Table of Content S

Table of Content S

Table of Contents

ABOUT THIS HANDBOOK......

INTRODUCTION......

COMPANY POLICIES & PROCEDURES......

Grievance Policy......

Safety......

Training and Trial Period......

Job Opportunities......

Attendance......

Work Schedule......

Meal Periods......

Rest Periods......

Pay Day and Wage Statements......

Minimum Age of Employment......

Part-Time Employee Hours......

Overtime Pay......

Final Pay and Termination Adjustments......

Notice of Termination......

Proprietary Information......

Violence, Weapons, and Verbal Threats in the Workplace......

Customer Service......

Personal Appearance......

Apparel......

Housekeeping and Safety......

Emergency Procedures......

Company Property......

Personal Telephone Calls......

Travel Policy......

Electronic Communications Policy......

Employee Internet Use......

Copy Machines/Fax Machines......

Leaving Your Work Station......

Employee Review......

Employee Purchases......

Employee Pilferage/Vandalism......

Privacy Issues......

Sampling......

Time Clocks / Time Cards......

Essential Records......

Bulletins......

Conducting Business with Relatives......

Discipline and Warning System......

Smoking......

Personal Property......

Gambling......

Gifts/Gratuities/Samples......

Solicitations and Distribution......

Harassment in the Workplace......

Accommodation of Disability......

Accommodation of Religious Practices......

Substance Abuse......

Searches And Inspections......

Testing Procedures......

Disciplinary Action......

Drug Convictions......

Employee Assistance Program (EAP)......

COMPANY BENEFITS......

Benefit Program......

Paid Holidays......

Paid Time Off......

Personal Days......

Sick Days......

Vacation Time......

Sickness or Accident Off the Job......

Long Term Disability......

Accidents On the Job......

Medical Verification Certificate......

Jury Duty Leave......

Family and Medical Leave Act (FMLA)......

Small Necessities Leave (SNLA)......

Death in the Family......

Military Leave......

Life Insurance and Accidental Death......

Health Insurance......

Dental Plan......

401(k) Savings Plan......

Tuition Reimbursement......

Transportation......

The Mussel Club......

Slade Gorton & Co., Inc. Office Locations......

At-Will Employment

This employee handbook does not constitute an employment contract. No representative of the Company, other than the President, has any authority to enter into any agreement for employment for any specified period of time. In the absence of a specific written provision to the contrary signed by the Company’s CEO, all employment at Slade Gorton & Co., Inc., is on an at-will basis and may be terminated with or without cause, by either party, at any time.

Our Door is Always Open

This employee handbook is intended only as a description of Company policies and benefits. It is subject to change at any time without prior notice at the sole discretion of the Company.

If you have a question, concern, or complaint, please see the Vice President of Human Resources.

All rules, regulations and benefits information contained in this booklet are effective as of June 2015.

Welcome to Slade Gorton & Co., Inc.

As a new employee we want you to feel valued and important while working for Slade Gorton & Co. In fact, we hope you refer to us as “My Company” because you will play an important role in making us successful. Your happiness here will enable you to perform your job more efficiently and effectively.

The Company’s mission is to bring wholesome and nutritious seafood from around the world to America’s table, while honoring the work of the men and women globally who dedicate themselves to our industry.

In fulfilling our mission, Slade Gorton & Co. strives to be a vibrant force in the food industry in order to increase the positive impact of what we do for so many. This means we will create ongoing value for all of our stakeholders; our customers and vendors, our employees, shareholders and the communities in which we operate. Creating value goes beyond economic value by providing a challenging and rewarding career path, by fostering a sense of team, and by doing well by doing good.

This employee handbook is designed to help you better understand your role as an employee of Slade Gorton & Co. and provide you with the basic information you need to know about our values and beliefs, the “dos and don’ts,” our expectations, the benefits, the responsibilities and opportunities that are associated with your employment here.

OVER EIGHTY-SEVEN YEARS BUILT ON QUALITY, SERVICE, AND BEING

“PARTNERS IN SEAFOOD SERVICE WORLDWIDE”

Slade Gorton & Co., Inc. was founded in 1928 in Chicago, Illinois by the late Thomas Slade Gorton, Jr., whose grandfather, Slade Gorton, Sr., founded the worldwide fish business now known as the “Gorton’s of Gloucester.”* Slade Gorton, Sr. is famous for having helped to develop with Clarence Birdseye, the process of freezing fish in Gloucester, thus starting the frozen seafood industry. Slade Gorton, Jr. expanded his seafood business from Chicago and Gloucester to Boston in 1951 and since then the Company has been providing a diverse line of seafood products to processors, distributors, wholesalers, retailers and chain restaurants throughout the United States.

*There is no connection between Slade Gorton & Co., Inc. and Gorton’s of Gloucester.

COMPANY POLICIES & PROCEDURES

Our rules are based on common sense and courtesy. For the safety and well-being of yourself, your fellow employees, our customers and vendors, you must learn these rules and abide by them. The absence of a policy does not restrict Slade Gorton & Co., Inc. from taking any action it deems necessary. If any policy in this Handbook is deemed inconsistent with applicable state or federal law, the law shall prevail.

Grievance Policy

If you ever have a question about your job or a problem of any kind, you owe it to yourself and Slade Gorton & Co., Inc. to take your problem to your immediate supervisor or department manager. If there is a time when you are not satisfied with the answer you receive or that you have a grievance that needs further attention, please consult with the Vice President of Human Resources. We are never too busy to listen to any employee.

Safety

Safety is a priority at Slade Gorton & Co., Inc. and is everybody’s job. All employees are responsible for following the Company’s safety rules. All unsafe conditions and safety violations

should be reported immediately to your Manager or the Vice President of Operations. Negligence or willful actions by employees which could result in injury to themselves, other employees, or customers may lend to disciplinary action, up to and including termination. Likewise, negligence or willful actions by employees which could result in damage to customer or company property may lend to disciplinary action, up to and including termination.

Information about the Safety Committee and names of CPR trained individuals are available from the Vice President of Human Resources and are posted on Company bulletin boards. The Company will provide training in CPR and first aid to interested employees.

Training and Trial Period

The first sixty (60) calendar days of your employment will constitute a trial period. As a new employee of Slade Gorton & Co., Inc. you will receive “on-the-job” training by your

immediate superior or by a designated sponsor-employee, and your performance will be reviewed at periodic intervals. During your trial period, your work will be evaluated to determine whether your performance is meeting the Company’s standards. An employee whose performance fails to meet such standards may be terminated at any time. Successful completion of the trial period does not change an employee’s at-will status, and in no way serves as a guarantee of future employment.

Job Opportunities

Whatever your position within the Company, you are important to Slade Gorton & Co., Inc. Your desire to learn and work productively will enhance job opportunities for yourself and fellow associates and the continued growth of the Company. For position openings, check the bulletin board in your area or contact the Vice President of Human Resources or your Manager. Employees must have six months of continuous service with the Company before posting for a new position. Employees must also meet the required qualifications for the position. Please speak to your supervisor and fill out an internal application for transfer or promotion and give it to the Vice President of Human Resources or to your Manager. The Company has the right to decide whether or not to post an open position, and not all open positions are posted.

Attendance

It is the policy of Slade Gorton & Co., Inc. to expect regular, on time attendance of all employees as part of their responsibility in the employment relationship. Regular attendance is necessary to ensure service to our customers, safety of our fellow employees and the orderly and efficient operation of the Company. We depend on you and would like you to maintain a perfect attendance record if at all possible. We are all expected to arrive at work on time on each of our scheduled workdays. When you must be absent, you must notify your manager before your normal starting time and explain the reason for the absence. Absent employees must continue to notify their managers each day until they return to work, unless an alternate call-in schedule has been agreed upon. Failure to notify management as required may result in disciplinary action, up to and including termination of employment. If an employee is absent without notice for three (3) consecutive days, the Company will consider the employee to have voluntarily resigned from his or her position.

If an illness or a personal matter requires that you must leave work during a workday, you must inform your manager of this situation and obtain your manager’s prior approval before leaving work.

The job of every employee is important to the Company’s daily operations, and punctuality is essential. If an employee will be late to work, the employee must contact his or her supervisor before the start of the scheduled shift. Excessive tardiness is grounds for discipline, up to and including termination.

Work Schedule

Being a multi-faceted company, the working hours may vary from department to department and location to location, based on operational needs. Therefore, your specific department manager will establish your working schedule. Employees are expected to report to work regardless of weather conditions except in the case of extreme emergency conditions.

Meal Periods

Employees working shifts of six hours or more may take an unpaid lunch break. Lunch breaks will be at least thirty (30) minutes long, but they may vary from thirty (30) minutes to an hour depending on the department in which you work. Any deviations from your department’s practice in the amount of time taken for lunch breaks must be approved in advance by the department manager. Any employees working outside of Massachusetts or Florida will receive meal and rest breaks in accordance with the applicable state laws.

Rest Periods

All employees will be allowed one paid fifteen (15) minute rest period each day. The Company provides free coffee to employees for enjoyment during rest periods, and it also maintains vending machines for snacks and soda. The price of vending machine products is subsidized by the Company.

Pay Day and Wage Statements

Hourly employees are paid weekly. Normally, payday will be on either Thursday or Friday (depending on location) for the work week ending the previous Saturday. Salaried employees are paid biweekly for the previous week and the week in which the paycheck is issued.

Payment is by direct deposit or check at the employee’s election. On pay days, employees electing direct deposit will receive a wage statement showing the date, total hours worked, gross earnings, tax withholdings, and any deductions requested by the employee.

Minimum Age of Employment

Both full-time and part-time persons employed by Slade Gorton & Co., Inc, must be at least seventeen (17) years of age for general office work and eighteen (18) years of age to work in the warehouse department.

Part-Time Employee Hours

The normal work week for a regular part-time employee will consist of up to twenty five (25)

hours per week.

Overtime Pay

Overtime may be required depending on the needs of the Company. Overtime is defined as hours worked by non-exempt employees in excess of forty hours in one workweek. Non-exempt employees, both full-time and part-time, receive overtime compensation at the rate of one and one half (1½ ) times the employee’s regular straight time hourly rate.. When overtime is calculated, holiday hours will be considered time worked unless the holiday is observed on a non-working day. Swap days also count towards the calculation of overtime pay. Sick Days, Vacation Days, Wellness Days, Personal Days, and other time off will not be counted as time worked when overtime is calculated.

All overtime must be approved by the department manager before the work is performed. If an employee’s duties require the employee to work additional, unscheduled hours and the employee is unable to secure prior approval to work overtime, the employee should accurately record all working time and advise his or her manager of the additional hours worked as soon as possible.

Non-exempt California employees will receive overtime pay at 1.5 times the regular rate for hours worked in excess of eight (8) in a workday or forty (40) in a workweek. Non-exempt California employees will also receive premium pay at twice the regular rate for hours worked in excess of twelve (12) in a single workday or for any hours worked in excess of eight (8) on the seventh (7th) consecutive day worked in the workweek.

Final Pay and Termination Adjustments

When employment ends, the employee will receive the balance of his or her unpaid wages, if any, and pay for any accrued but unused vacation, personal, and/or swap days. Employees who resign from the Company will receive their final pay on the next regular payday. Employees discharged by the Company will receive their final pay on their last day of work.

Notice of Termination

The Company asks that employees provide written notice of their intent to resign at least two weeks in advance of the effective date of their resignation. In certain cases, the Company may request that the employee leave immediately, rather than work through a notice period. An employee who fails to give at least two (2) weeks’ notice will not be eligible for rehire. An employee must return all company property at the time of termination including, but not limited to, credit card, keys, cell phones and IT equipment.

Proprietary Information

The seafood industry is very competitive, and proprietary information is vital to the achievement of our business goals and objectives. You may not forward or remove Company records and documents from our place of business without permission from your department manager. This policy applies to all of the Company’s business information, including but not limited to recipes and/or formulas. In addition, it is against Company policy to discuss Company business matters outside your immediate business location. You may only pass Company information on to our customers or vendors to the extent that it is strictly necessary in order to conduct business. Unauthorized attempts to access information in the Company’s computer system is a violation of this policy and may result in disciplinary action, up to and including termination.

Any requests for information directed to the Company the news media must be referred to the CEO of the Company. No employee may comment to the press on behalf of the Company other than Kim Gorton or a person designated by Kim Gorton.

Violence, Weapons, and Verbal Threats in the Workplace

Slade Gorton & Co., Inc. is committed to providing a safe work environment for all employees. In support of this policy, Slade Gorton & Co., Inc. expressly prohibits any form of violence in the workplace or on its premises by employees, vendors, visitors or customers, including, but not limited to, unauthorized possession or use of firearms or other weapons, verbal threats, intimidation, physical abuse or similar such behavior (hereinafter referred to as “violence in the workplace”).

If you believe that you have witnessed violence in the workplace, or if you have been the victim of workplace violence, , you must immediately report the matter to the Vice President of Human Resources, your Manager or the CEO. The Company will undertake a prompt investigation. Any individual found to have committed any act of violence in the workplace will be subject to discipline, up to and including termination. Slade Gorton & Co., Inc. expressly prohibits retaliation against any employee who reports violence in the workplace.

If you witness violence in the workplace from a vendor, visitor, or customer, you should safely excuse yourself from the situation, making no response, and immediately report it to the Vice President of Human Resources or your Manager. will either confront the wrongdoer directly or call the police for assistance. If you cannot locate the Vice President of Human Resources or your Manager, report the incident to the CEO.