upon Reemployment Employees reemployed following military leave will receive seniority and other benefits determined by seniority that the employee had at the beginning of the military leave, plus any additional seniority and benefits the employee would have attained, with reasonable certainty, had the individual remained continuously employed. An employee’s time spent on active military duty will be counted toward their eligibility for FMLA leave once they return to their job at the Firm. Additionally, upon reemployment, a covered employee will not be discharged except for cause for up to one year following reemployment. • Documentation An employee's manager will, upon the employee's reapplication for employment, request that the employee provide the Firm with military discharge documentation to established the

35 x Issue arising from a covered military member’s short notice deployment (i.e., notification. x Military events and related activities, such as official ceremonies, programs, or events sponsored by the military or family support or assistance programs. x Certain childcare and related activities arising from the active duty or call to active- duty status of a covered military member. timeliness of the application for reemployment, the duration of the military service, and the honorable discharge from the military service. Contact the Human Resources Manager for more information or questions about military leave. 5.4.1 Military Family Leave Entitlements Rödl Management Inc. provides leaves of absence without pay to Regular Full-time Employees & Regular Part-time Employees (those who have worked at least 1250 hours in the preceding 12 months) who wish to take time off from work duties to fulfill family obligations relating to the deployment of, or care for, a family member who is on active duty with the US military. Military Caregiver Leave: Rödl Management Inc. will grant an eligible employee who is a spouse, child, parent, or next of kin of a covered service member with a serious injury or illness up to a total of 26 workweeks of unpaid leave during a “single 12-month period” to care for the service member. A covered service member is 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. A serious injury or illness is one that was incurred by a service member in the line of duty or on active duty that may render the service member medically unfit to perform the duties of his or her office, grade, rank, or rating. The “single 12-month period” for leave to care for a covered service member with a serious injury or illness begins on the first day the employee takes leave for this reason and ends 12 months later, regardless of the 12-month period established by the employer for other types of FMLA leave. An eligible employee is limited to a combined total of 26 workweeks of leave for any FMLA-qualifying reason during the “single 12-month period.” (Only 12 of the 26 weeks total may be for a FMLA-qualifying reason other than to care for a covered service member.) Qualifying Exigency Leave: Rödl Management will grant an eligible employee up to a total of 12 workweeks of unpaid leave during the normal 12-month period established by the employer for FMLA leave for qualifying exigencies arising out of the fact that the employee’s spouse, son, daughter, or parent is on active duty, or has been notified of an impending call or order to active duty, in support of a contingency operation. Under the terms of the statute, qualifying exigency leave is available to a family member of a military member in the National Guard or Reserves; it does not extend to family members of military members in the Regular Armed Forces. Qualifying exigencies include: deployment on seven or less days of notice) for a period of seven days from the date of

36 x Making or updating financial and legal arrangements to address a covered military member’s absence. x Attending counseling provided by someone other than a health care provider for oneself, the covered military member, or the child of the covered military member, the need for which arises from the active duty or call to active-duty status of the covered military member; x Taking up to five days of leave to spend time with a covered military member who is on short-term temporary, rest and recuperation leave during deployment; x Attending to certain matters, including attending arrival ceremonies, reintegration briefings and events, and other official ceremonies or programs sponsored by the military for a period of 90 days following the termination of the covered military member’s active-duty status, and addressing issues arising from the death of a covered military member; x Any other event that the employee and employer agree is a qualifying exigency

37 TIMEKEEPING/PAYROLL6 6.1 Paydays All employees are paid semi-monthly on the 15th and end of the month. Each paycheck will include earnings for all work performed through that payroll period for all salaried personnel. Hourly employees are paid one pay period in arrears. In the event that a regularly scheduled payday falls on a day off such as a weekend or holiday, employees will receive pay on the last day of work before the regularly scheduled payday. The Firm will deposit employees’ pay directly into their bank accounts when they provide advance written authorization to Rödl Management Inc. An itemized statement of wages is available on our payroll provider’s website when Rödl Management Inc. makes direct deposits. Rödl Management is committed to compliance with the Fair Labor Standards Act (FLSA) and all regulations interpreting the FLSA. While Exempt Staff are generally entitled to their full salary regardless of the actual hours worked, certain deductions from salary are permitted, such as, but not limited to, personal absences of a day or more, leave under the Family Medical Leave Act, or deductions for disciplinary suspensions of a full day or more imposed in Good Faith for infractions of workplace conduct rules or safety violations of major significance. All pay deductions for exempt staff must be authorized by the HR Manager. Pay deductions not permitted by the FLSA are strictly prohibited. If any member of the Exempt Staff believes that a deduction is improper, they should immediately notify a Partner or the HR Manager. Any deductions not in compliance with the FLSA will be reimbursed. All staff that is not identified as Exempt Staff is considered Non-Exempt staff, even if they are usually paid on a salary basis. All Non-Exempt staff are identified at the time of hire or when they move from an Exempt role into a Non-Exempt role. Rödl Management is committed to paying its Non-Exempt staff for all hours worked. All overtime must be approved in advance by a Partner. There is no “off-the- clock” work. Non-exempt employees who do not report all time worked will be subject to disciplinary action up to and including termination. If any employee believes that they have not been paid for all hours worked or their pay is inaccurate for any reason, the employee must immediately notify their immediate supervisor and/or the HR Manager. 6.2 Pay Deductions The law requires that Rödl Management Inc. make certain deductions from every employee's compensation. Among these are applicable federal, state, and local income taxes. Rödl Management Inc. also must deduct Social Security taxes on each employee's earnings up to a specified limit that is called the Social Security "wage base," unless that employee is exempt from FICA withholding (i.e. a non-resident alien). Rödl Management Inc. matches the amount of Social Security taxes paid by each employee. Rödl Management Inc. offers programs and benefits beyond those required by law. Eligible employees may voluntarily authorize deductions from their pay checks to cover the costs of participation in these programs.

38 If employees have questions concerning why deductions were made from their paycheck or how they were calculated, the HR Manager can assist in having their questions answered.

39 7 WORK CONDITIONS & HOURS A. ‘œ„•—‘ˆ•‰’•„‘œ„—ˆ•‘„—ˆ–†‹ˆ‡˜ˆš‹Œ†‹Œ–‡ˆŢ‘ˆ‡„– ‘‰’•„ ˆ›Œ…ŒŒ—œ„‘‡ B. „„‘„ŠŒ‘Š„•—‘ˆ•‰’•„‘œ„—ˆ•‘„—ˆ–†‹ˆ‡˜ˆš‹Œ†‹Œ–‡ˆŢ‘ˆ‡„– ’•„ ˆ›Œ…ŒŒ—œę Managing Partners must inform the HR Manager of any agreed upon exceptions. 7.1.1 Flexible Work Arrangements The Firm is committed to excellence and to the belief that when flexibility is well integrated with a performance-based culture, it becomes a strategic tool to achieve our business goals and to foster engagement. Flexible work arrangements may include Flextime, Flexplace, Compressed Work Schedules or Part-Time Work Arrangement. Please see the Flexible Work Arrangement Guide on GRIPS for more details including how to request an FWA. This policy applies to full-time and part-time employees of the Firm. However, not every position lends itself to a flexible work arrangement. It will depend on the nature of the position, responsibilities, and the business needs of the Firm. No employee is entitled to a flexible work arrangement. Compensation, benefits based on salary, as well as time-off benefits may be impacted, depending on the specific arrangement. Some benefit plans are not pro-rated and some are not offered to part-time employees. Except for the 401(k) Safe Harbor Contribution equal to 3% of an employee’s total compensation, commuter reimbursement and mobile phone reimbursement, no benefits are offered to employees who work fewer than 30 hours per week. Specific details about benefit eligibility for part-time employees are provided in the relevant benefit plan’s document and Section 4 of this Manual: Employee Benefits Programs. The Firm or an employee may discontinue flexibility at any time if it is deemed necessary or appropriate to do so. The employee or Managing Partner should make every effort to provide notification of at least 2 weeks prior to ending flexibility. However, business needs may require a Managing Partner to provide less notice. 7.1 Work Schedules Regular working hours are from 8:30 a.m. to 5:30 p.m. or 8:00 a.m. to 5:00 p.m. depending on the office location, five days a week, with one hour for lunch, Monday through Friday. The same applies to fulltime remote employees. Work hours for the various “busy seasons” will be determined as required by the Managing Partners and must be adhered to by all affected personnel. Employees must receive express permission from

40 7.2 Use of Mail Systems Employees are required to reimburse Rödl Management Inc. for any charges resulting from their personal use of postage, FedEx or other carrier. 7.3 Smoking In keeping with Rödl Management Inc.'s intent to provide a safe and healthful work environment, smoking is prohibited throughout the workplace. This policy applies equally to all employees, clients and visitors. 7.4 Emergency Closings At times, emergencies such as severe weather, fires, power failures, etc. can disrupt Firm operations. In extreme cases, these circumstances may require the closing of our offices. Most employees are able to complete the essential functions of their job remotely. For the few employees whose role requires them to be in the office, and upon approval of the respective office’s Managing Partner, the Firm will pay for time in which they are unable to reach the office (or client office) in these circumstances. Employees are urged to use common sense and discretion in making decisions in this area. In the event of extreme circumstances during which the office (or client office) may be closed for several days, the Firm may require the employees to make up time on alternate days including weekends. 7.5 Business Travel Expenses and Regulations Rödl Management Inc. will reimburse employees for reasonable business travel expenses incurred while on assignments away from the normal work location. A Partner must approve all business travel in advance. Employees whose travel plans have been approved are responsible for making their own travel arrangements. When approved, the costs of travel, meals, lodging, and other expenses directly related to accomplishing business travel objectives will be reimbursed by Rödl Management Inc. Employees are expected to limit expenses to reasonable amounts. As the reimbursement amounts for mileage and per diem are subject to frequent change, please refer to our GRIPS site to find our most current reimbursement rates under our Business Travel Policy. Employees who are involved in an accident while traveling on business must promptly report the incident to their immediate supervisor. The immediate supervisor should then contact the HR Department as soon as is reasonably possible.

41 Employees who use their own personal vehicle or drive a rental vehicle while on Firm business should under no circumstances send or check text messages while driving. Additionally, employees should be aware of, and at all times follow, local regulations on the use of cell phones while driving keeping in mind that certain states and municipalities prohibit the use of handheld cellular devices while driving. With prior Partner approval, a family member or friend may accompany employees on business travel, when the presence of a companion will not interfere with successful completion of business objectives. Generally, employees are also permitted to combine personal travel with business travel, as long as time away from work is approved. Additional expenses arising from such nonbusiness travel are the responsibility of the employee. When travel is completed, employees should submit completed travel expense reports in Expensify within 30 days. Receipts for all individual expenses should accompany reports. Employees should contact their supervisor for guidance and assistance on procedures related to travel arrangements, expense reports, reimbursement for specific expenses, or any other business travel issues. Abuse of this business travel expenses policy, including falsifying expense reports to reflect costs not incurred by the employee, can be grounds for disciplinary action, up to and including termination of employment. 7.6 Office Appearance Policy Our office and workspace appearance are indicative of how we view ourselves and our attitude towards and respect for others, both colleagues and clients. All workspaces must remain clear of clutter and confidential materials at the end of the day.

42 8 EMPLOYEE CONDUCT & DISCIPLINARY ACTION x Theft or inappropriate removal or possession of property x Working under the influence of alcohol or illegal drugs x Possession, distribution, sale, transfer, or use of alcohol or illegal drugs in the workplace x Fighting or threatening violence in the workplace x Boisterous or disruptive activity in the workplace x Negligence or improper conduct leading to damage of employer-owned or customer-owned property x Insubordination or other disrespectful conduct x Smoking in prohibited areas x Sexual or other unlawful or unwelcome harassment x Possession of dangerous or unauthorized materials, such as explosives or firearms, in the workplace x Excessive absenteeism or any absence without notice x Unauthorized disclosure of business "secrets" or confidential information of the Firm or its clients or potential clients x Violation of personnel policies x Unsatisfactory performance or conduct 8.1 Employee Conduct and Work Rules To ensure orderly operations and provide the best possible work environment, Rödl Management Inc. expects employees to follow rules of conduct that will protect the interests and safety of all employees and the organization. It is not possible to list all the forms of behavior that are considered unacceptable in the workplace. The following are examples of infractions of rules of conduct that may result in disciplinary action, up to and including termination of employment: Employment with Rödl Management Inc. is at the mutual consent of Rödl Management Inc. and the employee, and either party may terminate that relationship at any time, with or without cause, and with or without advance notice. 8.2 Drug and Alcohol Use It is the Firm's desire to provide a drug-free, healthful, and safe workplace. To promote this goal, employees are required to report to work in appropriate mental and physical condition to perform their jobs in a satisfactory manner. While on the Firm’s premises and while conducting business-related activities of the Firm, no employee may use, possess, distribute, sell, or be under the influence of alcohol or illegal drugs. The legal use of prescribed drugs is permitted on the job only if it does not impair an employee's ability to perform the essential functions of the job effectively and in a safe manner that does not endanger other individuals in the workplace.

43 Violations of this policy may lead to disciplinary action, up to and including immediate termination of employment, and/or required participation in a substance abuse rehabilitation or treatment program. Such violations may also have legal consequences. Employees with questions on this policy or issues related to drug or alcohol use in the workplace should raise their concerns with their supervisor, the Human Resources Manager or the CEO without fear of reprisal. 8.3 Sexual and Other Unlawful Harassment and Discrimination Rödl Management Inc. is committed to maintaining a workplace free from sexual harassment and other forms of unlawful discrimination and harassment. Sexual harassment is a form of workplace discrimination. Rödl Management Inc. has a zero-tolerance policy for any form of sexual harassment, and all employees are required to work in a manner that prevents sexual harassment in the workplace. This Policy is one component of Rödl Management Inc.’s commitment to a discrimination-free work environment. This policy must be posted prominently in all work locations where required by law and be provided to employees upon hiring. Sexual harassment is against the law. All employees have a legal right to a workplace free from sexual harassment, and employees can enforce this right by filing a complaint internally with Rödl Management Inc., or with a government agency or in court under federal, state or local antidiscrimination laws. This policy applies to all employees, applicants for employment, interns, whether paid or unpaid, contractors and persons conducting business with Rödl Management Inc. Sexual harassment will not be tolerated. Sexual harassment is offensive, is a violation of our policies, is unlawful, and subjects Rödl Management Inc. to liability for harm to victims of sexual harassment. Harassers may also be individually subject to liability. Any employee, regardless of position in the Firm, who engages in sexual harassment or retaliation, or who knowingly allows such behavior to continue, will be penalized for such misconduct with disciplinary action, up to and including termination. Rödl Management Inc. will conduct a prompt, thorough and confidential investigation that ensures due process for all parties, whenever management receives a complaint about sexual harassment, or otherwise knows of possible sexual harassment occurring. Effective corrective action will be taken whenever sexual harassment is found to have occurred. All employees, including Partners, Associate Partners, Directors and Managers are required to cooperate with any internal investigation of sexual harassment. All employees are encouraged to report any harassment or behaviors that violate this policy. Upon request, Rödl Management Inc. will provide a complaint form for employees to report harassment and file complaints. See Policy 8.3.2 Complaint Procedure for more information. Partners, Associate Partners, Directors and Managers are required to report any complaint that they receive, or any harassment that they observe to the Human Resources Manager.

44 x Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive work environment, even if the complaining individual is not the intended target of the sexual harassment; x Such conduct is made either explicitly or implicitly a term or condition of employment; or x Submission to or rejection of such conduct is used as the basis for employment 1) Physical assaults of a sexual nature, such as: i) Touching, pinching, patting, grabbing, brushing against another employee’s body or poking another employee’s body; ii) Rape, sexual battery, molestation or attempts to commit these assaults. 2) Unwanted sexual advances or propositions, such as: i) Requests for sexual favors accompanied by implied or overt threats concerning the victim’s job performance evaluation, a promotion or other job benefits or detriments; ii) Subtle or obvious pressure for unwelcome sexual activities. This policy applies to all employees, paid or unpaid interns, and non-employees and all must follow and uphold this policy. What Is “Sexual Harassment”? Sexual harassment is a form of sex discrimination and is unlawful under federal, state, and (where applicable) local law. Sexual harassment includes harassment on the basis of sex, sexual orientation, gender identity and the status of being transgender. Sexual harassment includes unwelcome conduct which is either of a sexual nature, or which is directed at an individual because of that individual’s sex when: decisions affecting an individual’s employment. A sexually harassing hostile work environment consists of words, signs, jokes, pranks, intimidation, or physical violence which are of a sexual nature, or which are directed at an individual because of that individual’s sex. Sexual harassment also consists of any unwanted verbal or physical advances, sexually explicit derogatory statements or sexually discriminatory remarks made by someone which are offensive or objectionable to the recipient, which cause the recipient discomfort or humiliation, which interfere with the recipient’s job performance. Sexual harassment also occurs when a person in authority tries to trade job benefits for sexual favors. This can include hiring, promotion, continued employment or any other terms, conditions, or privileges of employment. This is also called “quid pro quo” harassment. Any employee who feels harassed should complain so that any violation of this policy can be corrected promptly. Any harassing conduct, even a single incident, can be addressed under this policy. Examples of sexual harassment. The following describes some, but not all, of the types of acts that may be unlawful sexual harassment and that are strictly prohibited:

45 3) Sexually oriented gestures, noises, remarks, jokes or comments about a person’s sexuality or sexual experience, which create a hostile work environment. 4) Sexual or discriminatory displays or publications anywhere in the workplace, such as: i) Displaying pictures, posters, calendars, graffiti, objects, promotional material, reading materials or other materials that are sexually demeaning or pornographic. This includes such sexual displays on workplace computers or cell phones and sharing such displays while in the workplace. 5) Hostile actions taken against an individual because of that individual’s sex, sexual orientation, gender identity and the status of being transgender, such as: i) Interfering with, destroying or damaging a person’s workstation, tools or equipment, or otherwise interfering with the individual’s ability to perform the job; ii) Sabotaging an individual’s work; iii) Bullying, yelling, name-calling. x filed a complaint of sexual harassment, either internally or with any anti-discrimination agency; x testified or assisted in a proceeding involving sexual harassment under state or local Human Rights Law or other anti-discrimination law; x opposed sexual harassment by making a verbal or informal complaint to management, or by simply informing a supervisor or manager of harassment; x complained that another employee has been sexually harassed; or x encouraged a fellow employee to report harassment. Who can be a target of sexual harassment? Sexual harassment can occur between any individuals, regardless of their sex or gender. Employees, paid or unpaid interns, and non- employees, including independent contractors, and those employed by companies contracting to provide services in the workplace are protected under this policy and applicable Federal, State and Local laws. A perpetrator of sexual harassment can be a superior, a subordinate, a coworker or anyone in the workplace including an independent contractor, contract worker, vendor, client, customer or visitor. Where can sexual harassment occur? Unlawful sexual harassment is not limited to the physical workplace itself. It can occur while employees are traveling for business or at employer sponsored events or parties. Calls, texts, emails, and social media usage by employees can constitute unlawful workplace harassment, even if they occur away from the workplace premises or not during work hours. What is “Retaliation”? Unlawful retaliation can be any action that would keep a worker from coming forward to make or support a sexual harassment claim. Adverse action need not be job- related or occur in the workplace to constitute unlawful retaliation. Such retaliation is unlawful under federal, state, and (where applicable) local law. This policy and applicable Federal/State/Local laws protect any individual who has engaged in “protected activity.” Protected activity occurs when a person has:

46 Retaliation Prohibition: No person covered by this Policy shall be subject to adverse employment action including being discharged, disciplined, discriminated against, or otherwise subject to adverse employment action because the employee reports an incident of sexual harassment, provides information, or otherwise assists in any investigation of a sexual harassment complaint. Rödl Management Inc. has a zero-tolerance policy for such retaliation against anyone who, in good faith complains or provides information about suspected sexual harassment. Any employee of Rödl Management Inc. who retaliates against anyone involved in a sexual harassment investigation will be subjected to disciplinary action, up to and including termination. Any employee, paid or unpaid intern, or non-employee working in the workplace who believes they have been subject to such retaliation should inform a Partner, Associate Partner, Director, Manager, or the Human Resources Manager. Any employee, paid or unpaid intern or non-employee who believes they have been a victim of such retaliation may also seek compensation in other available forums, as explained below in the section on Legal Protections. Reporting Procedure for Harassment or Discrimination: Preventing sexual harassment is everyone’s responsibility. Rödl Management Inc. provides regular training to help prevent sexual harassment. But the Firm cannot remedy acts of sexual harassment unless it knows about them. Any employee, paid or unpaid intern, or non-employee who has been subjected to behavior that may constitute sexual harassment, or any other form of harassment or discrimination, is encouraged to report such behavior to a Partner, Associate Partner, Manager or the Human Resources Manager. Anyone who witnesses or becomes aware of potential instances of sexual harassment should report such behavior to a Partner, Associate Partner, Director, Manager or the Human Resources Manager. Any employee, regardless of position, who has a complaint of or who witnesses harassment or discrimination prohibited by Company’s policies by anyone, including supervisors, managers, Employees or third parties, has a responsibility to immediately bring the issue to the attention of Company management. Employees may bring a complaint of or report an observation of discrimination or harassment prohibited by Company’s policies to their supervisor, a member of the Human Resources department, or any member of management. Reports of discrimination or harassment involving a member of management should not be reported to that person, but rather to one of the other persons identified above. A form for submission of a written complaint is available by contacting the Human Resources Department, and all employees are encouraged but not required to use this complaint form. Employees who are reporting sexual harassment on behalf of other employees should use the complaint form and note that it is on another employee’s behalf. See Policy 8.3.2 Complaint Procedure for more information. Employees, paid or unpaid interns or non-employees who believe they have been a victim of sexual harassment may also seek assistance in other available forums, as explained below in the section on Legal Protections. Supervisory Responsibilities. All Partners, Associate Partners, Directors and Managers who receive a complaint or information about suspected sexual harassment, observe what may be

47 sexually harassing behavior or for any reason suspect that sexual harassment is occurring, are required to report such suspected sexual harassment to the Human Resources Manager. In addition to being subject to discipline if they engaged in sexually harassing conduct themselves, Partners, Associate Partners and Managers will be subject to discipline for failing to report suspected sexual harassment or otherwise knowingly allowing sexual harassment to continue. Partners, Associate Partners, Directors and Managers will also be subject to discipline for engaging in any retaliation. 8.3.1 Disability Harassment The Firm maintains that all its employees should be able to enjoy a work environment free from all forms of discrimination, including disability harassment. Harassment because of someone’s disability is a form of misconduct which undermines the integrity of the employment relationship. No employee, regardless of physical ability, should be subjected to unsolicited and unwelcome overtures or conduct, either verbal or physical. Disability harassment generally does not refer to occasional comments of a socially acceptable nature. It refers to behavior, which is not welcome, which is personally offensive, which is socially unacceptable, which debilitates morale, and which therefore interferes with our work effectiveness. Such conduct, regardless of whom perpetrates it, is specifically prohibited. This includes but is not limited to continued or repeated verbal abuse regarding a person’s disability or about an individual’s appearance, size or personal characteristics, such as walking, talking, hearing, seeing, learning, etc., or an offensive or abusive physical contact. Alleged violations of this policy will be investigated and when the facts determine a violation has occurred, appropriate disciplinary action will be taken up to and including termination. See Policy 8.3.2 Complaint Procedure for more information. Any questions regarding either this policy or a specific fact or situation should be addressed to the Human Resources Manager or the CEO. 8.3.2 Complaint Procedure All harassment complaints must be reported as soon as possible and in accordance with the reporting policies and procedures described above in Section 8.3. Employees have the right to report a complaint to the Human Resources Manager, any Partner, Associate Partner, Director, Manager or any Company Officer, including the CEO. Complaints can be made in person, via email, TEAMS or any other form of communication utilized by the Firm. There is also an official Complaint Form that is available on GRIPS under Firm Policies. All complaints will be promptly and thoroughly investigated. The investigation will be objective and complete; all those with pertinent information on the subject will be interviewed. All persons involved in the interview process should also maintain confidentiality to the extent possible.

48 If an employee makes a complaint of harassment or discrimination, they may be required to put those matters into written form so as to clarify the nature of the issues and to better enable the Company to investigate. If an employee makes a complaint of harassment and feels that the complaint is not being handled properly or not being investigated properly, then the employee is required to take the matter to successively higher levels of authority within the company. No employee will suffer reprisals for reporting sexual, disability or other unlawful harassment or conduct, or for initiating or assisting in any action or proceeding regarding unlawful harassment or discrimination. Any incidents of further harassment or retaliation should be reported immediately to the Human Resources Manager, any Partner, Associate Partner, Director, Manager or a Company Officer. When the investigation ends, a determination will be made, and the results will be communicated to the complainant, the alleged harasser, and, as appropriate, to all others directly concerned. If sexual or other unlawful harassment is proven, prompt and effective remedial action will result. This action includes the following: (a) the harasser will be disciplined, and the complainant notified; (b) steps will be taken to prevent any further harassment; and (c) other appropriate remedial action will be taken. Complaint and Investigation of Discrimination and Harassment. All complaints or information about suspected discrimination or harassment, including but not limited to sexual harassment, will be investigated, whether that information was reported in verbal or written form. Investigations will be conducted in a timely manner and will be confidential to the extent possible. An investigation of any complaint, information or knowledge of suspected discrimination or harassment will be prompt and thorough and should be completed within 60 days or sooner as required by state or local ordinance, or as soon as is reasonably possible. The investigation will be confidential to the extent possible. All persons involved, including complainants, witnesses and alleged perpetrators will be accorded due process to protect their rights to a fair and impartial investigation. Any employee may be required to cooperate as needed in an investigation of suspected discrimination or harassment. Employees who participate in any investigation will not be retaliated against. Investigations will generally be done in accordance with the following steps (though the Firm retains the discretion to alter these steps depending upon the circumstances): • Upon receipt of complaint, the Human Resources Manager must inform the CEO and will then conduct an immediate review of the allegations, and take any interim actions, as appropriate. • If documents, emails or phone records are relevant to the allegations, take steps to obtain and preserve them. • Request and review all relevant documents, including all electronic communications.

49 x Interview all parties involved, including any relevant witnesses; Create a written documentation of the investigation (such as a letter, memo or email), which contains the following: o A list of all documents reviewed, along with a detailed summary of relevant documents; o A list of names of those interviewed, along with a detailed summary of their statements; o A timeline of events; o A summary of prior relevant incidents, reported or unreported; and o The final resolution of the complaint, together with any corrective actions action(s). • Keep the written documentation and associated documents in the employer’s records. • Promptly notify the individual who complained and the individual(s) who responded of the final determination and implement any corrective actions identified in the written document as determined and approved by the Executive Committee. • Inform the individual who complained of their right to file a complaint or charge externally as outlined below Legal Protections and External Remedies. Sexual harassment is not only prohibited by Rödl Management Inc. but is also prohibited by state, federal, and, where applicable, local law. Aside from the internal process at Rödl Management Inc., employees may also choose to pursue legal remedies with Federal, State or Local governmental entities at any time. Complaining internally to Rödl Management Inc. does not extend any employee’s time to file with or in court. The EEOC, State and Local agencies have varying time limits on when a complaint may be filed. Information on filing with the EEOC is stated below. Information on filing a complaint with the State or Local governing entity with jurisdiction over each Rödl Management Inc. office is posted in an accessible are in each office along with other Federal, State and Local employment law notification. The information is also available in GRIPS under Firm Policies. All employees and paid or unpaid interns of Rödl Management Inc. are protected by the United States Equal Employment Opportunity Commission (EEOC). The EEOC enforces federal anti-discrimination laws, including Title VII of the 1964 federal Civil Rights Act (codified as 42 U.S.C. § 2000e et seq.). An individual can file a complaint with the EEOC anytime within 180 days from the alleged harassment or discrimination (though some states permit such charges to be filed within 300 days of the alleged discrimination or harassment). There is no cost to file a complaint with the EEOC. The EEOC will investigate the complaint and determine whether there is reasonable cause to believe that discrimination has occurred, at which point the EEOC will issue a Right to Sue letter permitting the individual to file a complaint in federal court. The EEOC does not hold hearings or award relief but may take other action including pursuing cases in federal court on behalf of complaining parties. Federal courts may award remedies if discrimination is found to have occurred.

50 If an employee believes that he/she has been discriminated against at work, he/she can file a “Charge of Discrimination.” The EEOC has district, area, and field offices where complaints can be filed. Contact the EEOC by calling 1-800-669-4000 (1-800-669-6820 (TTY)), visiting their website at www.eeoc.gov or via email at info@eeoc.gov State and Local Protections. Many states and localities enforce laws protecting individuals from sexual harassment and discrimination. An individual should contact the state, county, city or town in which they live to find out if such a law exists. The Firm maintains a list of entities with jurisdiction over each physical office location on GRIPS under Firm Policies. Contact the Local Police Department. If the harassment involves physical touching, coerced physical confinement or coerced sex acts, the conduct may constitute a crime, and an employee, paid or unpaid intern has the right to contact the local police department. 8.4 The Genetic Information Nondiscrimination Act The Genetic Information Non-Discrimination Act of 2008 (GINA) prohibits employers and other entities covered by GINA Title II from requesting or requiring genetic information of an individual or family member of the individual, except as specifically allowed by law. To comply with this law, we are asking that employees not provide any genetic information to a request for medical information (i.e. doctor’s excuse for absences, etc.) “Genetic Information” as defined by GINA includes an individual’s family medical history, the results of an individual’s or family member’s genetic tests, the fact that an individual or an individual’s family member sought or received genetic services, and genetic information of a fetus carried by an individual or an individual’s family member or an embryo lawfully held by an individual or family member receiving assistive reproductive services. 8.5 Attendance and Punctuality To maintain a safe and productive work environment, Rödl Management Inc. expects employees to be reliable and to be punctual in reporting for scheduled work. Absenteeism and tardiness place a burden on other employees and on Rödl Management Inc. In the rare instances when employees cannot avoid being late to work or are unable to work as scheduled, they should notify their supervisor as soon as possible in advance of the anticipated tardiness or absence. Employees should also mark themselves out on the Office Calendar or request a co-worker to do it for them if they are unable to access the system themselves. Poor attendance and excessive tardiness are disruptive. Either may lead to disciplinary action, up to and including termination of employment. 8.6 Personal Appearance Dress, grooming, and personal cleanliness standards contribute to the morale of all employees and affect the business image Rödl Management Inc. presents to customers and visitors. During business hours, employees are expected to present a clean and neat appearance and to dress in appropriate attire. The Firm has a “Dress for Your Day” approach to determine appropriate

51 attire for each working day. At times, appropriate attire may be “business casual” or “smart casual.” Dress is a personal matter that requires each individual to exercise personal judgement. We realize there may be differences from one person to another, but everyone should make a positive, professional impression in their own style. Attire worn while interacting with our clients should always be client appropriate and adhere to client guidelines while at client sites (though never below Firm Dress Code Standards). Current examples of appropriate and inappropriate attire are posted on GRIPS. 8.7 Return of Property Employees are responsible for all Rödl Management Inc. property, materials, or written information issued to them or in their possession or control. Employees must return all Rödl Management Inc. property immediately upon request or upon termination of employment. The Firms expects remote employees to retain the original packaging for monitors, laptops, keyboards and any other equipment provided by the Firm. Upon separation, employees should return Firm property in the original packaging or provide suitable packaging at their own expense. The Firm will pay or reimburse for the cost of shipping to return the items. Where permitted by applicable laws, Rödl Management Inc. may withhold from the employee's check or final paycheck the cost of any items that are not returned when required. Rödl Management Inc. may also take all action deemed appropriate to recover or protect its property. 8.8 Employment Termination / Resignation Termination of employment is an inevitable part of personnel activity within any organization, and many of the reasons for termination are routine. Below are examples of some of the most common circumstances under which employment is terminated: • Resignation - voluntary employment termination initiated by an employee. Although advance notice is not required, Rödl Management Inc. requests at least two-weeks or longer written resignation notice from all employees. • Discharge - involuntary employment termination initiated by the organization. • Retirement - voluntary employment termination initiated by the employee meeting age, length of service, and any other criteria for retirement from the organization. Since employment with Rödl Management Inc. is based on mutual consent, both the employee and Rödl Management Inc. have the right to terminate employment at will, with or without cause, at any time. Employee benefits will be affected by employment termination in the following manner: all accrued, vested benefits that are due and payable at termination will be paid. Some benefits may be continued at the employee's expense if the employee so chooses. The employee will be notified in writing of the benefits that may be continued and of the terms, conditions, and limitations of such continuance.

52 8.9 Progressive Discipline The purpose of this policy is to state Rödl Management Inc.'s position on administering equitable and consistent discipline for unsatisfactory conduct in the workplace. The best disciplinary measure is the one that does not have to be enforced and comes from good leadership and fair supervision at all employment levels. Rödl Management Inc.'s own best interest lies in ensuring fair treatment of all employees and in making certain that disciplinary actions are prompt, uniform, and impartial. The major purpose of any disciplinary action is to correct the problem, prevent recurrence, and prepare the employee for satisfactory service in the future. Although employment with Rödl Management Inc. is based on mutual consent and both the employee and Rödl Management Inc. have the right to terminate employment at will, with or without cause or advance notice, Rödl Management Inc. may use progressive discipline at its discretion. Disciplinary action may call for any of four steps -- verbal warning, written warning, suspension with or without pay, or termination of employment -- depending on the severity of the problem and the number of occurrences. There may be circumstances when one or more steps are bypassed. Progressive discipline means that, with respect to most disciplinary problems, these steps will normally be followed: a first offense may call for a verbal warning; a next offense may be followed by a written warning; another offense may lead to a suspension, and still another offense may then lead to termination of employment. If more than 12 months have passed since the last disciplinary action, the process will normally start over depending on the severity of the issue. Rödl Management Inc. recognizes that there are certain types of employee problems that are serious enough to justify either a suspension, or, in extreme situations, termination of employment, without going through the usual progressive discipline steps. By using progressive discipline, we hope that most employee problems can be corrected at an early stage, benefiting both the employee and Rödl Management Inc.

53 MISCELLANEOUS9 9.1 Life-Threatening Illnesses in the Workplace Employees with life-threatening illnesses, such as cancer, heart disease, and other serious conditions often wish to continue their normal pursuits, including work, to the extent allowed by their condition. Rödl Management Inc. supports these endeavors as long as employees are able to meet acceptable performance standards and to perform the essential functions of their job, with or without reasonable accommodation. Any employee seeking an accommodation for a disability should refer to Policy 2.4 regarding Disability Accommodations. All medical information on individual employees is treated confidentially. Rödl Management Inc. will take reasonable precautions to protect such information from inappropriate disclosure. Employees have a responsibility to respect and maintain the confidentiality of employee medical information. Anyone inappropriately disclosing such information is subject to disciplinary action, up to and including termination of employment.

54 10.1 Overview Due to the dynamic, rapidly changing environment of information technology, a majority of Rödl Management Inc.’s policies concerning IT, including policies on passwords, cyber security management, licensing, etc. will be on GRIPS under the tab for RITE to ensure the most up-to date information. The policies in this manual are ones that are more constant and not affected by changes in technology. 10.2 Computer, E-Mail and Messaging Usage Computers, computer files, the e-mail system, TEAMS or any other messaging system and software furnished to employees are Rödl Management Inc. property intended for business use. Employees should have no expectation of privacy with regard to information and messaged stored in company systems. Rödl Management Inc. strives to maintain a workplace free of harassment and sensitive to the diversity of its employees. Therefore, Rödl Management Inc. prohibits the use of computers, TEAMS and the e-mail system in ways that are disruptive, offensive to others, or harmful to morale. For example, the display or transmission of sexually explicit images, messages, and cartoons is not allowed. Other such misuse includes, but is not limited to ethnic slurs, racial comments, off-color jokes, or anything that may be construed as harassment or showing disrespect for others. E-mail, TEAMS and any other messaging system may not be used to solicit others for commercial ventures, religious or political causes, outside organizations, or other non-business matters. All technology provided by the Firm, including computer systems, communication networks, Firm-related work records and other information stored electronically, is the property of the Firm and not the employee. In general, use of the Firm’s technology systems and electronic communications should be job-related and not for personal convenience. The Firm reserves the right to examine, monitor and regulate email and other electronic communications, directories, files and all other content, including internet use, transmitted by or stored in its technology systems, whether onsite or offsite. Internal and external email, voice mail, TEAMS messages and other electronic communications are considered business records and may be subject to discovery in the event of litigation. Employees must be aware of this possibility when communicating electronically within and outside the Firm. The Firm retains the authority to track employees' login times and durations to assess their access to the Firm's network during work hours. This login data is part of the Firm's continuous employee evaluation process and may be utilized for disciplinary actions if necessary 10 INFORMATION TECHNOLOGY & SOCIAL MEDIA

55 Employees should promptly notify their immediate supervisor, the Human Resources Manager, the CEO or any Partner, upon learning of any violation of this policy. Employees who violate this policy will be subject to disciplinary action, up to and including termination of employment. 10.3 Computer Policy Assigned Equipment Employees are responsible for the care and return of their computer and related equipment and other technological equipment assigned to them. See Policy 8.7 Return of Property for more details. 10.4 Social Media Only authorized employees may post on social media on behalf of the Firm. The Executive Committee will identify those employees who have authorization. Rödl Management Inc. has a few additional guidelines for personal use of social media when referencing Rödl Management Inc., Rödl Langford de Kock LLP our any related entity. The most current guidelines are available on GRIPS. • Employees need to know and adhere to all the Firm’s policies when using social media in reference whether for personal or professional use, and particularly those policies related to Harassment, Ethics and Conduct and Confidentiality of the Firm and its clients, • Employees should be aware of the effect their actions may have on their images, as well as the image of the Firm. The information that employees post may be public information for a long time. • Employees should be aware that the Firm may observe content and information made available by employees through social media. Employees should use their best judgment to ensure that their posts do not include material that is inappropriate or harmful to the Firm, its employees or customers. • Subject to applicable law, online activity that violates the Firm’s policies may subject an employee to disciplinary action up to and including termination. 10.4.1 Firm Social Media and Employee Privacy The Firm may on occasion use employee information (name, picture, position, etc.) in its social media platforms for recruitment purposes. Our employees' privacy is important to Rödl Management Inc. We respect employees’ privacy and understand the trust they place in us to safeguard their personal information. Employees’ personal data will only be provided to third parties for recruiting or business development purposes after they have been offered theopportunity to object thereto. At all times an employee can object against the use of their data for these purposes.