Employee Handbook - Online

Table of Contents

SECTION I: Introductory Policies

• Contract Disclaimer/At-Will Employment Relationship

SECTION II: Working at Indica Digital

• Employee Categories
• Exempt and Non-Exempt Classifications and Time Recording
• Working Hours
• Breaks
• Nurisng Mother Breaks
• Paydays and Pay Periods
• Review Your Pay Stub
• Personnel File

Section III: Career Development at Indica Digital

• Internal Transfers/Promotions
• Rehire Information

SECTION IV: Indica Digital Benefits Program

• Holidays
• Paid Time Off
• Definition & Eligibility
• Availability and Transition from Previous PTO Policy
• Procedure for Requesting PTO
• Indica Digital Gives Back Hours (RGB Hours)
• Medical, Dental, and Vision Benefits
• Health Insurance
• Definition of Dependent
• Retirement Savings Plan
• Employee Assistance Program
• Short-Term Disability
• Long-Term Disability
• Voluntary Benefits
• Worker’s Compensation

Section V: Leaves of Absence

• Family and Medical Leave (“FMLA Leave”)
• Requests for Leave
• Restoration to Position
• Return to Work
• Failure to Return From Leave
• Miscellaneous
• Paid Parental Leave Policy
• Eligibility
• General Provisions
• Employee Status and Benefits
• Notice Requirements
• Bereavement Leave
• Jury Duty
• Witness Duty
• Military Leave
• Personal Leave of Absence
• Other Leaves

Section VI: Indica Digital Business Practices and Policies

• Equal Employment Opportunity
• The Americans with Disabilities Amendments Act (ADAAA)
  
• Sexual and Anti-Harassment or Discrimination Policy
• Anti-Violence Policy
• Prohibited Conduct
  
• Procedures for Reporting a Threat
• Conduct Guidelines & Discipline
  
• Expense Reimbursement
• Attendance
• Personal Relationships
• Inclement Weather Policy
• Dress Code
• Personal Property
• Visitors in the Workplace
• Drug and Alcohol Abuse
• Smoke-Free Workplace Policy
• Policies Applicable to Social Media
• Policies Applicable to Business Use of Social Media
• Policies Applicable to Personal Use of Social Media
• Confidential Information
• Outside Employment
• Business Ethics/Conflict of Interest
• Solicitations and Distributions
• Return of Company Property

Section VII: Information Technology Acceptable Use and Personnel Security Policy

• Acceptable Use Policy
• Physical Asset Protection
• Unauthorized Software or Modification of Electronic Resources
• Secure Storage of Physical Assets
• Physical Asset Return Upon Termination
• Lost or Stolen Physical Assets
• Personal Data Storage
• Limited Personal Use
• Trademark and Copyright Adherence
• Use of Personal Electronic Resources
• Personal Electronic Resources for Visitors
• Transmission of Company Information
• Company Ownership Banner
• Return of Company Data
• User IDs and Passwords
• E-mail Messaging and Social Media
• Viruses and Tampering
• No Unauthorized use of Cloud Services
• No Expectation of Privacy
• Company’s Right to Monitor Messages and Systems Use
• Adherence to Security Policies
• Termination
• Disciplinary Action Policy
• Third Party Compliance with Security Policies
• Receipt of Employee Handbook

SECTION I: Introductory Policies

Introduction

Whether you recently joined our team or have been at Indica Digital, LLC. (“Indica Digital” or the “Company”) for a while, we are confident that you will find our Company a dynamic and rewarding place in which to work, and we look forward to a productive and successful association. We consider the employees of Indica Digital to be one of its most valuable resources. This handbook has been written to serve as a guide for our relationship to the extent allowed by applicable law.

There are several things that are important to keep in mind about this handbook. First, except as otherwise stated with regard to the Company’s “at-will” employment policy, this handbook contains only general information and guidelines. It is not comprehensive nor does it address all the possible applications of, or exceptions to, the general policies and procedures described. Benefits, such as those provided by the group health plan, are subject to the terms of the actual policy or plan document. Please refer to the plan summaries for actual terms; the plan document is controlling. For that reason, if you have any questions concerning eligibility for a particular benefit, or the applicability of a policy or practice to you, you should address your specific questions to HR.

Indica Digital policies unique to the state of Illinois in conjunction with this handbook. To the extent that any policy or statement contained in this handbook is contrary to or in conflict with state or local law, Indica Digital will follow applicable state or local laws.

This handbook does not prohibit protected conduct or communications relating to your wages, hours or working conditions, or any other conduct protected by Section 7 of the National Labor Relations Act.

Furthermore, nothing in this handbook prohibits an employee from reporting concerns, making lawful disclosures, or communicating with any governmental authority about conduct the employee believes violates any laws or regulations, including reporting any concerns via the Company’s hotline, which is addressed in the Company’s Code of Conduct.

Once again, welcome to Indica Digital. We are pleased you are here!

Contract Disclaimer/At-Will Employment Relationship

This handbook has been prepared as a general reference guide to help familiarize employees with Indica Digital’s basic policies, and procedures, as well as the many employee benefits which it provides. This handbook applies to all full-time, part-time, and temporary employees. It specifically supersedes and replaces all previous employee handbooks, manuals, and policy statements, whether oral or written, issued by Indica Digital.

Please note that this handbook is not a contract or an offer to form a contract. It is not intended to create any binding contractual commitments between the Company and any employee.

Furthermore, it does not provide any guarantee or assurance of continued employment with the Company for any particular term.

It is important for you to understand that notwithstanding anything contained in this handbook or in any other current or future policy statement or practice, the Company and its employees retain the mutual right to terminate the employment relationship “at will,” with or without warning, notice or cause. No representative of the Company, other than the CEO, has the authority to make any binding representations, whether oral or written, contrary to the foregoing or purporting to guarantee any particular benefits, procedures, terms or conditions of employment. Even as to the CEO, such representations will be binding on the Company only if they are set forth specifically in a written employment agreement signed by the CEO, CTO, or CFO.

The Company expressly reserves all of its traditional management rights, including, without limitation, the right to unilaterally revise, interpret or discontinue any of the policies, procedures, rules or benefits set forth in this handbook at any time. In no case, however, may any such action alter the prevailing “at will” employment relationship or guarantee any particular benefits, procedures, terms or conditions of employment.

The Company encourages employees, as well as management, to talk openly to each other about work and working relationships so that effective, continuous employee/management communications exist. Employees who have questions about the contents of this handbook, or about any aspect of their employment, are encouraged to Indica Digital them with their supervisor, their manager or CEO. They will gladly provide you with the information you need or direct you to someone who can do so. We take pride in keeping an open line of communication with all employees.

SECTION II: Working at Indica Digital

Employee Categories

All employees are classified as follows:

Regular, Full-Time: Regular, full-time employees are those employees who normally are scheduled to work at least 30 hours per workweek and whose employment has no specified end date. Regular full-time employees are entitled to participate in all Company benefits subject to the terms and conditions of those specific benefits.

Regular, Part-Time: Regular, part-time employees are those employees who normally are scheduled to work fewer than 30 hours per workweek and whose employment has no specified end date. Regular part-time employees are entitled to participate in only certain benefits offered by the Company, as expressly described herein.

Temporary / Interns: Temporary employees are those employees who are employed only for a specified period of time or a specific project. Temporary employees may work a full or part- time schedule. Temporary employees are eligible only for those benefits required by law to be provided.

In addition, all employees are classified as exempt or non-exempt for purposes of overtime pay eligibility.

Exempt and Non-Exempt Classifications and Time Recording In order to ensure that all employees are properly paid, including for overtime where appropriate, Indica Digital has established the following timekeeping and pay policies. Violations of these policies will result in disciplinary action, up to and including termination.

“Exempt” or “non-exempt” status of employment refers to requirements of a law known as the Fair Labor Standards Act (“FLSA”). Employees are informed of their “exempt” or “non- exempt” status in writing when they are offered a job assignment or change job assignments.

Non-exempt employees: Non-exempt employees must maintain a record of the total hours worked each day. These hours must be accurately recorded in accordance with Indica Digital’s timekeeping procedures and policies. Each employee must review their information each week to verify that the reported hours worked are complete and accurate. Time reported must accurately reflect all regular and overtime hours worked, any absences, late arrivals, early departures and meal breaks. Before each pay date, managers will verify and approve each non- exempt employee’s time. Non-exempt employees must provide accurate time records. A non- exempt employee must notify his/her manager immediately if the employee determines that recorded time is not accurate. Paychecks should be reviewed to ensure the non-exempt employee was paid properly for all regular and overtime hours worked. Any suspected errors must be reported immediately to the Payroll Department.

There occasionally may be times when non-exempt employees will be required to work additional hours, including overtime hours. Failure to work additional hours as required by the Company will be deemed an unexcused absence. Compensatory time off cannot be taken in lieu of overtime pay. With the approval of the non-exempt employee’s manager, a non-exempt employee may be permitted to take time off only in the same workweek in which such employee worked additional hours. Non-exempt employees may not make up missed hours in a subsequent work week.

A non-exempt employee is not permitted to work any hours not scheduled (including overtime hours) unless authorized by the non-exempt employee’s manager. Non-exempt employees may not start work prior to the start of their scheduled workday, stop work after the end of their scheduled workday, work during a meal break, or perform any other extra or overtime work unless authorized to do so by their manager and the time is recorded accurately. Non-exempt employees are expressly prohibited from performing any “off the clock” work. Any non-exempt employee who works unauthorized time, fails to report all hours worked, or inaccurately reports hours worked will be subject to disciplinary action, up to and including termination of employment.

Technological advances have opened new doors for performing work while away from the workplace. Non-exempt employees are prohibited from working from home, telecommuting, or otherwise performing work while away from their regular workplace and/or outside of their scheduled working hours, unless authorized in writing by their manager. This prohibition includes the use of smart phones and other mobile devices, laptops, tablets, and home computers – whether owned by the Company or by the employee – away from a non-exempt employee’s workplace and/or outside of scheduled working hours.

It is a violation of the Company’s policy for any employee to falsify a timecard, or to alter another non-exempt employee’s timecard. It is also a violation of Company policy for any employee or manager to instruct another employee to incorrectly or falsely report hours worked or alter another employee’s timecard to under or over report hours worked.

Employees should report immediately to their manager (or if there isn’t a manager the most then senior member of the HR Department) if any manager or employee instructs them to (1) incorrectly or falsely under or over report hours worked, or (2) alter another employee’s time records to inaccurately or falsely report that employee’s hours worked.

Exempt employees:

• Under federal and state laws, your salary is subject to certain deductions. For example, absent contrary state law requirements, your salary can be reduced for the following reasons:
• Full day absences for personal reasons.
• Full day absences for sickness or disability (PTO may be used to maintain pay for the day).
• Family and Medical Leave absences (either full or partial day absences).
• To offset amounts received as payment for military pay.
• The first or last week of employment in the event you work less than a full week.
• Any full workweek in which you do not perform any work.
• Your salary may also be reduced for certain other types of deductions such as your portion of health, dental, or life insurance premiums; state, federal or local taxes; social security; or voluntary contributions to a 401(k) plan. Company policy provides compensation of exempt employees should not be reduced for any partial-day absence (other than intermittent or reduced schedule FMLA leave); any partial-week absence occasioned by the Company or its operating requirements, including holidays and partial-week shutdowns; or because of variations in the quality or quantity of work performed.

Improper deductions from the salary of exempt employees are a serious violation of Indica Digital’s policy. The Company encourages any exempt employee who believes his/her salary has been improperly reduced to report the problem immediately to his/her immediate supervisor or the CPO. The Company will review the deduction to determine if it was proper. The review process may require the employee to provide information or present documents to the Company. The employee will be notified of the results of the Company’s review. If the Company determines that the deduction was improper, the employee will be reimbursed for the improper deduction as soon as practicable. Employees are assured that the Company is committed to comply, and expects all supervisors and managers to comply with this policy and to carefully avoid making improper deductions from the salaries of exempt employees. Employees also are assured that no retaliatory action will be taken for reporting improper deductions. Employees who suspect retaliation should report their concerns immediately to his or her immediate supervisor, to their manager or CEO. Please Note: Company’s attendance and disciplinary action policies are applicable to exempt employees even though an absence may not be one for which a deduction from salary may be taken.

Working Hours Indica Digital keeps regular business hours, which may fluctuate based on the business needs and your manager’s discretion. Extra work hours may be required to meet business needs. Non-exempt employees may not work overtime hours without authorization from their supervisor or manager. Compensation of overtime hours worked will be made in accordance with the Fair Labor Standards Act and applicable state law. Managers will inform employees of their scheduled hours and whether additional hours are required.

Breaks Non-exempt employees will be provided a thirty-minute unpaid meal break and two fifteen- minute rest breaks unless otherwise specified by applicable state law. Non-exempt employees should be completely relieved of all work duties during their meal break and should not perform any work duties while they are clocked out for their meal break. Nursing Mother Breaks Employees who are nursing will be provided with reasonable nursing breaks to express breast milk as frequently as needed. When applicable, nursing mothers should use the meal and/or rest breaks already provided by the Company. If those breaks are insufficient, the Company will provide additional paid breaks. Indica Digital will provide an appropriate location for this to occur. Employees will not be retaliated against for exercising their rights under this policy.

Paydays and Pay Periods The Company’s workweek runs from Monday at 12:00 a.m. to Sunday at 11:59 p.m. Paychecks are issued every other Friday (26 pay periods per year), covering a bi-weekly pay period paid one week in arrears. If a payday falls on a holiday or weekend, employees will be paid on the preceding business day. Please see the Payroll Schedule in Waves Apps for more details.

Review Your Pay Stub Indica Digital makes every effort to ensure our employees are paid correctly. Occasionally, however, inadvertent mistakes can happen. When mistakes do happen and are called to our attention, we will promptly make any corrections necessary. Please review your pay stub when you receive it to make sure it is correct. If you believe a mistake has occurred or if you have any questions, please use the reporting procedure outlined below.

To report concerns or obtain more information: If you have a question about deductions from your pay, please immediately contact the Payroll Department. If you believe you have been subject to improper deduction(s) or your pay does not accurately reflect your hours worked, you should immediately report the matter to your manager, to the Payroll Department or to any member of management with whom you feel comfortable. Every report will be fully investigated and corrective action will be taken where appropriate. In addition, Indica Digital will not allow any form of retaliation against individuals who report alleged violations of this policy or who cooperate in Indica Digital’s investigation of such reports. Retaliation is unacceptable, and any form of retaliation in violation of this policy will result in disciplinary action, up to and including termination of employment.

Personnel File Employees will be granted access to personnel files to the extent required and in accordance with applicable state law.

Please keep your personnel file up to date by informing us of any changes to your personal data including address and emergency contact information. Unreported changes of home and mailing address, marital status, birth or adoption of children, etc. may affect your tax withholding and benefit eligibility.

Employees should consult their applicable State Supplement for additional information regarding overtime, meal and rest breaks, and other terms and conditions of employment, as applicable.

Section III: Career Development at Indica Digital

Overview Your career is important to Indica Digital, and we value your on-going professional development. Everyone has different goals and we recognize the need for individual career paths tailored to your needs. This section is dedicated to offering you a summary of the programs Indica Digital has to offer you as you continue to develop in your career.

Internal Transfers/Promotions Employees with more than three (3) months of service in their current department may request consideration to transfer to other jobs as opportunities become available and will be considered along with other applicants. Only employees in good standing (e.g. not on an active performance plan and no disciplinary actions) may apply for internal roles. At times, Indica Digital may also initiate transfers of employees between departments and other offices to meet specific work requirements and reassignment of work requirements based on the needs of the business.

Indica Digital offers employees promotions to higher-level positions when appropriate. Management prefers to promote from within and may first consider current employees with the necessary qualifications and skills to fill openings above the entry level, unless outside recruitment is considered to be in the Company’s best interest.

Management retains the discretion to make exceptions to this policy.

Rehire Information Former employees who are classified as eligible for rehire and left Indica Digital in good standing may be considered for re-employment. An application must be submitted to HR and the manager of the respective department or team, and the applicant must meet all minimum qualifications and requirements of the position.

Managers must obtain approval from the CEO or designee prior to re-hiring a former employee. If an employee is re-hired within six (6) months of the separation, service will be considered “bridged” and all benefits will be based on the original hire date. Service time for equity is not governed by this statement, please consult the equity document for those provisions.

SECTION IV: Indica Digital Benefits Program

Overview In addition to a vibrant culture and competitive pay, it is Indica Digital’s policy to provide a comprehensive benefit platform to all eligible employees. The Indica Digital benefits program includes health insurance, a generous time off policy, retirement savings as well as other benefit offerings.

We are constantly evaluating Indica Digital’s programs and policies to better meet present and future requirements. These policies have been developed over the years and continue to evolve with changing times and needs.

The next few pages contain a brief outline of the benefits program Indica Digital provides for you and your family. Of course, this information is only a guideline. Certain benefits may vary based on state law. Please refer to the state supplement provided with this handbook, if applicable, to determine whether the benefits vary in your state.

The descriptions of the insurance benefits highlight certain aspects of Indica Digital’s insurance and other benefit plans for your general information. Further important details about these plans, including eligibility and benefits provisions, are set forth in summary plan descriptions (“SPDs”) (which may be revised from time-to-time) for each of these plans. Additionally, the official plan documents are available for your review upon request to HR. In the determination of benefits or other matters under each plan, the terms of the official plan documents shall govern over the language of any descriptions of the plans in this handbook or any other document, including the SPDs.

While Indica Digital intends to maintain these employee benefits, it reserves the right to modify, amend or terminate these benefits on a prospective basis at any time, without prior notice, and for any reason.

If you have any questions regarding your benefits, please contact HR.

Holidays The Company typically observes the following holidays:

• New Year’s Day
• Memorial Day
• Independence Day
• Labor Day
• Thanksgiving
• Day after Thanksgiving
• Christmas Eve
• Christmas
• New Year’s Eve

If a recognized holiday falls on a Saturday, the holiday will be observed on Friday. If a recognized holiday falls on a Sunday, the holiday will be observed on Monday. In the event both the holiday eve and holiday fall on a Saturday and Sunday (e.g. Christmas Eve and Christmas), please refer to the holiday schedule in via google calendar for most current holiday information.

Regular, full-time and part-time employees are eligible for holiday pay. Full-time employees receive the equivalent of 8 hours of pay. Eligible part-time and full-time employees are only qualified for holiday pay if the holiday falls on a regularly scheduled workday. In order for an eligible employee to receive holiday pay, the employee must work the employee’s last regularly scheduled day before the holiday and the first regularly scheduled day following the holiday, unless the employee’s absence has been pre-approved or is otherwise authorized by law. In addition to the regular Company holidays, regular full-time employees employed on or before June 30th qualify for two (2) additional paid floating holidays. Those joining the organization after June 30th are eligible for one (1) paid floating holiday. Floating holidays may be scheduled and taken on any regular workday, subject to advance scheduling and supervisory approval. Any floating holiday not used during the calendar year will be forfeited, unless otherwise prohibited by law. In addition, terminating employees will not receive pay for an unused floating holiday, nor can employees take a floating holiday during the resignation notice period, unless scheduled prior to the resignation notice.

Paid Time Off In order to maintain our high level of performance in everything we do, we strongly believe it is important for you to have ample time off to “recharge” and stay motivated and energized. We also want to ensure that our people take full advantage of the time off opportunities available to them. Therefore, Indica Digital has designed an unlimited Paid Time Off program that is among the best to support the “work/life balance” needs of our employees.

Definition & Eligibility Paid Time Off (PTO) is provided to regular full-time and part-time employees. Full-time employees are defined as employees working at least 30 hours per week. Eligible part-time employees are defined as those working between 20 and 30 hours per week. Temporary employees and/or Interns are not eligible for PTO. You may use this time off for any number of reasons, including, but not limited to, the following:

• Vacation
• Personal/Sick Time
• Bereavement (outside of the Bereavement Policy guidelines)
• Religious Observances
• Inclement Weather Conditions

PTO is paid at your base pay rate at the time PTO is taken. It does not include overtime or any special forms of compensation such as commission, incentives or bonuses.

Availability and Transition from Previous PTO Policy Effective January 1, 2020, Indica Digital will switch to an unlimited PTO policy for full-time and part- time employees. Under this policy, employees may take PTO time at their discretion, provided their professional duties and responsibilities are not neglected. PTO under the new policy will not accrue.

Unless used for an emergency, employees who plan to take PTO pursuant to this policy must obtain their manager’s advance approval and must provide their manager with their contact information if they need to be reached while out on PTO.

Under the new policy, employees who have an accrued PTO balance as of January 1, 2020, up to the maximum carryover balance of 40 hours under Indica Digital’s prior PTO policy, should continue to submit their PTO time to HR. During the transition to an unlimited PTO policy, Indica Digital will continue to honor vested, accrued PTO hours. Also during this transition and with respect to vested and accrued PTO hours, PTO requests that qualify for paid time off under applicable state paid sick leave laws will run concurrently until the vested balance is exhausted. If an employee’s employment separates before his or her accrued PTO balance is exhausted, he or she will be paid the cash value of the remaining balance upon termination.

Procedure for Requesting PTO

• Exempt employees may use PTO in 1⁄2 day increments. Hourly, non-exempt employees may use PTO in 1 hour increments.
• Unless used for an emergency, use of PTO is subject to manager approval, department business needs and established departmental procedures for requests for time off. Indica Digital will continue to track PTO taken by employees.
• Employees may not take more than 10 consecutive days of PTO under this policy, including for absences covered by federal, state, or local laws pertaining to employee leave.
• To the extent practicable, PTO must be scheduled in advance for time off for vacations, personal leave appointments or other reasons.
• When advance notice of PTO cannot be provided, employees must follow the Company’s established procedures for calling in an absence. Employees who do not follow the procedure may have PTO denied and be subject to disciplinary action for violating the Company’s attendance policy.
• Excessive unscheduled absences are not acceptable and will subject the employee to discipline, up to and including discharge. Indica Digital’s unlimited PTO policy should not be interpreted, and will not be enforced, as a mechanism to provide employees with cover for unapproved and unscheduled absences.
• All employees are required to record and approve used PTO time via the payroll timekeeping system.
• Unless expressly approved in writing by the Functional Leader and the assigned People

Business Partner, employees may not use PTO or Floating Holidays during a notice period.

Excepted as provided above, when time off requested by an employee qualifies for paid time off pursuant to the New York City Earned Sick Time Act, the City of Chicago Paid Sick Leave Ordinance, the California’s Healthy Workplaces Healthy Families Act, or other paid time off state or local law, the employee is required to exhaust his or her paid time off under the applicable state or local policy before receiving PTO under this policy. In accordance with applicable law, the Company may designate qualifying paid time off as being taken under the appropriate state and local paid time off law. For more information regarding paid time off under these state and local laws, please consult your applicable State Supplement and/or HR.

Employees may not take more than 10 days of PTO pursuant to this policy for any FMLA qualifying reason. Beyond this 10 day period, any additional leave under the FMLA policy will be unpaid. Employees who receive short term disability benefits and/or workers’ compensation benefits for any absence do not qualify for additional PTO under this policy.

Employees should consult their applicable State Supplement for additional information regarding other forms of paid time off.

Indica Digital Gives Back Hours (IDGB Hours) Indica Digital supports our employees in their commitment to give back to our communities. The Indica Digital Cares Community Day provides you with eight (8) paid hours to volunteer at an organization of your choice. These hours can be taken as a full day or in four (4) hour increments. Indica Digital Gives Back Hours must be prescheduled and approved by your manager to ensure business needs are covered. If feasible, you are welcome to schedule IDGB Hours with fellow team members or those with whom you work cross-functionally. We also ask that you send an email to your manager with a CC: to HR with the name of the organization you will be volunteering for so we can compile all of our Indica Digital Stories and celebrate our impact on our communities. Pictures are also welcome! Please note that IDGB Hours are provided for a specific purpose and are not part of your PTO accrual. Any unused IDGB Hours are not paid out upon your departure from Indica Digital. The hours need to be entered into the time tracking system, where it is to be approved by the employee’s manager and HR.

Medical, Dental, and Vision Benefits HR is available if you have questions about detailed and specific information regarding the below benefit plans and SPDs. Indica Digital reserves the right to alter our benefits offerings on a prospective basis at any time.

Health Insurance Regular full-time and part-time employees who are normally scheduled to work at least 30 hours per week may participate in Indica Digital’s group health insurance program including medical, dental and vision options. Under these plans, you will receive comprehensive health insurance coverage for both you and your eligible dependents, which will start according to the plan’s SPD. Enrollment in Indica Digital’s health plans must take place within 30 days of your new hire eligibility date or within 30 days of a Qualifying Life Event (e.g. marriage/divorce, birth of a child, loss of coverage, etc.).

Definition of Dependent For purposes of coverage, dependents are defined as spouse; children or stepchildren under the age of 26; children of whom an employee is the legal guardian; and a former spouse when court ordered.

Retirement Savings Plan Eligible employees may participate in Indica Digital’s 401(k) savings plan after the waiting period listed in the plan’s Summary Plan Document (SPD) upon employment or re-hire. The 401(k) Plan is designed to offer you tax advantages and flexibility in building savings for your future security whether you elect to have contributions made on a pretax or after tax basis.

This plan is a voluntary, defined contribution plan authorized under Section 401(k) of the Internal Revenue Service code. Your contributions into the plan will be made on a pretax or after tax basis through payroll deductions. You may contribute in accordance with the rules contained in the plan document, however, IRS rules limits your contributions to a certain maximum dollar amount that is announced each calendar year.

Employee Assistance Program At every stage of your life, there may be unpredictable events and questions. Indica Digital offers an Employee Assistance Program at no cost to you. This service provides access on a confidential basis to professionals equipped to help you find solutions for the everyday challenges of work and home as well as more serious issues involving emotional and physical well-being.

Depending on your needs, help is easy to access via telephone consultations, face-to-face meetings and educational materials. Program and contact information is available.

Short-Term Disability Regular, full-time employees who are unable to work for at least seven (7) consecutive calendar days because of a non-work-related illness or injury may be entitled to short-term disability benefits. In the event of an accident, short-term disability is available after one (1) business day. Short-term disability benefits are an income protection benefit, not a leave of absence. Employees unable to work because of an illness or injury must apply for an appropriate leave of absence for which they may be eligible. Additional information may be found in the SPD or can be obtained from HR Leave Manager. Employees seeking to apply for short- term disability benefits should contact HR Leave Manager promptly and must provide sufficient information to the third party administrator to determine if they are eligible to receive short-term disability benefits. Employees may be required to present a fitness-for-duty certification from their health care provider before being permitted to return to work.

Long-Term Disability Another way Indica Digital helps protect eligible employees – at no cost and with no need to enroll – is through our long-term disability program. Long-term disability benefits are an income continuation benefit, not a leave of absence. Additional information may be found in the SPD or can be obtained from HR Leave Manager. Employees who receive long-term disability benefits may be required to present a fitness-for-duty certification from their health care provider before being permitted to return to work or as part of a conditional offer of reemployment.

Voluntary Benefits Eligible employees may participate in Indica Digital’s Voluntary Benefits Program. A full listing of our available voluntary benefits can be found by asking HR.

Worker’s Compensation Accidental injuries or work-related illnesses which occur during working hours or conditions caused by work activities are covered under our Worker’s Compensation policy, which is paid for in full by Indica Digital. This insurance provides for the payment of medical expenses and weekly compensation payments during the period of an employee’s work-related injury or illness. Report all injuries, no matter how slight, to your manager or HR as soon as possible. You must file your claim forms promptly in order for your claim to be processed and Company records to be prepared properly. Failure to follow Company procedures may affect your ability to receive Worker’s Compensation benefits.

Worker’s Compensation benefits are income protection benefits. Employees unable to work because of a work-related injury or illness must apply for an appropriate leave of absence for which they are eligible.

Section V: Leaves of Absence

General Leave of Absence Guidelines While regular attendance is crucial to maintain business operations, the Company recognizes that, for a variety of reasons, employees may need time off from work. Indica Digital provides a number of types of leaves of absence. Some are governed by law and others are discretionary. Unless otherwise required by law, you should submit a request at least 30 days in advance for all planned leaves; in case of an emergency, the request should be made as soon as you become aware of the need for leave. Requests for leave of absence must be approved by Company management. The Company reserves the right to approve or deny leave requests in accordance with applicable law. For disability-related leave requests, the Company will engage in an interactive process with you to identify possible accommodations that will enable you to perform the essential functions of your job and to determine whether leave is an appropriate accommodation. You must provide a certification from your health care provider to support a leave for medical reasons or you may be required to provide information from your health care provider regarding the nature, extent and severity of your condition.

Failure to provide the required certification and/or information to the Company in a timely manner may result in delay or denial of leave. If you fail to return to work on the first workday following the expiration of an authorized leave, you may be deemed to have voluntarily resigned from the Company and may be taken off the payroll. Should you require an extension of leave, you must request such extension and have it approved before the expiration of the currently approved leave. While Indica Digital will make a reasonable effort to return you to your former position or a comparable position following an approved leave of absence, there is no guarantee that you will be reinstated to your position, or any position, except as required by law.

Unless otherwise provided or as required by law, leave is unpaid. Where leave is unpaid, employees may use PTO when it is approved by the Company in accordance with the Company’s PTO policy. Use of PTO during an otherwise unpaid leave will not extend the period of an approved leave of absence. Group health insurance coverage will be continued during a leave of absence, to the extent required by law.

Holidays that fall during a leave of absence will not be paid.

Family and Medical Leave (“FMLA Leave”) Employees who have been employed by Indica Digital for at least 12 months (not necessarily consecutive), who have worked at least 1,250 hours during the prior 12 months, and who work within 75 miles of a worksite with 50 or more Indica Digital employees may take up to 12 workweeks of unpaid leave per rolling 12-month period in accordance with the Family and Medical Leave Act of 1993 (“FMLA”). The total amount of FMLA leave an eligible employee is entitled to take for any of the purposes set forth in this FMLA Policy, or any combination of purposes, is 12 weeks during any rolling 12-month period, measured backward from the date the employee uses FMLA leave. In addition, an employee may be eligible for additional leave for any of the same purposes if additional leave is provided for by the law of the state in which the employee is employed.

Requests for Leave An employee desiring a FMLA leave shall make written application to his or her HR manager unless this is impossible due to an emergency. Please see your HR manager for the appropriate paperwork. Employees generally are expected to give at least 30 days’ advance notice of intent to take a foreseeable FMLA leave. Where 30 days’ advance notice is not possible, the employee must give as much notice as is practicable. If the need for a leave is not foreseeable, the employee generally is expected to give notice to Indica Digital within 1 or 2 days of learning of the need. An employee who fails to give 30 days’ advance notice may be denied leave until 30 days after the date the employee provides the required notice. Subject to the health care provider’s approval, employees who request leave for planned medical treatments must make a reasonable effort to schedule treatment so as not to disrupt Indica Digital’s operations. Upon receipt of the written application, Indica Digital will provide an employer response form apprising the employee of the status of his or her FMLA leave.

Types of Leave

1) Family Leave An eligible employee will be granted unpaid FMLA leave for the birth of a child of the employee or the placement of a child with the employee for adoption or foster care to bond with a newborn or newly placed son or daughter. Family leave must be concluded no later than 12 months after the birth or placement of the child with the employee.

2) Medical Leave – Serious Health Condition of an Employee or Family Member An eligible employee will be granted unpaid FMLA leave for: (1) the employee’s own serious health condition that makes the employee unable to perform the functions of his or her job or (2) the serious health condition of the employee’s spouse, child, or parent (this does not include parents-in-law). The term “spouse” means a husband or wife and also includes an individual in a same-sex or common law marriage that either: (1) was entered into in a State that recognizes such marriages; or (2) if entered into outside of any State, is valid in the place where entered into and could have been entered into in at least one State. The term “spouse” does not include unmarried domestic partners unless required by law.

If the FMLA leave is being taken for the employee’s own serious health condition and that serious health condition also entitles the employee to leave under an Indica Digital-provided disability program or a workers’ compensation absence, these leaves will run concurrently for purposes of both the disability plan and the FMLA leave entitlement.

The phrase “serious health condition” means an illness, injury, impairment or physical or mental condition that involves: (a) any in-patient care (i.e., an overnight stay) in a hospital, hospice or residential medical care facility (including any period of incapacity or any subsequent treatment in connection with in-patient care); (b) any period of incapacity of more than three (3) consecutive calendar days, including any subsequent treatment or period of incapacity relating to the same condition, that also involves: (a) treatment two (2) or more times by a health care provider, by a nurse or physician’s assistant under the direct supervision of a health care provider, or by a provider of health care services under orders of, or on referral by, a health care provider or (b) treatment by a health care provider on at least one occasion which results in a regimen of continuing treatment under the supervision of a health care provider; (c) any period of incapacity due to pregnancy or for prenatal care; (d) any period of incapacity due to a chronic serious health condition; (e) any period of incapacity which is permanent or long-term due to a condition for which treatment may not be effective, if the employee (or family member) is under the continuing supervision of (but not necessarily receiving active treatment by) a health care provider; or (f) any period of absence to receive multiple treatments by a health care provider or by a provider of health care services under orders of, or on referral by, a health care provider, either for restorative surgery after an accident or other injury or for a condition that likely will result in a period of incapacity of more than three (3) consecutive calendar days in the absence of medical intervention or treatment.

3) Military Leave – Military Caregiver Leave An eligible employee will be granted unpaid FMLA leave to care for a Covered Servicemember (defined below) with a serious injury or illness related to certain types of military service (for up to 26 weeks) (for additional details, see the discussion of the Military-Related FMLA Leave for more details, which is set forth below)

For purposes of this policy, a “Covered Servicemember” is a member or veteran of the United States Armed Forces, including 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. The term “serious injury or illness” means an injury or illness incurred by the member in the line of duty while on active duty in the Armed Forces that may render the member medically unfit to perform the duties of the member’s office, grade, rank, or rating, or one that existed before the beginning of active duty and was aggravated by service in the line of duty while on active duty. With regard to veterans, the injury or illness may manifest itself before or after the individual assumed veteran status.

4) Military Leave – Qualifying Exigency Leave An eligible employee will be granted unpaid FMLA leave to handle certain qualifying exigencies (urgent needs) arising out of the fact that the employee’s spouse, son, daughter, or parent is on duty under a call or order to active duty in the Uniformed Services (for up to 12 weeks) (for additional details, see the discussion of the Military-Related FMLA Leave for more details, which is set forth below).

The phrase “qualifying exigencies” includes activities such as short-notice deployment, military events, arranging alternative childcare, making financial and legal arrangements related to the deployment, rest and recuperation, counseling, and post-deployment debriefings.

For purposes of this FMLA Policy, “incapacity” means the inability to work, attend school or perform other regular daily activities due to the serious health condition, treatment therefore or recovery therefrom.

The maximum amount of leave that may be taken in a 12-month period for all reasons combined is 12 weeks, with one exception. For leave to care for a Covered Service member, the maximum combined leave entitlement is 26 weeks, with leaves for all other reasons constituting no more than 12 of those 26 weeks.

Certification An employee’s request for leave due to a serious health condition (either the employee’s own or that of a family member) must be supported by a timely certification issued by a health care provider. Also, in general, recertification may be required every 30 calendar days unless the certification specifies a minimum duration of incapacity of more than 30 days. When the leave is foreseeable and at least 30 days’ notice has been provided, the employee must provide the original certification (a form that can be obtained from your HR Leave Manager) to your HR Leave Manager before the leave begins. In other situations, the original certification must be provided to your HR Leave Manager within 15 days following the employer’s request for the certification. If the certification or recertification is not provided as set forth above, leave may be denied or discontinued until it is provided and the employee may receive discipline for any unapproved absences, up to and including termination of employment. Indica Digital may elect to obtain a second, and in some circumstances, a third, opinion of the existence of a serious health condition.

Intermittent or Reduced Schedule Leave As part of an eligible employee’s leave for a serious health condition (either the employee’s own or that of a family member), intermittent or reduced schedule leave may be taken if such leave is certified as medically necessary by a treating health care provider. Employees seeking intermittent or reduced schedule leave for a serious health condition must produce medical certification issued by a health care provider. Indica Digital may elect to obtain a second, and in some circumstances, a third, opinion of the medical necessity for this type of leave.

An employee requesting an intermittent or reduced schedule leave must attempt to schedule the leave so as not to disrupt Indica Digital’s operations, and Indica Digital may require the employee to transfer temporarily to an available alternative position with equivalent pay and benefits for which the employee is qualified and which better accommodates the employee’s leave. Benefits During Leave Existing medical and other insurance coverages offered by Indica Digital (“Health Benefits”) will remain in force during the employee’s FMLA leave period as long as required contributions, if applicable, are made by the employee during this period. However, the employee is responsible for continuing to pay directly to the applicable provider any costs or fees relating to individually- owned, voluntary policies (as applicable) during leave. After twelve (12) weeks of medical leave, an employee may be eligible for continuation of health coverage at the employee’s own expense under the federal law known as COBRA.

Employees on an unpaid FMLA leave will maintain the benefits they accrued prior to commencement of the leave but will not accrue additional seniority or benefits while on unpaid leave. While on an unpaid FMLA leave, an employee’s required contribution for Health Benefits coverage must be submitted on the first day of each month or as otherwise agreed to in writing between Indica Digital and the employee.

If an employee’s contributions are not made within thirty (30) days of the due date, all Health Benefits coverage for which the employee is required to contribute can be terminated, provided that Indica Digital has given the employee fifteen (15) days’ advance written notice of the termination of coverage. Upon return from the FMLA leave, even if Health Benefits coverage has lapsed, an employee will be reinstated to benefits coverages on the same terms as prior to taking the leave, without any qualifying period, physical examination or pre-existing conditions limitation. Any changes made by Indica Digital to employee contributions to Health Benefits coverage will apply to employees on FMLA leave.

If an employee fails to make required contributions for Health Benefits coverage, and Indica Digital elects to make such employee contribution on behalf of the employee to keep the coverage in effect during a FMLA leave period, Indica Digital may recover the amount of such contributions made by Indica Digital for the employee regardless of whether the employee returns from FMLA leave. This may be accomplished through payroll deductions, and the employee will be required to authorize such deductions until all amounts are reimbursed to Indica Digital.

Restoration to Position Generally, eligible employees returning from FMLA leave within 12 weeks will be returned to the position that they held when they went on leave, or they may be placed in an equivalent position with equivalent benefits, pay and other terms and condition of employment. Employees returning from unpaid FMLA leave will be restored to their position at the same seniority and benefit level as they had immediately before the unpaid leave began. Exceptions to such restoration will include, but are not limited to, changes in the work force such as reductions-in- force or elimination of positions/departments such that there is no position to which the employee would be entitled if the employee had not taken the leave. If an employee qualifies as a “key employee,” the employee may be denied restoration following FMLA leave on the grounds that the employee’s restoration would cause grievous and substantial economic injury to Indica Digital. A “key employee” is a salaried employee that is among the highest paid 10 percent of all employees employed by Indica Digital within 75 miles of the employee’s work site. If an employee qualifies as a “key employee,” Indica Digital will inform the employee as part of its employer response to the employee’s request for leave.

There may be instances where an employee’s position has been eliminated during the course of an employee’s FMLA leave. When this occurs, the Company will notify affected employees as soon as practicable.

Return to Work Employees on FMLA leave must inform their manager or HR Leave Manager periodically of their status and intent to work following the expiration of their approved FMLA leave. Employees returning from FMLA leave must be able to assume all of the essential functions of their jobs upon return, subject to compliance with all state and federal laws. As a condition to restoring an employee whose leave was based on the employee’s own serious health condition, the employee must provide to their manager or HR Leave Manager, at the employee’s cost, a fitness-for-duty certification from the employee’s health care provider stating that the employee is able to resume work. A fitness-for-duty certification will not be required from employees returning from intermittent leave.

Failure to Return From Leave Unless required otherwise by law, an employee who is granted a leave of absence under these provisions and who fails to return to work upon expiration of the leave granted shall be deemed to have abandoned his or her job.

Miscellaneous In situations where both a husband and wife are employed by Indica Digital, Indica Digital has the right to limit their total amount of leave to twelve (12) weeks when the leave is due to the birth or adoption of a child or care of a child after birth or adoption or to care for a parent who has a serious health condition.

In accordance with applicable law, Indica Digital may require that employees use other forms of paid time off or leave concurrently with FMLA leave.

This FMLA Policy should not be construed to confer any express or implied contractual relationship or rights to any employee not expressly provided for by FMLA. Indica Digital reserves the right to modify this or any other policy as necessary, in its sole discretion to the extent permitted by law. State or local leave laws may also apply.

Paid Parental Leave Policy Indica Digital recognizes the importance of key moments in our employees’ lives such as welcoming a new child into the family. As a result, Indica Digital offers paid parental leave associated with the birth of an employee’s own child or the placement of a child with the employee in connection with adoption.

The function of this policy is to provide employees with a general description of the Indica Digital Parental Leave policy. In the event of any conflict between this policy and the applicable law, employees will be afforded all rights required by law.

Eligibility All regular, full-time or part-time employees are eligible to participate in Indica Digital’s Parental Leave program. Part-time employees receive benefits on a pro-rated basis based on the number of hours they are regularly scheduled to work.

General Provisions Under this policy, Indica Digital will grant four (4) weeks of paid parental leave during the 3-month period following the qualifying event to eligible employees for one or more of the following reasons:

• The birth of a child of the employee in order to care for the child
• The placement of a child with the employee for adoption (excluding the adoption of the children of a spouse) In coordination with Parental Leave, Birth mothers are eligible for six to eight weeks (6 - 8) weeks of paid leave to be coordinated with applicable Short Term Disability benefits. Total paid benefits may not exceed twelve (16) weeks.

The paid parental leave may be taken in a consecutive 4-week period or may be divided into two 2-week or four 1 week blocks spread over a three (3) month period.

All leave benefits provided under this policy shall run concurrently with available FMLA Leave. Employee Status and Benefits Health insurance benefits will continue to be provided under this policy at the same rate in effect before the leave was taken regardless of length of service.

Notice Requirements The employee must provide 30 days’ notice (or as much notice as practicable if the timing of the leave is not foreseeable) to the department head of the request for leave. All requested Paid Parental Leave time should be requested in Indica Digital’s time management system.

Bereavement Leave In order to provide support during times of personal loss, regular, full-time employees are eligible for thirty (30) days of paid bereavement leave in the event of the death of a spouse or child. For purposes of this policy, “child” is defined as an employee’s son or daughter who is a biological, adopted, or foster child, a stepchild, a legal ward or a child of a person standing in loco parentis (in the place of a parent). Three (3) days of paid bereavement will be provided if a death occurs within the employee’s immediate family (excluding spouse or child as noted above) or extended family. “Immediate family” includes parents and siblings. “Extended family” includes grandparents, grandchildren, aunts, uncles, cousins and parents-in-law.

Employees may request additional days off, which must be approved by Indica Digital management. Unless approved by management, additional requested days will be unpaid. Requests for Bereavement Leave should be made as soon as the employee becomes aware of the need for leave. An employee must provide the Company with at least 48 hours’ advance notice of the employee’s intention to take bereavement leave, unless providing such notice is not reasonable or practicable. The Company may request reasonable documentation from the employee to verify the employee’s eligibility for leave under this policy. For verification purposes, information verifying the need for leave may be requested by HR.

Jury Duty The Company realizes that it is the obligation of all U.S. citizens to serve on a jury when summoned to do so. All employees will be allowed time off to perform such civic service as required by law. Employees selected for jury duty will receive their base hourly rate or full base salary, less the amount received from the court as jury pay, for up to ten (10) days (or more if required by applicable law). Additional time off for jury duty beyond the first ten working days will be unpaid (unless applicable law requires otherwise). Absence for jury duty, paid or unpaid, will not be counted against an employee’s attendance record. The Company may require proof of court attendance.

Witness Duty Employees subpoenaed to testify as a witness at an adjudicative proceeding or a deposition shall be granted time off without pay, provided the Employee has notified their immediate manager and the assigned People Business Partner of the need for time off as soon as practicable. Employees testifying at the request of the Company will be given time off with pay.

Military Leave Indica Digital is committed to protecting the job rights of employees absent on military leave. In accordance with federal and state law, it is the Company’s policy that no employee or prospective employee will be subjected to any form of discrimination on the basis of that person's membership in or obligation to perform service for any of the Uniformed Services of the United States.

No one will be denied employment, reemployment, promotion or other benefit of employment on the basis of such membership. Furthermore, no person will be subjected to retaliation or adverse employment action because such person has exercised his or her rights under applicable law or Company policy. Indica Digital provides military leave to eligible employees in accordance with the Uniform Services Employment and Reemployment Rights Act (USERRA) and applicable state law. Employees requesting military leave should contact HR as soon as they are aware of the need for leave.

Personal Leave of Absence If you are ineligible for any other Company leave of absence, the Company, under appropriate circumstances, may grant an employee who is in good standing and otherwise meeting all of Indica Digital’s expectations with respect to performance and attendance a personal leave of absence without pay.

Where practicable, a written request for a personal leave should be presented to management at least two (2) weeks before the anticipated start of the leave. Your request will be considered on the basis of staffing requirements and the reasons for the requested leave. The Company may require submission of appropriate documentation to support the initial leave request, continuation of leave or extension of leave.

At the discretion of the Company, a leave of absence may be granted for a period of up to four (4) weeks. Under unusual circumstances or as a form of accommodation, a personal leave may be extended upon submission of a written request for an extension to HR prior to the expiration of the leave. Employees on personal leave are not entitled to holiday pay. To the extent permitted by the Company’s health insurance plan, the Company will continue an employee’s health insurance coverage during the leave, provided the employee submits his/her share of the monthly premium payments to the Company in a timely manner.

Upon completion of your personal leave of absence, the Company will attempt to return you to your original job, or to a similar position, subject to prevailing business considerations. Reinstatement, however, is not guaranteed.

Failure to return to work at the expiration of leave will be considered a voluntary resignation of employment.

Other Leaves Depending on the state in which you work, the length of your employment at Indica Digital and the number of employees at the facility where you are assigned, you may be eligible for a variety of other leaves. In addition, Indica Digital complies with all state and local laws pertaining to leaves of absence. Please see the applicable Illinois, New York, or California State Supplement for more information. Where a provision providing for leave under the Illinois, New York, or California State Supplement provides for different leave benefits than described herein, Indica Digital will give effect to applicable state or local law.

Section VI: Indica Digital Business Practices and Policies

Equal Employment Opportunity The Company is an Equal Opportunity Employer. Employment opportunities at Indica Digital are based upon one's qualifications and capabilities to perform the essential functions of a particular job and are free from discrimination based on race, color, sex, gender identity, pregnancy, sexual orientation, age, marital status, religion, national origin, ancestry, citizenship status, veteran or military status, disability, genetic information, or any other characteristic protected by applicable federal, state, or local laws.

This Equal Employment Opportunity policy governs all aspects of employment, including, but not limited to, selection, job assignment, compensation, discipline, termination, and access to benefits and training.

All employees are responsible for complying with this policy. As a condition of employment, every employee is to treat all other employees equally, lawfully and fairly. Indica Digital strongly urges the reporting of all instances of discrimination and prohibits retaliation against any individual who reports discrimination or participates in an investigation of such report, including via its anonymous hotline (as further described below). Any incident of retaliation should be reported in the same manner as an incident of harassment or discrimination. Any employee who engages in retaliation will be subject to disciplinary action up to and including termination.

The Americans with Disabilities Amendments Act (ADAAA) The Americans with Disabilities Act (ADA) and the Americans with Disabilities Amendments Act, known as the ADAAA, are federal laws that require employers to not discriminate against applicants and individuals with disabilities and, when needed, to provide reasonable accommodations to applicants and employees who are qualified for a job, with or without reasonable accommodations, so that they may perform the essential job duties of the position. It is the policy of Indica Digital to comply with all applicable federal and state equal opportunity and discrimination laws concerning the employment of persons with disabilities. Furthermore, it is Indica Digital’s policy not to discriminate against qualified individuals with disabilities in regard to application procedures, hiring, advancement, discharge, compensation, training or other terms, conditions and privileges of employment.

When an individual with a disability is requesting accommodation and can be reasonably accommodated without creating an undue hardship or causing a direct threat to workplace safety, he or she will be given the same consideration for employment as any other applicant. Applicants who pose a direct threat to the health, safety and well-being of themselves or others in the workplace when the threat cannot be eliminated by reasonable accommodation will not be hired. HR is responsible for implementing this policy, including resolution of reasonable accommodation, safety/direct threat and undue hardship issues. Any employee or applicant who requires an accommodation should contact HR to request an accommodation. In accordance with applicable law, once Indica Digital is aware of the request for an accommodation, the Company will engage in an interactive process to identify possible accommodations that will enable the applicant or employee to perform the essential functions of his or her job. Employees are expected to cooperate with the Company during the interactive process and to provide requested information pertaining to an individual’s medical condition and/or potential accommodation(s) in accordance with applicable law.

Sexual and Anti-Harassment or Discrimination Policy All employees have the right to a work in an environment free from all forms of harassment and discrimination and conduct which can be considered harassing, coercive or disruptive. Indica Digital is committed to providing a work environment that is free of discrimination and all types of harassment. Actions, words, jokes, or comments based on an individual’s sex, gender, race, national origin or ancestry, color, age, marital status, pregnancy, disability, religion, sexual orientation, genetic information, veteran or military status, or any other legally protected characteristic will not be allowed. Harassment, sexual or based on any other legally protected characteristic, is against the law and against Indica Digital’s policy and will not be tolerated at any time.

Examples of Prohibited Sexual Harassment: Sexual harassment includes a broad spectrum of conduct including harassment based on gender, transgender and sexual orientation (meaning one’s heterosexuality, transgenderality, homosexuality, or bisexuality).

By way of illustration only, and not limitation, some examples of unlawful and unacceptable behavior include:

• Unwanted physical, verbal or other sexual advances;
• Offering an employment benefit (such as a Indica Digital, promotion, or assistance with one’s career) in exchange for sexual favors, or threatening an employment detriment (such as termination, demotion, or disciplinary action) for an employee’s failure to engage in sexual activity;
• Visual conduct, such as leering, making sexual gestures, displaying sexually suggestive objects or pictures, cartoons or posters;
• Verbal sexual advances, propositions, requests or comments;
• Verbal abuse of a sexual nature, graphic verbal commentaries about an individual’s body, sexually degrading words used to describe an individual, suggestive or obscene letters, notes, messages or invitations;
• Physical conduct, such as touching, assault, impeding or blocking movement;
• Physical or verbal abuse concerning an individual’s actual sex or the perception of the individual’s sex; and
• Verbal abuse concerning a person’s characteristics such as vocal pitch, facial hair or the size or shape of a person’s body, including remarks that a male is too feminine or a woman is too masculine. This policy applies to all employees, including supervisors and non-supervisory employees. Harassment of our members/clients, or employees of our members/clients, vendors, suppliers or independent contractors by our employees is also strictly prohibited. Such harassment includes the types of behavior specified in this policy, including sexual advances, verbal or physical conduct of a sexual nature, sexual comments and gender-based insults. Any such harassment will subject an employee to disciplinary action, up to and including immediate termination.

No employee shall directly or indirectly: (a) threaten or insinuate that another person’s refusal to submit to sexual advances or other forms of harassment will adversely affect that person’s relationship with Indica Digital, work status, evaluation, wages, advancement, assigned duties, or any other condition of employment; (b) promise, imply or grant preferential treatment in connection with another person engaging in sexual conduct; or (c) abuse the dignity of another person through insulting or degrading sexual remarks or conduct, or other remarks intended to insult or degrade another employee based on any other personal characteristic that is protected by law. All employees must be allowed to work in an environment free from sexual overtones and intimidation or other forms of discrimination. Sexual harassment can occur between men and women, or members of the same sex.

Examples of What Constitutes Prohibited Harassment: In addition to the above listed conduct Indica Digital strictly prohibits harassment concerning race, color, disability, religion, national origin, age or other legally protected characteristic. By way of illustration only, and not limitation, prohibited harassment concerning race, color, disability, religion, national origin, age or other protected characteristic includes:

• Slurs, epithets, and any other offensive remarks;
• Jokes, whether written, verbal, or electronic;
• Threats, intimidation, and other menacing behavior;
• Other verbal, graphic, or physical conduct; and
• Other conduct predicated upon one or more of the protected categories identified in this policy. Indica Digital values and promotes diversity in its workplace. Diversity refers to human differences, including those based on culture, ethnicity, gender and age that exist in the workforce. Indica Digital prohibits harassment and discrimination because it believes that promoting diversity plays an important role in attracting the widest pool of qualified applicants, fostering greater innovation and creativity and enhancing our communication and relationships with members and the community. Indica Digital considers harassment or discrimination in all forms to be a serious offense.

Harassment or discrimination of any form is unacceptable in the workplace itself and at other work-related settings such as business trips, meetings with members/clients and business-related social events. Indica Digital will not tolerate, condone, or allow harassment or discrimination of any kind, whether engaged in by fellow employees, supervisors, managers, or non-employees who conduct business with Indica Digital . Indica Digital . supports and encourages reporting of all incidents of sexual or other harassment or discrimination, regardless of who the offender may be.

Any employee who has a complaint of or has witnessed any form of harassment or discrimination should immediately report the harassment to any executive officer of Indica Digital or to HR.

Complaints can also be made anonymously to our independent provider Lighthouse via the following means: Phone: 844-670-0006 Website: www.lighthouse-services.com/Indica Digital Email: reports@lighthouse-services.com (must include company name with report) Fax: (215) 689-3885 (must include company name with report)

Indica Digital cannot respond to or correct possibly offensive behavior unless it is immediately made aware of the conduct.

If Indica Digital receives a report or becomes aware of the possibility of harassment or discrimination, either from a complaint or from observation, a prompt and discreet investigation will be conducted and every effort will be made to keep the matter confidential within its ability to do so while still conducting a thorough investigation. After the investigation has been concluded, a determination will be made and appropriate action will be taken to resolve the complaint. Where a hostile work environment has been found to exist, Indica Digital will take all reasonable steps to eliminate the conduct creating such an environment.

This policy also prohibits retaliation against employees who bring harassment or discrimination charges or assist in investigating charges. Any employee bringing a harassment complaint (other than a knowingly false or recklessly made claim) or assisting in the investigation of such a complaint will not be adversely affected in terms and conditions of employment, nor discriminated against or discharged because of the complaint. Any incident of retaliation should be reported in the same manner as an incident of harassment or discrimination. Any employee who engages in retaliation will be subject to disciplinary action up to and including termination.

If an employee does not report harassment or discrimination to management, Indica Digital may not be able to fully investigate and possibly correct the situation. Indica Digital requires that all suspected or actual harassment (whether or not you are involved or a subject of the harassment) be immediately reported to the most immediate supervisor of the harassed person.

If an employee is not comfortable with reporting sexual harassment to his or her supervisor, for any reason, then the employee should report the problem to a higher level manager, or to an executive officer of Indica Digital or to HR.

No employee will be penalized or sanctioned for “going around or over the head” of his or her supervisor to report harassment or discrimination. Indica Digital’s goal is to have and maintain a workplace free from discrimination and any form of harassment.

Anti-Violence Policy We are strongly committed to providing a safe workplace. The purpose of this policy is to minimize the risk of personal injury to employees and damage to Indica Digital and personal property.

Prohibited Conduct Threats, threatening language or any other acts of aggression or violence made toward or by any Indica Digital employee will not be tolerated. For purposes of this policy, a threat includes any verbal or physical harassment or abuse, any attempt at intimidating or instilling fear in others, menacing gestures, flashing of weapons, stalking or any other hostile, aggressive, injurious and/or destructive action undertaken for the purpose of domination or intimidation. Weapons are prohibited on Company premises unless such prohibition is restricted by applicable law.

Procedures for Reporting a Threat All potentially dangerous situations, including threats by co-workers, should be reported immediately to any member of management with whom you feel comfortable. Reports of threats may be maintained confidential to the extent maintaining confidentiality does not impede our ability to investigate and respond to complaints. All threats will be promptly investigated. No employee will be subjected to retaliation, intimidation or disciplinary action as a result of reporting a threat in good faith under this policy.

If an investigation confirms that threat of a violent act or violence itself has occurred, the Company will take swift and appropriate corrective action.

If you are the recipient of a threat made by an outside party, please follow the steps detailed in this section. It is important for us to be aware of any potential danger in our offices. Indeed, we want to take effective measures to protect everyone from the threat of a violent act by an employee or by anyone else.

If you have any questions about this policy, please speak with your manager, someone in management or People Ops.

Conduct Guidelines & Discipline Indica Digital expects an employee’s conduct and performance to conform to general standards of good conduct, professionalism, and business ethics; the requirements of his or her job; the Company Code of Conduct, published and common sense health and safety rules and practices; and applicable federal, state and local laws, rules, and regulations. There are certain, fairly obvious types of conduct which are unacceptable and which will subject an employee to disciplinary action, up to and including discharge. The following, non-exclusive list of such conduct is offered for the guidance of employees:

• Theft or unauthorized possession of Company property or the property of fellow employees or customers, regardless of value. This includes expense or corporate credit card abuse.
• Working under the influence of alcohol or illicit drugs.
• Possession, distribution sales, or transfer of alcohol or illicit drugs in the workplace.
• Smoking in the workplace.
• Provoking or engaging in a fight or threatening harm to others while on duty or on Company property.
• Engaging in abusive, obscene, threatening, intimidating or profane language or conduct while on duty or on Company property.
• Sexual or other unlawful or unwelcome harassment.
• Insubordination, including failure or refusal to promptly carry out the orders or instructions of a supervisor or manager. (Note: This includes the failure or refusal to work overtime required by the Company.)
• Excessive absenteeism or any absence without notice.
• Acts of dishonesty, including falsification or alteration of attendance records, time records, reimbursement records or other employment-related documents.
• Gambling in any form while on duty or on Company property.
• Misrepresentation or omission of material facts on an employment application, resume or other document used to secure or retain employment with the Company.
• Committing any criminal offense while on duty or on Company property, or which otherwise may adversely affect the employee’s work or work relationships or the Company’s business or reputation.
• Excessive use of work time for personal matters and/or using company property, time or resources for pursuit of commercial endeavors not related to Company business.
• Poor workmanship, substandard productivity or unsatisfactory work performance.
• Damaging or improperly using, caring for or maintaining Company property, including tools, equipment, machinery, databases or software.
• Repeatedly exceeding time limits on meal and break periods, or taking meal and break periods at other than designated times, without proper authorization.
• Stopping or leaving work before the end of a scheduled work period without proper authorization.
• Sleeping, loafing or wasting time during a scheduled work period.
• Intentionally interfering with other employees on the job.
• Posting materials without proper authorization, or defacing, marking, damaging, destroying or removing materials posted by the Company.
• Unauthorized examination, use or disclosure of confidential Company records or proprietary information.
• Misrepresentation regarding a leave of absence, or obtaining other employment during a leave of absence without proper authorization from the Company.
• Violating the Company’s Code of Conduct.
• Violating any Company policy.

All disciplinary action is within the Company’s discretion. Cases of unacceptable work behavior will be handled on an individual basis, subject to such penalties as the Company may deem appropriate, up to and including termination of employment. Relevant factors include, but are not limited to, the nature of the offense, the surrounding circumstances, and the employee’s prior work record. The Company generally endorses the concept of corrective counseling, which is predicated on the assumption that employees, when given the opportunity to correct work behavioral problems, will do so. Therefore, when deemed appropriate, the Company will attempt to apply corrective counseling before discharging an employee. Nevertheless, in any given case, the disciplinary action imposed by the Company can range from informal counseling, to written warnings, to suspensions without pay, to immediate discharge. Furthermore, nothing stated herein should be construed as imposing a requirement of “cause” for discipline or discharge, or as otherwise limiting the prevailing “at-will” employment relationship between the Company and its employees.

Expense Reimbursement For more information, please review the Indica Digital Travel & Expense Policy managed by Finance.

Attendance Your professional skills, experience and dedication is what made you an excellent hire for Indica Digital, and with that, you were hired to perform an important function at the Company. As with any group effort, operating effectively takes cooperation and commitment from everyone.

Therefore, your attendance and punctuality are very important. Unnecessary absences and tardiness are expensive, disruptive and place an unfair burden on your fellow employees and your manager. We expect excellent attendance from each of you. Excessive absenteeism or tardiness will result in disciplinary action up to and including termination. Please confer with your functional leader to ensure you understand specific policies related to attendance within your department. We expect you, as a team member, to avoid these problems wherever possible.

We do recognize, however, that there are times when absences and tardiness cannot be avoided. In such cases, you are expected to notify your manager as early as possible, but at least 30 minutes before the start of your workday. Asking another employee, friend or relative to give this notice is improper and constitutes grounds for disciplinary action. You are expected to provide the reason for the absence and the expected duration every day that you are absent, including consecutive days of absence. If you call in sick for three or more consecutive days, you may be required to provide your manager with a doctor’s note on the day you return to work. In addition, a pattern of absences (e.g., frequent call-ins on a Monday or Friday, or before or after holidays, or before or after scheduled PTO) may result in disciplinary action, including discharge. Unreported absences of three (3) consecutive work-days will be considered a voluntary resignation of your employment with the Company.

Personal Relationships Our goal is to ensure that everyone is cared for and protected, including the Company. Therefore, this policy intends to clarify boundaries for personal relationships within the workplace. The Company does not ban or discourage inter-office or inter-company dating. However, during working hours and at all work-related events, all employees must conduct themselves in appropriate workplace behavior and in a manner that does not interfere with overall productivity.

Outside of working hours, all conduct is considered private, as long as the conduct does not create problems within the workplace. Managers may not date or become romantically involved with a reporting employee. Any manager who decides to pursue a romantic relationship with an employee, must inform their manager and the Chief People Officer immediately so that the Company has ample opportunity to protect all parties involved. This may include a reorganization of the team or reporting lines so that the employees are no longer in a direct management/employee relationship, nor able to influence or affect the terms and conditions of employment of the subordinate employee. Even if there isn’t a supervisory or official relationship, the Company reserves the right, in cases where a conflict or the potential for conflict arises to intervene and proactively address issues related to personal relationships within the team. Resolution could include re-assigning employees, or if appropriate, discontinuation of employment. Refusal of reassignment or an acceptable solution will be considered a voluntary resignation.

Inclement Weather Policy The safety of employees is a primary priority to Indica Digital. Because of this, the Company does not want employees to take undue risks in order to travel to work when there is inclement weather. Though the office will rarely close due to weather, we encourage employees to use their best judgment in assessing the situation. If the employee has the technology and job responsibilities that allows him/her to work from home on such occasions, it should be considered a ‘normal’ work day. However, if the employee is not able to work from home and chooses not to come into the office, it is expected that the employee will enter PTO time for the day, using the time tracking system.

Dress Code Indica Digital’s objective in establishing a relaxed, casual, and informal dress code is to encourage employees to work comfortably while in our offices. Though we value the importance of being comfortable, we ask that employees dress in an appropriate and professional manner. Most clothing is generally acceptable except offensive clothing with profanity or crude slogans, beachwear, or unprofessional clothing like tank or tube tops and short shorts or skirts.

Personal Property Indica Digital assumes no responsibility for personal property located on its premises. Employees are to use their own discretion when choosing to bring personal property into the workplace, and do so at their own risk. Additionally, employees may not possess or display any property that may be viewed as inappropriate or offensive on Indica Digital premises.

Visitors in the Workplace All employees who allow a guest on Indica Digital property must ensure that the guest is aware of business practices, and the guest may be asked to leave to accommodate the needs of the business at any time. All visitors to Indica Digital, must maintain a professional manner and be respectful of the working environment they are in. Under no circumstances is it appropriate to leave a guest on Company property with no direct supervision from an employee of Indica Digital. Visitors are only allowed during normal business hours. All visitors must sign a Non-Disclosure-Agreement (NDA) before entering the work area. All employees must be fully cognizant of their obligations under the Company’s Information Technology Acceptable Use and Personal Security Policy (Section VI below) when considering visitors in any Indica Digital property.

Drug and Alcohol Abuse Indica Digital considers drug and alcohol abuse a very serious problem, and is committed to maintaining a workplace free of substance abuse. This policy applies to all employees of Indica Digital. without exception, including part-time and temporary employees as well as contractors operating on Indica Digital’s premises.

No employee is allowed, unless approved during certain instances designated by Indica Digital management for celebration, or casual instances, to consume, possess, sell, or purchase any alcoholic beverage on any property owned by or leased on behalf of Indica Digital or in any vehicle owned by or leased on behalf of Indica Digital. No employee may use, possess, sell, transfer, or purchase any illegal drug or other controlled substance that may alter an individual’s mental or physical capacity in any way. Exceptions are aspirin- or ibuprofen-based products, as well as legal drugs that have been prescribed to that employee by a doctor and are being used in the manner prescribed.

Indica Digital will not tolerate employees who report for duty while impaired by use of alcohol or illegal drugs.

All employees should report evidence of alcohol or drug abuse to their manager immediately. In cases in which the use of alcohol or drugs creates an imminent threat to the safety of persons or property, employees are required by Indica Digital to report the violation. Failure to do so may result in disciplinary action.

Employees found in violation of Indica Digital’s Drug and Alcohol Abuse Policy will be subject to disciplinary action, up to and including termination. It is our policy at Indica Digital to assist employees and family members who suffer from drug or alcohol abuse. Employees with a substance-abuse problem may be eligible for a leave of absence, and are encouraged to contact Indica Digital management for details.

As a part of our effort to maintain a workplace free of substance abuse, Indica Digital employees may be asked to submit to a medical examination and/or clinical testing for the presence of alcohol and/or drugs. Within the limits of state and federal laws, we reserve the right to examine and test for drugs and alcohol at our discretion. Such situations may include, but are not limited to, the following:

• The screening of employees being considered for employment with Indica Digital, in accordance with applicable state and federal law;
• Cases in which there are reasonable grounds for believing that an employee is under the influence of alcohol or drugs;
• As part of an investigation of any accident in the workplace in which there are reasonable grounds to suspect that alcohol and/or drugs were involved;
• On a random basis, where allowed by statute;
• As a follow-up to a rehabilitation program, where allowed by statute;
• As deemed necessary to maintain the safety of employees, members, clients, or the public at large, where allowed by statute;
• When an employee returns to duty following an absence other than that resulting from PTO.

Smoke-Free Workplace Policy It is the policy of Indica Digital to provide a tobacco-free environment for all employees and visitors. This policy prohibits smoking of any tobacco product including the use of oral tobacco products or “spit” tobacco on all company premises, in order to provide and maintain a safe and healthy work environment for all employees.

Policies Applicable to Social Media At Indica Digital we realize that our employees express themselves by participating in social media forums including blogs, wikis, online social networks and other forms of online publishing or discussion, but these communication channels are changing the way we talk to each other, our customers, target audiences and partners.

Indica Digital has developed the following social media policy to provide helpful and practical advice for you when operating on the internet as an identifiable Indica Digital employee in order to balance Indica Digital’s desire for employees to use social media while protecting its legitimate business interests. Employees who violate these policies are subject to discipline, up to and including termination. If you violate these guidelines, we may require you to correct, edit or remove a post or statement.

Customer or general service issues Indica Digital on social media on another online platform are handled exclusively by the Voice of the Customer team.

Indica Digital recognizes that social media provides opportunities to participate in interactive discussions and share information on particular business and non-business related topics. Social media use, however, poses risks to Indica Digital’s trade secrets and other confidential and proprietary information, reputation and brands. The following policy provisions are intended to balance those interests.

This policy will not be interpreted or enforced in violation of federal labor law, and does not prohibit protected conduct or communications relating to employee wages, hours or working conditions, or any other conduct protected by Section 7 of the National Labor Relations Act. Policies Applicable to Business Use of Social Media Only employees expressly authorized by Indica Digital may engage in social media activities on behalf of Indica Digital, although we encourage all employees to promote, share or re-tweet official Indica Digital posts (i.e., those that originate on Indica Digital social media channels) like press releases, hiring announcements, etc., to their personal social channels, if they feel motivated to do so. The Company expects employees posting on behalf of Indica Digital to exercise sound business judgment and to otherwise comply with this policy.

When engaging in social media activities on behalf of Indica Digital, employees must respect the intellectual property rights (trademark and copyright) of third parties and may not use a third party’s logos and other copyrighted or trademarked material without the permission of that party. Indica Digital’s logos, drawings, trademarks, copyrights, or other images or photographs of Indica Digital typically associated with Indica Digital must be used in a manner consistent with Indica Digital’s policies. Please visit the #creative-brandassets Slack channel to review the Indica Digital Brandbook.

Employees participating in social media activities on behalf of Indica Digital’s business or in relation to Indica Digital’s products or services, must disclose their affiliation with the company. Indica Digital requires all employees who are communicating on behalf of the Company to always disclose their affiliation and to use approved naming conventions. Posts by Indica Digital employees should be accurate and factual. Any errors should be acknowledged and corrected promptly.

Spam and/or comments that are off-topic should be removed from Indica Digital-sponsored or managed social media sites and should not be posted by Indica Digital employees to social media sites sponsored or managed by third parties.

Policies Applicable to Personal Use of Social Media When posting comments to social media sites, including an online forum such as a blog, employees may not include any trade secret or other confidential or proprietary information of Indica Digital. Confidential or proprietary information includes any Indica Digital nonpublic financial information, trade secrets, technical/product/service developments which have not been made public, or Indica Digital’s business development or marketing plans; other information which the disclosure of would violate any federal, state or local statute or regulation (including privacy laws). Questions about whether an item of information constitutes a trade secret or other confidential or proprietary information of Indica Digital should be directed to the employee’s manager or the Company’s legal department. This also includes anything to do with a legal or compliance issues or any legal matter, without first checking with legal.

Personal handles/usernames should not include any Indica Digital-related branding as it may cause confusion to our clients and prospects when they are trying to reach out to us. Some users like to take to social media as a way to express their frustration with a company or service, in hopes of reaching a resolution faster than calling the company directly. If you share Indica Digital content, OR list Indica Digital as your employer in your bio, refrain from posting negatively about other companies as they may be a current client or prospect. Such interactions can hurt deal progress or our customer relationships.

Employees are allowed to associate themselves with the Company when posting but they must clearly brand their online posts as personal and purely their own. We suggest adding the phrase “Thoughts and opinions are my own” to any personal bio/profile if Indica Digital content will be posted. The company should not be held liable for any repercussions the employee's content may generate.

To the extent Indica Digital employees are posting comments to social media outside of the scope of their job responsibilities, they may not make any statements that would give the impression that the views they have expressed are the opinions of Indica Digital. Indica Digital employees may not utilize any of Indica Digital’s logos, drawings, trademarks, copyrights, or other images or photographs of Indica Digital or typically associated with Indica Digital with respect to their personal social media activities if doing so would reasonably create the impression that the social media post or page is sponsored or sanctioned by Indica Digital.

Indica Digital employees posting positive comments to social media in their personal capacity about Indica Digital or its products or services must disclose their affiliation with Indica Digital in the post.

Indica Digital employees may not post statements, in their personal capacity or as representatives of Indica Digital, that they know to be defamatory or false about Indica Digital or supervisory employees, other employees, independent contractors (consultants), or any third party (including a competitor or customer of Indica Digital).

Indica Digital employees may not post disparaging statements or negative opinions, in their personal capacity or as representatives of Indica Digital, about Indica Digital’s customers, other third parties or Indica Digital’s products or services.

Indica Digital employees are expected to abide by Indica Digital’s policies against unlawful discrimination and harassment while engaged in social media activities on behalf of Indica Digital or in their personal capacities. Posts should be respectful and courteous to fellow employees, competitors, customers and the general public. Indica Digital employees may not make comments or otherwise communicate about coworkers, supervisors, the Company, or vendors or suppliers in a manner that is vulgar, obscene, threatening, intimidating, harassing, libelous, or discriminatory on the basis of age, race, religion, sex, sexual orientation, gender identity or expression, genetic information, disability, national origin, ethnicity, citizenship, marital status, or any other legally recognized protected basis under federal, state, or local laws, regulations, or ordinances. Those communications are disrespectful and unprofessional and will not be tolerated by Indica Digital. Indica Digital employees are expected to respect the laws regarding copyrights, trademarks, rights of publicity and other third-party rights. To minimize the risk of a copyright violation, Indica Digital employees should provide references to the sources of information used and accurately cite copyrighted works identified in online communications.

Indica Digital prohibits taking retaliatory action against any employee for reporting possible violations of this policy or for cooperating in an investigation. Any employee who retaliates against another employee for reporting a possible deviation from this policy or for cooperating in an investigation will be subject to discipline.

Employees who come across unfavorable opinions, negative comments or criticism about themselves (in their capacity as employees of Indica Digital), coworkers (in their capacity as employees of Indica Digital) or Indica Digital (including its products or services), should not attempt to have the post removed and should not send a written reply as a representative of Indica Digital. Rather, the negative post should be forwarded to Indica Digital’s Public Relations and HRs.

Confidential Information In the course of employment, employees may acquire or be granted otherwise prohibited access to trade secrets and other confidential and proprietary information (collectively, “Confidential Information”) that is not known to the Company’s competitors, third parties or within the industry generally. Such information has been developed by the Company over a long period of time and at substantial expense, is confidential in nature and is of great competitive value to the Company. Confidential Information includes, but is not limited to, non-public data relating to the Company’s production practices and methods of doing business; sales, marketing, and service strategies, programs, and procedures; customers and prospective customers; particularized customer requirements and preferences; the identity, authority and responsibility of key customer contacts; payment methods; service, product and material costs and pricing structures; sources of supply; financial position and business plans; computer programs and databases; research projects; new product and service developments; and related formulas, plans, designs, and drawings.

The disclosure of Confidential Information to unauthorized persons outside the Company is prohibited and may constitute a violation of the law. Confidential Information should only be discussed within the Company on a “needs-to-know” basis. This duty of confidentiality applies during and even after your employment with the Company. As a condition of employment with Indica Digital, all employees must sign its standard confidentiality and IP assignment agreement. Nothing in this handbook prohibits an employee from communicating with any governmental authority or making a report in good faith and with a reasonable belief of any violations of law or regulation to a governmental authority, or disclosing Confidential Information that the employee acquired through lawful means in the course of his or her employment to a governmental authority in connection with any communication or report, or from filing, testifying or participating in a legal proceeding relating to any violations, including making other disclosures protected or required by any whistleblower law or regulation to the Securities and Exchange Commission, the Department of Labor, or any other appropriate government authority. To the extent an employee discloses any Confidential Information in connection with communicating with a governmental authority, the employee will honor the other confidentiality obligations in this handbook and their Confidentiality and IP Assignment Agreements and will only share such Confidential Information with his or her attorney, or with the government agency or entity. Nothing in this handbook shall be construed to permit or condone unlawful conduct, including but not limited to the theft or misappropriation of Company property, trade secrets or information.

Outside Employment Employees may hold outside jobs in unrelated businesses or occupations as long as the employee meets the performance standards of their position with Indica Digital . Unless an alternative work schedule has been approved by Indica Digital ., employees will be subject to Indica Digital's scheduling demands, regardless of any existing outside work assignments. [RJP: WE SHOULD DISCUSS THIS, AS OUR CURRENT IP ASSIGNMENT AND CONFIDENTIALITY AGREEMENT INDICATES AN EMPLOYEE CANNOT HOLD ANOTHER JOB.]

Indica Digital office space, equipment, time, resources, systems and materials are not to be used for purposes related to outside employment.

Business Ethics/Conflict of Interest In order to conduct business at a high level of proficiency and productivity, all employees have an obligation to perform their job duties and conduct business in a manner that avoids actual or potential conflicts of interest. An actual or potential conflict of interest exists when an employee is in a position to influence a decision that may result, directly or indirectly, in an improper benefit to that employee, a relative of the employee, or anyone with whom the employee has a close, personal relationship.

Employees must also avoid activities, interests, and relationships that might interfere with their ability to make decisions in the best interest of the Company. For this reason, employees may not accept any monetary payments from anyone doing or seeking to do business with the Company. The Company further prohibits employees from engaging in any outside business activities with anyone doing or seeking to do business with the Company.

Any conflict of interest situation should be reported by the employee to HR for resolution. Violators of this policy may be subject to disciplinary action, up to and including termination of employment.

Solicitations and Distributions To avoid disruption of the workplace and potential embarrassment for our employees, no solicitations, collections, circulation of petitions or distributions of literature by employees are permitted during working time or in working areas. "Working time" refers to the work time of the employee soliciting, collecting, circulating or distributing as well as the employee to whom such action is directed. It does not include breaks, meal periods or other times before or after work. "Working areas" includes all offices, reception areas, hallways, conference rooms or other areas where business is conducted. It does not include break rooms. In addition, no person from outside the Company is allowed on Company premises at any time for these or related purposes. If you observe someone who is not an employee engaging in any of these activities at any time, please notify management immediately.

Return of Company Property When an employment chapter at Indica Digital comes to a close, specific protocol will occur to ensure all Company property is correctly returned. Upon termination of employment or request of the Company, employees must return any and all property of the Company that is in their possession, custody, or control including, without limitation, all keys, computer hardware and software, cellular phones, materials, papers, books, files, documents, records, policies, database information and lists, mailing lists, notes, data and any other property or information that the employee may have relating to the Company or reflecting or embodying its confidential and proprietary information. Employees may not retain any such property or information in any form, and may not give copies of such property or information or disclose their contents to any other person. Furthermore, the employee must not remove any company data from any computer devices it is provided by the Company, including it may not “wipe” any data from such Company device.

Section VII: Information Technology Acceptable Use and Personnel Security Policy

Physical Asset Protection Any physical technology assets (i.e., laptops, smartphones, etc.) provided by Indica Digital to employees, contractors, or any third-party users, shall be properly controlled and protected, with reasonable care provided to avoid loss or damage. In particular, the party to whom the assets are provided shall not take any actions that may contribute to asset failure, shall not connect or use accessories or peripherals not supplied, supported or approved by the CTO, and shall not use any technology asset services not authorized by the Company.

Unauthorized Software or Modification of Electronic Resources No action shall be taken that compromises the normal function, operation and security of physical technology assets. Such action includes the installation of unauthorized or unlicensed software on the asset.

Secure Storage of Physical Assets To minimize loss or damage while traveling, any physical technology assets shall be carried with the traveler and shall not be put into checked luggage. When stored in a vehicle, any physical technology assets shall be placed into a completely enclosed and locked compartment (e.g., automobile trunk) where they are not visible to persons outside the vehicle.

Physical Asset Return Upon Termination When the party to whom the physical technology asset was issued no longer has a relationship with the Company (e.g., employment termination or contract termination), the asset shall be returned to the Company.

Lost or Stolen Physical Assets If any physical technology assets have been damaged, lost or stolen, the party to whom the assets were issued shall immediately inform the service desk and the party’s supervisor both verbally and in writing.

Personal Data Storage Users shall not store personal files on Indica Digital network drives or provided SaaS applications. Limited Personal Use Users shall restrict non-business related usage of the Internet to a minimum, and in particular shall not intentionally navigate to any unusual or non-genuine websites that do not contain content of an appropriate nature or that may contribute to computing and networking asset failure.

Trademark and Copyright Adherence Users shall respect and comply with local and international legal protection provided by trade secrets, patents, copyrights and trademarks to any information viewed or obtained via the Internet.

Use of Personal Electronic Resources The use of physical technology assets, other than those supplied by Indica Digital, to access computing and networking assets or to process Company information shall be strictly controlled. In particular, the entity owning the asset shall agree to enforce security policies comparable to what Indica Digital imposes on its own physical technology assets, especially regarding patching, software firewall protection, endpoint malware protection, disk or file/folder-level encryption when needed and appropriate controls over installation of software that can be used for network scanning, hacking or other potentially intrusive purposes. The Information Security department shall examine or test the asset to ensure that it meets these standards before allowing it to access the Company network. This may be done on an individual asset by asset basis, or on a class of assets owned by a vendor where the vendor agrees to perform the examination and testing in the same fashion as the Company, and to attest that it has been done. Thereafter, for assets that are allowed to access the Company network, Indica Digital shall examine or check such assets to confirm that they remain in compliance with company standards for access.

Personal Electronic Resources for Visitors Physical technology assets utilized by visitors while conducting business with Indica Digital and connecting to a designated guest network, are exempted from 1.2.9, but shall comply with all other Acceptable Use controls.

Transmission of Company Information Confidential Company information other than public information shall not be transmitted to a third party unless:

• The information originated from that third party.
• The information originated within the Company and the third party has entered into a non-disclosure agreement with the Company for the purpose of exchanging the information.
• The information originated within another party, and the Company has the express permission from the originator of the information to transmit the information to the third party.
• The information is shared in accordance with the Company’s information classification policies.

Company Ownership Banner Computing and networking assets shall display a banner prior to login, warning against unauthorized and inappropriate use.

Return of Company Data When an employee leaves the Company (i.e., is no longer employed by the Company), he or she shall return to the Company, before departing, all documents in any form, electronic or physical, containing any company information other than public information. Destruction or erasure of documents or company records shall be solely at the direction of the Company.

User IDs and Passwords Users must be responsible for all activity performed with their personal user IDs. They must not permit others to perform any activity with their user IDs and they must not perform any activity with IDs belonging to other users.

Company computer accounts, user IDs, network passwords, voice mail box PINs, credit card numbers, and gift card numbers and PINs must not be used by anyone other than the person to whom they were originally issued.

Users must never type their passwords if others are known to be watching their actions nor shall users write down or otherwise record passwords.

E-mail Messaging and Social Media Users must use the utmost care in creating messages on the Company’s systems. Even when a message has been deleted, it may still exist on a back-up system, be recreated, be printed, or may have been forwarded to someone else without its creator’s knowledge. As with paper records, proper care should be taken in creating electronic records, which can affect the Company’s business and which the Company may someday have to produce in connection with a lawsuit.

Viruses and Tampering The introduction of viruses, attempts to breach system security, or other tampering with any of the Company’s systems is expressly prohibited. Employees must immediately report any viruses, tampering, or other system breaches to a managerial employee. In order to reduce the possibility of viruses attacking the Company’s systems, employees should not open any attachments of unknown origin.

Any user who suspects infection by a virus or malware must immediately disconnect the involved device from the Company network, call the IT Security team, and make no attempt to eradicate the virus.

No Unauthorized use of Cloud Services Users shall not use services provided on the Internet (e.g., cloud services) to store, transmit or process company information other than public information, unless the service has been approved for such use by the Information Security team.

No Expectation of Privacy Communications on the Company’s systems are not private, and security cannot be guaranteed. Any passwords, codes or user IDs assigned by the Company are designed to protect the Company’s confidential information from outside third parties, not to provide employees with personal privacy in their messages. Employees should assume that any communications they send or receive on the Company’s systems may be read or heard by someone other than the intended recipient.

Company’s Right to Monitor Messages and Systems Use The Company reserves the right to monitor, access, retrieve, read, and disclose to law enforcement officials or other third parties all messages and other files created, sent, received, or stored on the Company’s systems without prior notice to the originators or recipients of such messages. The Company also reserves the right to monitor all activity conducted on its computers and other systems, e.g. networks, personal devices or other BYOD technology. Authorized personnel may monitor the electronic communications of employees and the use of Company computers and other systems to determine whether there have been any violations of law, breaches of confidentiality or security, or any violations of this Policy or any other Company policy.

Adherence to Security Policies Managers and supervisors are responsible for assuring that security processes and procedures within their areas of responsibility are followed. All Indica Digital employees must be aware of their responsibility for security and their requirement to protect Indica Digital assets by reviewing and acknowledging them on an annual basis. New Indica Digital employees must receive appropriate training before receiving access to Indica Digital information or services. When appropriate for the employee’s role, mandatory training specific to data security and measures to prevent unauthorized data disclosure is required. To ensure compliance, individual use of Indica Digital resources may be monitored. Indica Digital reserves the right to conduct periodic unannounced audits of all Indica Digital issues devices and accounts to ensure compliance with all policies. Further, Indica Digital may block access to any Internet sites that are determined to be inappropriate for any reason.

Termination The Human Resources department must comply in providing formal reporting of employee termination and/or reassignment to the organizations charged with performing identity and access management.

Disciplinary Action Policy Employees who fail to comply with Indica Digital’s Information Security Policies and control standards may be subject to disciplinary actions including termination of employment. The specific disciplinary action depends upon the nature of the violation and the impact of the violation of Indica Digital’s informational assets and related facilities. Access privileges may be revoked for user accounts during an investigation. Any actual or suspected violations of Indica Digital security policies or standards must be reported to the user’s supervisor and Information Security via security[at]IndicaDigital.com.

The Company reserves the right to hold employees personally liable for any violations of this Policy.

Third Party Compliance with Security Policies Third party consultants, contractors, and vendors are held accountable to the same level of security compliance as Indica Digital employees.

Vendor Risk Management Access to Indica Digital’s information by third parties will be properly controlled and will not be allowed until reviewed and assessed for proper security controls including not limited to consultants, IaaS/PaaS providers, and SaaS applications. Where there is a business need for third party access, a risk assessment is required to determine security implications and control requirements. Controls must be agreed upon and defined in a contract with the third party.

This policy will not be interpreted or enforced in violation of federal labor law, and does not prohibit protected conduct or communications relating to employee wages, hours or working conditions, or any other conduct protected by Section 7 of the National Labor Relations Act.