9410 Topanga Canyon Blvd., Suite 105

Chatsworth, CA 91311-5758

P 818.717.0200F 818.717.0257

EMPLOYEE HANDBOOK

WELCOME TO THE SIMPSON CO., INC.

Starting a new job is exciting, but at times can be overwhelming. This Employee Handbook has been developed to help you become acquainted with our company and answer many of your initial questions. It provides answers to most of the questions you may have about the company benefit programs, as well as the company policies and procedures we abide by, our responsibilities to you and your responsibilities to The Simpson Co., Inc. (“TSCo”)

From time to time, the information included in our Employee Handbook may change. Every effort will be made to keep you informed through suitable lines of communication, including postings on the company bulletin boards and/or notices sent directly to you in-house via electronic mail.

As an employee of TSCo, the importance of your contribution cannot be overstated. Our goal is to provide the finest-quality services to customers and to do this more efficiently and economically than our competitors. By satisfying our customer’s needs, they will continue to do business with us and will recommend us to others.

You are an important part of this process for your work directly influences our company's reputation.

We are glad you have joined us, and we hope you will find your work to be both challenging and rewarding.

Sincerely,

F. DEAN SIMPSON

President

RECEIPT OF EMPLOYEE HANDBOOKAND EMPLOYMENT-AT-WILL STATEMENT

This is to acknowledge that I have received a copy of The Simpson Co., Inc. (“TSCo”) Employee Handbook and understand that it sets forth the terms and conditions of my employment as well as the duties, responsibilities and obligations of my employment with the company. I understand and agree that it is my responsibility to read the Employee Handbook and to abide by the rules, policies and standards set forth in the Employee Handbook.

Please read the following statements and sign below to indicate your receipt and acknowledgement of TSCo Employee Handbook:

I also acknowledge that my employment with TSCo is not for a specified period of time and can be terminated at any time for any reason, with or without cause or notice, by me or by the company.

I acknowledge that no oral or written statements or representations regarding my employment can alter the foregoing. I also acknowledge that no manager or employee has the authority to enter into an employment agreement - express or implied - providing for employment other than at-will.

I also acknowledge that, except for the policy of at-will employment, the company reserves the right to revise, delete and add to the provisions of this Employee Handbook. All such revisions, deletions or additions must be in writing and must be signed by the president of the company. No oral statements or representations can change the provisions of this Employee Handbook.

I also acknowledge that, except for the policy of at-will employment, terms and conditions of employment with the company may be modified at the sole discretion of the company, with or without cause or notice, at any time. No implied contract concerning any employment-related decision, term of employment or condition of employment can be established by any other statement, conduct, policy or practice.

I understand that the foregoing agreement concerning my at-will employment status and the company's right to determine and modify the terms and conditions of employment is the sole and entire agreement between me and TSCo concerning the duration of my employment, the circumstances under which my employment may be terminated and the circumstances under which the terms and conditions of my employment may change. I further understand that this agreement supersedes all prior agreements, understandings and representations concerning my employment with the company.

I understand that my signature below indicates that I have read and understand the above statements and have received a copy of the TSCo Employee Handbook.

I acknowledge that the company reserves the right to monitor any type of company telecommunications, video surveillance, computer, or Internet activity and employees should not expect privacy while using work equipment.

If I have questions regarding the content or interpretation of this Employee Handbook, I will bring them to the attention of the Controller or President.

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Employee’s Printed Name Position

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Employee’s SignatureDate

The signed original copy of this agreement should be given to the Controller – it will be filed in your personnel file.

TABLE OF CONTENTS

THE WAY WE WORK

A WORD ABOUT THIS HANDBOOK

AFFIRMATIVE ACTION & EQUAL EMPLOYMENT

AMERICANS WITH DISABILITIES ACT

OUR EMPLOYEE RELATIONS PHILOSOPHY

Non-Harassment

Sexual Harassment

Third-Party Anti-Harassment Policy

Responsibility

Reporting

PERSONNEL ADMINISTRATION

Your Personnel File

Access to Personnel Files

EMPLOYMENT CLASSIFICATIONS

Introductory Period

Full-Time Employees

Part-Time Salaried Employees

Part-Time Hourly Employees

Temporary Employees

“Non-Exempt” and “Exempt” Employees

NEW EMPLOYEE ORIENTATION

Absence or Lateness

Anniversary Date

Attendance

At Will Employment

Business Hours/Work Week

Confidential Information

Credit Investigation

Customer Relations

Disciplinary Actions

Dismissal

Driver's License & Driving Record

Equal Employment Opportunity

Former Employees

Immigration Reform and Control Act (I-9)

Lunch Breaks

Lunch Room Facility

Open Door Policy

Outside Employment

Proof of U.S. Citizenship and/or Right to Work

Reinstatement of Benefits (Bridging)

Rest Breaks

Standards of Conduct

Suggestions and Ideas

COMPENSATION & PERFORMANCE

WAGE & SALARY POLICIES

Computing Pay

Deductions from Paycheck (Mandatory)

Direct Deposit

Error in Pay

Job Descriptions

Overtime Pay

Pay Cycle (24 pay periods per year)

Performance Reviews

Wage Assignments (Garnishments)

YOUR BENEFITS

Employee Benefit Program

Paid Leaves of Absence

Holiday Bonus

Holidays

Recognized Holidays

Holiday - Policies

Paid Time Off

Paid Time Off – Policies

Paid Sick Leave – Temporary Employees

401K Safe Harbor Plan

LEAVES

Personal Leave of Absence

Funeral (Bereavement) Leave

Rehabilitation Leave

Voting Leave

Jury Duty

School Visitation

Domestic Violence Leave

Pregnancy Leaves Of Absence

Occupational Injury or Illness

Employee Status & Benefits during Leave of Absence

Returning from a Leave Of Absence

Accepting Other Employment/Going into Business While On Leave

GROUP INSURANCE COVERAGE

Group Health and Dental Insurance

Eligibility Requirements for Group Insurance Benefit

Termination of Insurance

Cal-Cobra

Section 125 Plan

State Disability Insurance

Occupational Injury/Illness

Who Is Covered?

What Is Covered?

When Am I Covered?

What Are The Benefits?

How Do I Get The Benefits?

How Much Are The Cash Payments?

Unemployment Insurance

ON THE JOB

Care of Equipment

Cellular Telephones

Changes in Personal Data

Company Meetings

Computer Software (Unauthorized Copying)

Conflict of Interest/Code of Ethics

Corporate Vehicles

Customer and Public Relations

Dress Code / Personal Appearance

Electronic Mail Monitoring

Entry After-Hours

Exit Interviews

Expense Reimbursement

First Aid

Housekeeping

If You Must Leave Us

In An Emergency

Internet Usage

On Call

Outside Activities

Parking Lot

Personal Hygiene

Personal Phone Calls & Mail

Personal Property

Personal Use of Company Property

Protecting Company Information

Reference Checks

Return of Company Property

Safety Rules

Safety Rules When Operating Machines & Equipment

Security

Smoking

Solicitation and Distribution

Suggestions and Ideas

Theft

Violations of Policies

Voice Mail Monitoring

SAFETY IN THE WORKPLACE

Each Employee's Responsibility

Workplace Violence

Substance Abuse

NON-DISCLOSURE AGREEMENT

THE WAY WE WORK

A WORD ABOUT THIS HANDBOOK

This Employee Handbook contains information about the employment policies and practices of the company. We expect each employee to read this Employee Handbook carefully, as it is a valuable reference for understanding your job and the company. The policies outlined in this Employee Handbook should be regarded as management guidelines only, which in a developing business will require changes from time to time. The company retains the right to make decisions involving employment as needed in order to conduct its work in a manner that is beneficial to the employees and the company. This Employee Handbook supersedes and replaces any and all prior Employee Handbooks and inconsistent verbal or written policy statements. Except for the policy of at-will employment, which can only be changed by the president of the company in writing, the company reserves the right to revise, delete and add to the provisions of this Employee Handbook. All such revisions, deletions or additions must be in writing and must be signed by the president of the company. No oral statements, representations, or promise by a supervisor or manager may be interpreted as a change in policy nor will it constitute an agreement with an employee. No one other than the President of TSCo may alter or modify provisions of this Employee Handbook.

The provisions of this Employee Handbook are not intended to create contractual obligations with respect to any matters it covers. Nor is this Employee Handbook intended to create a contract guaranteeing that you will be employed for any specific time period.

OUR COMPANY IS AN AT-WILL EMPLOYER. THIS MEANS THAT REGARDLESS OF ANY PROVISION IN THIS EMPLOYEE HANDBOOK, EITHER YOU OR THE COMPANY MAY TERMINATE THE EMPLOYMENT RELATIONSHIP AT ANY TIME, FOR ANY REASON, WITH OR WITHOUT CAUSE OR NOTICE. NOTHING IN THIS EMPLOYEE HANDBOOK OR IN ANY DOCUMENT OR STATEMENT, WRITTEN OR ORAL, SHALL LIMIT THE RIGHT TO TERMINATE EMPLOYMENT-AT-WILL. NO OFFICER, EMPLOYEE OR REPRESENTATIVE OF THE COMPANY IS AUTHORIZED TO ENTER INTO AN AGREEMENT - EXPRESS OR IMPLIED – WITH ANY EMPLOYEE FOR EMPLOYMENT OTHER THAN AT-WILL, UNLESS THOSE AGREEMENTS ARE IN A WRITTEN CONTRACT SIGNED BY THE PRESIDENT OF THE COMPANY. THE TERMS AND CONDITIONS OF EMPLOYMENT MAY BE ALTERED AT ANY TIME WITHIN THE SOLE DISCRETION OF MANAGEMENT.

This Employee Handbook refers to current benefit plans maintained by the company. Refer to the actual plan documents and summary plan descriptions if you have specific questions regarding the benefit plans. Those documents are controlling.

AFFIRMATIVE ACTION EQUAL EMPLOYMENT

TSCo has been and will continue to be an equal opportunity employer. To assure full implementation of this equal employment policy, we will take steps to assure that:

a.Persons are recruited, hired, assigned and promoted without regard to race, religion, color, national origin, citizenship, sex, veteran status, age, disability or any other protected personal characteristics.

b.Similarly, all other personnel actions, such as compensation, benefits, transfers, layoffs and recall from layoffs, access to training, education, tuition assistance and social recreation programs are administered without regard to race, religion, color, veteran status, national origin, citizenship, sex, age, disability or any other protected personal characteristics.

You may discuss equal employment opportunity related questions with the Controller or any other member of management.

AMERICANS WITH DISABILITIES ACT

Our company is committed to providing equal employment opportunities to otherwise qualified individuals with disabilities, which may include providing reasonable accommodation where appropriate. In general, it is your responsibility to notify the Controller of the need for an accommodation. Upon doing so, the Controller may ask you for your input or the type of accommodation you believe may be necessary or the functional limitations caused by your disability. Also, when appropriate, we may need your permission to obtain additional information from your physician or other medical or rehabilitation professionals.

OUREMPLOYEE RELATIONS PHILOSOPHY

We are committed to providing the best possible climate for maximum development and goal achievement for all employees. Our practice is to treat each employee as an individual. We seek to develop a spirit of teamwork; individuals working together to attain a common goal.

In order to maintain an atmosphere where these goals can be accomplished, we provide a comfortable and progressive workplace. Most importantly, we have a workplace where communication is open and problems can be discussed and resolved in a mutually respectful atmosphere. We take into account individual circumstances and the individual employee.

We firmly believe that with direct communication, we can continue to resolve any difficulties that may arise and develop a mutually beneficial relationship.

Non-Harassment

We prohibit harassment of one employee by another employee, supervisor or third party for any reason including, but not limited to: veteran status, race, color, religion, sex, national origin, age, physical or mental disability, or any other protected characteristic. Harassment of third parties by our employees is also prohibited.

In addition to the above, race; religious creed; color; national origin; ancestry; physical disability; mental disability; medical condition, including genetic characteristics; marital status; sex; pregnancy, childbirth or related medical conditions; sexual orientation and age are protected classes in California.

The purpose of this policy is not to regulate the personal morality of employees. It is to assure that in the workplace, no employee harasses another for any reason.

While it is not easy to define precisely what harassment is, it includes: slurs, epithets, threats, derogatory comments or visual depictions, unwelcome jokes and teasing.

Any employee who feels that he or she is a victim of such harassment should immediately report the matter to the Controller or any other member of management. The company will investigate all such reports as confidentially as possible. Adverse action will not be taken against an employee because he or she, in good faith, reports or participates in the investigation of a violation of this policy. Violations of this policy are not permitted and may result in disciplinary action, up to and including discharge.

Sexual Harassment

Sexual harassment of one employee by another employee, supervisor or third party is against company policy and is unlawful under state and federal law.

We firmly prohibit sexual harassment of any employee by another employee, supervisor or third party. Harassment of third parties by our employees is also prohibited. The purpose of this policy is not to regulate the morality of employees. It is to assure that in the workplace, no employee is subject to sexual harassment. While it is not easy to define precisely what sexual harassment is, it includes: unwelcome sexual advances, requests for sexual favors and/or verbal or physical conduct of a sexual nature including, but not limited to: sexually-related drawings, pictures, jokes, teasing, uninvited touching or other sexually-related comments.

Sexual harassment of an employee will not be tolerated. Violations of this policy may result in disciplinary action, up to and including discharge. There will be no adverse action taken against employees who, in good faith, report violations of this policy or participate in the investigation of such violations.

Third-Party Anti-Harassment Policy

The Company is committed to providing a work environment that encourages mutual respect and is free of unlawful harassment. The Company strongly condemns any form of unlawful employment-related harassment. Company policy prohibits employees from, among other things, engaging in unlawful harassment of third parties, including customers, clients, vendors, contractors and persons working or visiting on the company’s premises.

Prohibited unlawful harassment includes, but is not limited to, the following: Any harassment or the use by anyone in the Company’s employ of any derogatory epithet (whether verbal, written or gestural) based on race, religious creed, color, age, sex, gender, gender identity, physical or mental disability, national origin, ancestry, medical condition, marital status, sexual orientation, or any other consideration made unlawful by federal, state or local laws; or sexual harassment, including (but not limited to) unwanted sexual advances, visual, verbal or physical conduct of a sexual nature, and gender-based sexually offensive conduct against a person of the same or opposite sex as the harasser when (1) submission to the conduct is made explicitly or implicitly a term or condition of doing business with the Company, (2) submission to or rejection of the conduct by an individual is used for business decisions affecting an individual, or (3) such conduct has the purpose or effect of unreasonably interfering with the third party’s work performance or that of creating an intimidating, hostile or offensive environment.

An employee who believes that this policy is being violated, with respect to third parties as referenced above, should report that belief to his or her supervisor or management immediately, either in writing or personally.

Upon notice of an employee's concern about the possible harassment of third parties, the Company will respond appropriately, will not retaliate against the employee for filing a harassment complaint, and will not knowingly permit retaliation by management or the employee’s coworkers.

Any employee violating this policy will be subject to disciplinary action up to and including termination of employment.

Responsibility

As an employee of TSCo, you are responsible for keeping our work environment free of harassment. Any employee, who becomes aware of an incident of harassment, whether by witnessing the incident or being told of it, must report it to the President or the Controller with whom you feel comfortable. When TSCo becomes aware that harassment might exist, it is obligated by law to take prompt and appropriate action, whether or not the victim wants the company to do so.

Reporting

If you feel that you have experienced harassment, report the incident immediately to the President or the Controller with whom you feel comfortable. Appropriate investigation and disciplinary action will be taken. All reports will be promptly investigated with due regard for the privacy of everyone involved.

TSCo accepts no liability for harassment of one employee by another employee. The individual who makes unwelcome advances, threatens or in any way harasses another employee is personally liable for such actions and their consequences. TSCo will not provide legal, financial or any other assistance to an individual accused of harassment if a legal complaint is filed.

Any employee who feels that he or she is a victim of sexual harassment should immediately report such actions in accordance with the following procedure. All complaints will be promptly and thoroughly investigated.