SINCLAIR BROADCAST GROUP, INC. AND SUBSIDIARIES EMPLOYEE HANDBOOK SINCLAIR BROADCAST GROUP TABLE OF CONTENTS WELCOME VISION-MISSION-VALUES INTRODUCTION EMPLOYMENT POLICIES AND PROCEDURES Equal Employment Opportunity . knmigration Law Compl'anco Hiring" Employee Full-time, Part-time, and Temporary Employees Introductory Period. PIinc .. Personal Appearance/Dress Code Change In . Attendance and Work Week and TImokeepIng Compensatory Time Break Policy Conductof Employees Build?ng Access and Visitors Dnver Safety and Company voh'cle Policy No Harassment Policy Open DoorIlGriovance Policy .. Con?ictof Interest/Outside Employment Affairs Buying Company Siock/InsiderTrading: Ethics andWhistIebIower Policies. 13 Telephone anti Mail 13 Computer. EmaIIandInternotUso 13 Social 15 Performance Evaluations. 16 17 Personnel Records .. 17 Compensation and Bonuses 17 Employee 18 EmploymentofRelatIves 19 BENEFITS Health Bene?ts (MedIcaI/DentaWIsIon Plans). 19 Short-Term Income Insurance 20 Maternity Leave for Full-Time Employees 21 Parental Leave for Full-Time Empioyeos21 Long-Term Disabiity Income Insurance21 Life Insurance? 22 Smplernontal Lifo Insurance 22 EmpioyeeAssistance Program 22 Workers' Cornponsation Insurance22 Vacationsfor Full-Time Empbyees22 Personal Time Off for Full-Time Employees Holidays. Sick Leave for? Full-time Employees Bereavement Leave Policy Jury Duty Leave? Family Medical Leave Act Military Medical Leave of Absence Personal Leave of Absence? Vacation Accruals and Holidays During Leave Retirement Plan.. ReImbursemenIoITuII66 Expenses I6I 66.6 Employee Stock Purchase . .. Welcome! it is our pleasure to welcome you to the Sinclair Broadcast Group We firmly believe that our employees are our most valuable resource and the contribution of each individual is critically important to our overall success. We are committed to creating and maintaining an environment where employees are able to realize their maximum potential while contributing to the working efficiency and long-term growth of Sinclair. Our goal is to make an outstanding and on-golng contribution to each community we serve so that our stations become leading forces in their markets. This can only be achieved if each and every one of us is entirely dedicated to the highest standards of excellence in all we do. We wish you success in your position and know that you will quickly come to share the pride we have in our stations and the Sinclair team. David Smith Rob Smith David Amy Fred Smith Duncan Smith Chris Ripley Sinclair?s Vision-Mission-Values VISION Connecting People with Content Everywhere. MISSION We create. innovate and lead for the benefit of everyone. We deliver mu st-have content across all platforms and all devices. We attract and retain the best employees. VALUES Love what you do. Be Inspirational Be Communicative Be part of something important Make a di?erenoe Live what you do. Be a person of integrity Be customer focused Be transparent Drive results Embrace what you do. Be forward thinking Be adaptive Be a strategic thinker Challenge the status quo INTRODUCTION This Handbook contains a general outline of the policies and practices of Shclair Broadcast Group. Inc. and all subsidiary organizations (referred to as the "Company" or?Sinchir') and is intended to provide information about working conditions, benefits, and policies affecting your employment It is expected that all employees will read, understand, and comply with all provisions of this Handbook. This Hancbook should answer questions most frequently raised by employees regarding general Company practices; however. this Hancbook does not attempt to anticipate every situation. question. or circumstance, which may arise. For employees whose employment is covered by a collective bargaining agreement or other employment agreement. in the event of any conflict between the provisions ofthis Hancbook and that agreement, the agreement will prevail. While it is Sinclair's intent to conform to every federal, state and local law, the Company operates in many states and it is difficult to specifically address the impact of each state's employment laws. Should there be a con?ict between any of the terms of this Handbook and any local, state or federal law. the applicable local, state or federal law will supersede the applicable provision of this Hand book only to the extent necessary to bring this Handbook into conformity or compliance with the applicable law. This Handaook is not intended to and does not set forth express or 'mplied contractual obligations of the Company of any kind. to include continued employment or employment for a specified period of time. The Company reserves the right to modify. revoke. suspend, brminate, or change any or all of the provisions of the Handbook or any plans. policies benefits, or procedures referred to, in whole or in part, at any time. with orwithout notice. The language in this Handbook is not intended to create. nor is it to be construed to constitute. a contract between the Company and any one or all of its employees. The contents of this Handaook are guidelines only; situations that arise vary too widely for policies to be definitive ?n every circumstance. If you have any questions concerning Company policy, or any provision of this Hancbook. please consult your station HR representative, or contact corporab HR. No one is authorized to commit the Company any obligations pertaining to compensation, benefits. term of employment. or any other action with ?nancial rami?cations except the CEO or Chairman by instrument in writing. Please understand that a good employee hanmcok is revised as a company and its environment grows and changes. This isa revised Hancbook (3/30/2018) and supersedes any and all previous employee handbooks. which shall no longer 399W- COMPANY POLICIES AND PROCEDURES Egual Emgoment Opmrtunlty The Company adheres to the EEO Plan, as wproved by the Federal Communications Commission. It is the policy of Sinclair that employment decisions will be based on such factors as merit, quailications, competence, and the needs of the Company. Employment practices will not be in?uenced or affected by virtue of an wplicant?s or employee's race, color, creed, religion, sex, national origin, age, disability, handicap, genetic information or any other characbristic protected by law. This policy applies to all personnel actions including recruitment, evaluation. selection. placement. promotion, assignment. transfer, compensation. training, leave approval, termination. and other terms and conditions of employment Sinclair supports and has a commitment to the principles of equal employment opportunity and therefore intends to provide an environment that is free from unlawful discrimination or harassment of any kind. All employees are expected conduct themselves in accordance with this policy. Any incident or situation that you believe involves discrimination or harassment should be brought to the attention of your Department Head, General Manager and/or Corporate Human Resources (please refer to the section titled Open Door Procedure). The Company will investigate allegations of discrimination or harassment as con?dentially as possible under the circumstances. Any manager or employee who is deermined by the Company to have engaged in such discrimination or harassment will be stbject to disc'plinary action up to and including discharge. Retaliation in any form against an employee who cornpiains of discrimination or harassment is strictly prohibibd and will itself result in disciplinary action up to and including discharge. Americans with Disabilities Act Sinclair will abide by the Americans with Disabilities Act and applicable amendments and prohibits discrim? nation in its employment practices against individuals with disabilities, who, with or without reasonable accommodation, can perform the functions of the position held or sought. When requested. it is the Company's policy to provide reasonable accommodations forthe known physical or mental limitation of an otherwise qualified individual with a disability unless the accommodation would pose an undue hardship on the operation of the Company or the individual poses a threat the health or safety of himself/herself or others and a reasonable accommodation cannot eliminate the risk. Immigration Law Compliance Sinclair complies with the Immigration Reform and Control Act of 1986 and is committed to employ'ng only United States clizens and aliens who are authorized to work in the United States. As a condition of employment, each new employee must properly complete, sign and date the first section of the US. Citizenship and Immigration Services Form l-9 on the first day of employment and provide appropriae evidence of identity and employment authorization within three business days. Rehired employees also must complete the form if they have not previously ?led an I-9 with the Company, if that previous l-9 is more than three (3) years old. or iftheir previous l-9 is no longer valid. Employment at Will it is the policy of the Company that no employee will have any contract of employment with the Company for any speci?ed period of time or for any particular terms or conditions unless in writing and by the CEO or Chairman. This Hancbook does not constitute an express or implied contract of employment The Company reserves the right to change any terms and conditions of employment at any time. The Company recognizes each employee?s right to brminate his or her employment at any time. and the Company retains a s?milar right. Hiring Sinclair is committed to employing. in its judgment, the best quali?ed candidates for approved positions while engaging in recruitment and selection practices that are in compliance with all applicdale employment laws. Prior to hire, candidates must accurately complete an employment application and other hiring related documents and successfully compleb pro-employment processes. including reference check. drug bsting and background check. Employee Supervision it is the policy of the Company that the work of all employees will be assigned, directed, and reviewed by supervisory personnel (generally a Department Head). Your supervisor has accepted the responsibility of guiding you 'n the completion of your work and needs to hear your suggestions, questions. and constructive ideas. Good communication and mutual understanding are essential to performing your best. If you have questions regarding any aspect of your assignments, or any policy or practice of the Company, please consult your Supervisor, Department Head or General Manager. Exemptand Non-Exempt Employees The Fair Labor Standards Act is a federal law which provides minimum standards for wage and overtime entitlement and spells out how work time must be compensated. Exempt or non-exempt classifications are based upon speci?c job duties. Each employee is designated as either ?non-exempt? or ?exemp from federal and state wage and hour laws. It is our policy to comply with all requirements of the FLSA and applibi state laws. Non-exempt employees are entitled to receive overtime pay under speci?c provisions of the law. Overtime pay is defined as time and one-halfthe regular rate of pay for all hours worked over forty (40) hours in a workweek. Exempt employees are those whose job assignments meet the legal requirements for overtime exemption not eligble for overt'me pay). Exempt employees who are paid on a salary basis normally must receive their full salary for any week in which they perform work Although, deductions from pay are permissible in some circumstances, the Company prohibits managers from making improper deductions from the salaries of exempt employees. If you beieve an improper deduction has been made to your salary, you should immediately report this information to your Department Head, General Manager or Human Resources (see Open Door Policy). Each non-exempt or exempt employee will also be categorized as full-time, part-time, or temporary. Full-Time, Part-Time and Temporary Employees it is the intent of Sinclair to clarify the de?nitions of employment categories so that employees understand their employment status and bene?t eligibility. A full-time employee is defined as an employee who works on average thirty (30) or more hours each week and is assigned to a regular work schedule. A part-time employee is an individual who is hired for an unspecified period. but who works on average less than thirty (30) hours per week. A temporary employee is an individual who is hired full- time or part-time fora limited period or for completion of a specific project or on a casual. irregularfiIl-in basis. Temporary and part-time employees are not eligible for the same bene?ts as provided to full-time employees. Part-time and bmporary employees are eigible participab in the 401(k) Plan and receive all legally mandated benefits, such as Workers' Compensation and Social Security bene?ts. Additionally, part-time employees (but not temporary employees) are eligble to participate in the Employee Stock Purchase Plan. it is the practice of the Company to supplement the regularfull-t'me work force with temporary or part-time employees when necessitated by periods of peak workload. employee absences (eg. due to holidays or vacation). orother situations as may be determined by the Company. An employee whose status changes from part-time or temporary to full-time will be eligible for benefits the ?rst of the pay period after seventy-five (75) days of full-time employment. Time worked by an employee in a temporary or part-time status will not be credited toward years of service with the Company for bene?t determination purposes. If a part-tine ortemporary employee has been employed by the Company for one (1) continuous year, then the benefit waiting period may be waived at the discretion of the General Manager and the employee will be eligble for benefits when changed to ful-time. Employees who leave the employ of the Company and retum must ful?ll the benefit waiting period requirement following their return, even ifthey had previously ful?lled this requirement during their prior employment. However, if an employee was eligible to participate in orwas participating in the 401(k) and/or the Employee Stock Purchase Plan prior to leaving the Company, the employee will be eligible to re-enroll without completing the benefit waiting period. Employees will receive credit for service with the Company in regards vesting requirements. If a full-time Empbyee is re-hired within six (6) months of the Employees' brmination date due a lay-off, the bene?t waiting period may be waived at the discretion ofthe General Manager. The employment relationship between the Company and each part-time, temporary, or full-time employee is at the will of either party (other than employees working under either a hbor contract or a personal contract, contract employees), and may be terminated by either party at any time. Introductory Period it is the policy of the Company that all new employees and re-hires serve an introductory period of ninety (90) days. This is an opportunity for new employees become familiar with Sinclair and their new job and for the Company initially evaluate the employee's performance and ability to aqust to the new environment. Upon completion of the ninety (90) day introductory period, the Company may extend the introductory period up to an additional ninety (90) days. The decision to extend the introductory period '5 at the discretion of the Company. Introductory employees will be paid for any Company observed holidays which occur during the period; however. reimbursement for these days may be withheld from the employee's last check it the event of termination of employment before completion of the 'ntroducbry period. Completion of the introductory period does not entile an employee to remain employed with the Company. Both the employee and Sinclairare free, at any time. with or without advance notice and with or without cause. to end the employment relationship for any reason at any time during or alter completion of the introductory period. Employees who transfer. are promoted. or are reassigned to other positions within the Company wil not be required to serve any introductory time in the new position. However. at the discretion of the Department Head, if the position a currentemployee 's changing is sibstantially different from the one previously heki receptionist sales assistant, or non-supervisory to supervisory). the change can be made conditional won successful completion of a ninety (90) day trial period in the new position. At the completion or any time during the trial period. the employee may or may not be retained 'n the new position. Public Relations The success of our Company depends on maintaining a positive image and good communications with the public. Employees are expected to treat viewers, customers, and the general ptblic in a respectful, courteous, and polite manner at all times. At times you may have to exercise considerable restraint. as the very nature of our business 'nvites comment and criticism. It is not reasonable to believe that our audience or clients will always be pleased with our programming or services. in dealing with the pric, all employees will do their utmost to remain cordial under all circumstances and maintain a spirit of helpfulness and consideration. Complaints and criticisms may be forwarded to your Department Head or General Manager. Since clients and visitors may come int) our stations at any time, it is also important that we keep the facilities clean, neat. attractive. and. above all, business-Ike. Maintaining this environment is a full-time responsibility of all employees. Because we are so frequently in the public eye, employment with Sinclair creabs the pobntial for making our personal lives subject to public scrutiny. The Company. therefore. must and does retain the prerogative to take employment action based upon employee conduct both during work time and outside the workplace if. in the Company's sole judgment and discretion, it creates the pobntial for a negative reflection on the Company. Personal Appearance/Dress Code The professional image of each station is enhanced by the appearance as well as the conduct of its employees. Dress. grooming, and personal cleanliness standards contribute to the morale of all employees and affect the 'mage we present to customers and visitors. Each employee is expected to exercise good taste and should wear clothing and footwear acceptable for our business environment. Workplace attire and grooming must be neat. clean and appropriate for the work being performed and the setting in which the work is performed. Dress requirements will vary among different work grows and types of work. Therefore. please dress appropriately for the position, including adhering to any applicable safety standards. Consult your Department Head 3 you have any questions as to what constitutes mpropriate attire. We hope that you will tare pride in the Company and represent it and yourself in the most favorable manner, not only in the work place. but also at Company-related events and activities. Changes in Status Maintaining accurate and current information on employees is vital the Company and ultimably bene?cial for employees. If you change youraddress. home or cellulartelephone number, name, marital status oremergency contact. be sure notify the as soon as possible. Employees can make the necessary changes through The Bridge The Bridge is a cloud-based system that employees will use to do such things as update or view personal information. stbmit time cards, request time off and view pay slips. The Bndge can be accessed from the home page of SinclairNer. Attendance and Ta rdlness All employees are emected to report to work each day, on time as scheduled. When you must be absent for illness or other emergency. you are expected to contact your immediate Supervisor directly with as much advance notice as possible so arrangements can be made to cover your assigned area. Personnel wishing to take persch days or sidt leave (when known) must give their Department Head at least two (2) working days' notice. Punctualiy is essential to the efficient operation of any bushess. Employees are expected I) report to work on time and be prepared to begin working at the beginning of theirscheduled work hours. If you are going to be unavoidably detained and lab for work, phone the station and advise your immediate Supervisor of yourtardiness and expeded time of arrival. Any work time missed may be deducted from gross pay. accounted for in an wpropriate leave category. or made-up during the work week at the discretion of the Department Head. Excessive absences or tardiness will result in disciplinary action up to and including discharge. Snow/Inclement Weather It is the policy of the Company to remain open during most periods of inclement weather. however, where extraordinary c'rcumstances warrant, the General Manager reserves the right to opera? under a modi?ed schedule or with essential stall, approve the use of leave. or in unlikely situations. close the station. As a general guideline, if public transportation systems are running, then a_ll employees are expected to report to work as usual. However. the lack of public transportation does not necessarily mean that employees are not expected to report to work. Final decisions about station operations during inclement weather are ocmmunicabd employees as soon as practical. Please see your Department Head for ?nformation about your station's specific communication procedure in such instances. If an employee is unable to report work due to adverse weather conditions, the employee will not be paid for that the off or the employee will forfeit a personal or vacation day. Employees must call their supervisor to advise if not reporting to work during instances of inclement weather. Final decisions regarding excused and paid absences are at the discretion of the General Manager. Hours of Work It is the potcy of the Company to establish working hours as required by the business of broadcasting, which runs twenty- four (24) hours a day, three hundred sixty-?ve (365) days a year. Employees of the non-broadcasting divisions of the Company are required to work the hours necessary to perform all business goals and obligations of their department The speci?c schedule of hours for employees will be determined by the Department Head to whom they are assigned. Employees will be informed of their daily schedule of hours of work, including meal periods, and any other changes or provisions deemed proper or necessary by the Department Head. Work Week and Timekeeglng The work week is Sunday through Saturday beginning and ending at midnight on Saturday. The normal work day for most full-time employees wil consist of eight (8) hours of work live (5) days a week, with a required daily unpaid meal break of at least one-half M) hour duration. unless operational needs require otherwise. Speci?c work schedules and lunohbreak policy is determined by the station's General Manager. Noneiusmpt employees wil be required to complete an individual electronic time card showing daily hours worked and/or paid time off or other leave taken. Time will cover one (1) work week, and will be oomplebd and certi?ed by the Department Head at the end of the week. Each employee working a full-time. forty (40) hour work week schedule is required to account for at least eight (8) hours each work day with either actual time worked or time deducted from an appropriate leave category. Completed time cards must be submitted in an accurate. timely fashion to ensure proper accounting and payments. Each non-exempt employee must accurately record all regular and overtime hours worked. meal breaks. early or late arrivals. early or late departures and absences. Exempt employees are expecbd to oompleb a time card for any workweek in which paid time off, holidays orother leave is used. Failure to properly submit timeourds is a violation of this policy. Overtime Overtime will be paid consisent with mplicable state and federal wage and hour laws. Employees will be required to work overtime when it is deemed necessary by the Company. Overtime will be assigned by the Department Head to employees in that particular job for which overtime is required. Unless job emergencies or the requirements of the assignment provide othenivise, no employee will be permitted to work overtime without the prior approval of their Department Head. Overtime compensation will only be paid to non-exempt employees who work in excess of forty (40) hours during the work week at one and one-half (1 Va) times their regular hourly rate. unless applicable state or local law requires otherwise. Overtime pay (that is. time and a half) is calculated on any hours worked in excess of forty (40) hours it any one week. If an employee has worked overtime on a particular day or days in a week in which the employee has also taken sick leave. personal leave. etc. and the total number of hours worked in such week will not be in excess of forty (40) hours. then the will not be entitled to overt'me pay. Example: Monday Worked 8 hours Tuesday Worked 10 hours Wednesday Sick Thursday Worked 8 hours Friday Worked 8 hours Total hours worked: 34 - paid at regular rate Sick: 8 - paid at regular rate Compensatory Time The Company does not allow accrual of compensatory time by exempt or non-exempt employees. Pydays All employees are paid on a bi-weekly basis, every other Friday. In the event that a regularly scheduled payday falls on a holiday, employees will receive pay on the last business day before the regularly scheduled payday. A copy of the payroll calendar can be found on SinclairNel. Employees are required to participate in payroll direct deposit, except where prohibited by state and local laws. This means that once you enrol. your pay will be deposited directly into your bank account at your bank'ng institution. Employees enroll in direct deposit electronically by accessing your employee record within The Bridge. Pay slips are available for viewing at any t'me by accessing your employee record within The Bridge. Break Policy Although specific work hours and schedules are determined by the individual Department Head based on department needs. each full-t'me employee's scheduled workday will nomially be for a total of nine (9) hours. which will include eight (8) work hours. and a sixty (60) minub unpaid meal break. In an effort to accommodate the needs and/or wishes of smokers. as well as any non-smoker who may wish to take a s'miar break during the day. the Company offers an alternative option. At the choosing of the employee, and with the prior approval of the employee's smervisor, the employee may elect to take his/her unpaid meal break as one thirty (30) minute break and two fifteen (15) minute breaks. In the event that the employee elects this option, he/she still has an obligation I) provide at least eight (8) hours of actual time worked each workday. No notice or mproval is necessary if the employee does not wish to exercise this break option. Smoking Policy In keeping with Sinclair?s intent to provide a safe and healthy work environment, smoking ('ncluding use of e-cigaretbs) or other use of tobacco is not allowed inside any of the Company's buildings. company vehicles or near any entrances to Company buildings. Conduct of Employees It is the policy of the Company that certain rules and regulations regarding employee behavior are necessary for the efficient operation of the Company and for the bene?t and protection of the rights and safety of all. 1. Such conduct includes: A. Complying with al Company safety and health regulations and all personnel policies; complying with the spirit and letter of the Company's anti-discrimination policies; abiding by all Company policies with respect smoking; wearing clothing deemed wpropriate by the Company for the work being performed; performing assigned tasks efficiently and well; maintaining an orderly and clean work place and work area; and mepow refraining from the use of alcoholic beverages or drugs. other than a drug prescribed by a physician taken consisbnt with the prescription or proper use of over the counbr medication during working hours, 'ncluding meal/break periods. This policy also includes within it the residual effects of alcohol and drugs where they may affect the employee's work performance and/or relationship with co- employees. If an employee has to take medication that may affect fitness for duty. the employee must notify their supervisor and Human Resources Representative. The Company may request a doctor?s statement be obtained by the employee which evaluates the medication with respect to its effect upon the employee?s work performance. 2. Employees will not: A. Possess or use an illegal or controlled sibstance, other than a drug prescribed by a physician. or sell any such sibstance; B. engage in any conduct which could adversely affect the Company's public image or its mission; 5 Q. carry or possess firearms. explosives. or any weapons on Company property or while in the performance of Company duties; be insubordinate. disrespectful. or refuse to follow management's instructions concerning a job-related assault a fellow employee. visitor. or customer. steal, unlawfully possess, misuse, or willfully damage the property of the Company, a client, or another employee's property or be negligent with such property; gamble on Company property, be dishonest. including. but not limited to. falsifying any Company record or report. such as an appication for employment. a production record, sales order, program or operating log, an employee?s time card. or shipping and receiving records: be arrested for a cr'minal act which. in the Compaan judgment, hvolves moral turpitude, as well as an arrest for a felony or theft; fill out or alter another employee's time card or permit another employee to ?ll out or alter your time card; record any aural communication without the express consent of all parties to the conversation; engage in any harassing behavior with regard to sex. marital status. gender orientation. age. race. creed. religion, national origin, physical or mentaldisability. personal appearance, genetic information. veteran status, or any other characbristic protecbd by law, engage in any act of violence. disorderly conduct. or use threaten'ng or abusive language; verbalize. ptblish. or distribub false or maicious stabments concerning the Company, clients. managers. or any employee; misuse d'sability or other insurance or bene?t programs; abuse Company the by loafng. sleeping, conducting personal business, or interfering with another employee's work performance; solicit. promote. or distribute literature in support of any cause or organization during his or her working time or during the working time of the employee(s) to whom such activity is addressed; or violab any Company or building policy. The above lists are illustrative of the types of behavior that is required and/or will not be permitted by an employee. and are not intended to be all-'nclusive. Failire to adhere to and/or with the above requirements will subject the employee to disc'plinary action. up to and including discharge. Building Access and Visitors For the safety of all employees, employees must observe security practices to control access to our facilities. it is expected that: A No v'sitors are permitted in a station without clearance from your Department Head or immediate Supervisor. Inform the reception area of all visitors you may be expecting so they may be properly greeted. AI visiors must use the main entrance, sign in, and are escorted while in the building. All employees report lost/stolen key cards immediably. Never share your access code or lend your key card to anyone. Keep all doors and entrances locked and do not prop doors open. Do not allow a non-employee to follow you into the building or enter the building as you ext. Report any unusual or suspicious behavior to your Department Head immediately. Employees must learn and practice the specific security policies at the'r facility. Additional information can be found within the Employee Safety Program located on SincbirNer. Safety Employees must learn and observe all safety guidel'nes. including the information found within the Employee Safety Program located on SinclairNef. Any work-related accident or unsafe/unhealthy condition should be reported to your Department Head immediately. If a crisis or near crisis stuation arises in one of the stations, use common sense. you do not need to handle it on your own. lrnmediately consult your Department Head. manager on duty, and/or General Manager. Driver Safety and Company Vehicle Policv Employees who drive Company vehicles or drive personal vehicles on Company business must learn and observe this Driver Safety and Company Vehicle Policy. Employees are expecbd to drive in a safe and responsible manner and to maintain a good driving record. To achieve that end. a set of procedures has been established that are to be followed. 1. Procedures for Drivers of Company Vehicles A. The minimum age to drive a company vehicle is 21. Only Sinclair employees or other individuals performing company business are authorized drive company vehicles. Under special circumstances and with the approval of the Group Manager. General Manager. or Business Manager there may be exceptions. B. As a condition of employment. regular drivers of company vehicles and employees driv'ng personal vehicles for company business must have and mainain a valid driver?s license from the state in which their station or work site '3 located or as otherwise permitted by applicable state regulations. Transferred employees must comply with local laws in obtaining a local driver's license. Regular drivers of company vehicles must produce or authorize a review of their driving record and driver license history upon hire and on an annual basis. C. Employees who drive commercial vehicles or who are otherwise subject to separate rules and regulations such as those dictated by state or federal law Department of Transportation requirements) are also expected to adhere to all policies and regulations associated with the appropriate law or regulation that applies. D. Driving privileges will not be granted orwill be suspended ifa?ofthree (3) or more violations and/or preventable accidents have occurred in the past three (3) years in company or personal vehicles. Special Executive Management approval will be required for those drivers exceeding these levels. Management can suspend or revoke driving privileges of company vehicles at any time. E. No employee will be permitted to drive a company vehicle or a personal vehiclefor business purposes if found guilty of the following in the past three (3) years: 0 Driving under the influence Suspended license Revoked license Operating during a period of suspension or revocation Negligent homicide arising out of the use of a motor vehicle (gross negligence) Using a mobr vehicle for the commission of a felony Aggravated assault with a motor vehicle Grand theft - auto Hit and run F. All Employees are expected to follow all driving laws and operate the vehicle in a safe manner at all times, including but not limited b, adherence to posted speed limits and directional signs, use of turn signals. use of mobile phones. and avoidance of confrontational or offensive behavior while driving. Employees should generally refrain from using mobile phones and other mobile devices iPod) when operating a motor vehicle while on company business. particularly in states or other municipal jurisdictions where a hand-free device is stab law or where cell phone use is altogether prohibited. Reading or sending text messages or emails while driving a company vehicle is strictly prohibited. If it necessary to use a device while driving, employees must either safely pull off to the side of the road and stop the vehicle or use a hands-free device. Engaging in other distracted-driving activities including, but not l'mibd to, eating, reading or changing radio stations or music, is strongly discouraged. G. All employees are expected to wear seat belts at all times while in a moving vehicle being used for company business. whether they are the driver or a passenger. Use of alcohol. drugs or other that in any way impair driving ability is prohibited. Employees are emected to report to their supervisor any moving violations and accidents. including those listed it above, received. Employee's assigned Company vehicles are responsble for the proper maintenance and care ofthese vehicles. Proper maintenance schedules must be followed. including regubr oil changes and proper tire care. Drivers are responsible for securing the vehicle assigned. including locking vehicle doors whenever the vehicle is left unattended. All parking tickets. fines associated with violation of toll facility rules or regulations. or citations for moving violations while operating a company vehicle will be the responsibility of the driver. When assignments and time permits. employees must plan their vehicle parking to avoid parking tickets when covering news events. If a company vehicle is used outside of normal bushess hours for personal use. the appropriate guidelines relating to taxation and safety will be in force. Drivers of vehicles authorized to take vehicles home will be charged the daily commuting amount established by IRS guidelines. News department vehicles may not be used for personal use other than for daily commuting. The transport of spouses. famiy members, or friends for personal use is not authorized. News Department employees, when authorized by Abnagement use company vehicles, are expected to maintain photographer/ camera vehicles in a fully operational mode. ready to respond to breaking news. When off-duty. cameras and other equipment should be secured in a safe place. 2. Accidents Involving Company Vehicles A. If an employee is involved in an accident while driving one of the Compaan vehicles. it is mandatory that the police are called to the scene and the police report obtained. A police report is necessary for insurance purposes. The police should be advised that a company vehicle has been involved in an accident and that a police report is required. Whenever possble the accident scene should be photographed or videotaped. Upon returning to the office, the accident should be reported immediably the employee's supervisor so that an accident report can be ?lled out and submitbd our insurance company. In accordance the Drug Free Workplace Policy post-accident testing procedures. the employee is required to submit to a drug I alcohol test immediately or as soon as possible after the accident it reasonable cause exists indicating that the employee may be under the influence of drugs or alcohol. in the Company's judgment. and (1) if the employee caused the accident or contribubd to the accident, and/or (2) if persch injury employees or others which necessitates medical attention; or results in lost work time; and/or (3) if damage to Sinclair property which may be reasonably believed to have a cost of repair of $1,000.00 or more; and/or (4) if reasonable cause exists indicating that the employee may be under the influence of drugs or alcohol and. in the Company's judgment, to have contribubd to the accident; unless prohibin by law. 3. Personal Use of Company Vehicles A. All vehicles provided by the Company will be used for 'qualitied business' purposes. This means that all other usage will be called personal use. The guidelines, as issued by the IRS regarding the use of company vehicles. require that personal use must be included as income to the employee. To determine the amount of benefit to be added to the employee's W-2. the driver must keep track of the information noted below and storm it to the Business Office quarterly by the of April. July. October. and January so the vehicle use can be appropriately taxed. Please use the 'Auto Usage Report? form found on SinclairNet. . Total miles driven Total business miles driven Total commuting miles driven Total personal miles driven Make. model. year of car assigned you If more than one vehicle was assigned to you. information on each vehicle must be submitted. If a vehicle was assigned for less than one year, give the applicable dabs. If this information '3 not provided. the full amount of the lease value of the car as determined by the tables provided by the IRS will be allocated. Federal and state taxes will be due on the amount added to the employee's W-2. FICA taxes will be withheld if income is below the FICA I'mit Persch use will be determined by dividing the total of personal and commuting miles by total miles driven. This facbr vrn'll then be applied against the IRS Lease Table Values. Gasoline reimbursement (at IRS prevailing allowance) wil also be included if applimble. Drivers of news vehicles will be charged the IRS daily commuting amount. 4. Driving Personal Vehicles on Company Business If an employee's duties require driving a vehicle other than a company vehicle. such as a Market'ng Consultant. then the employee will be stbject to Section above. Employees who regularly drive their personal vehicle for company business must produceorauthorize a review of their driving record and driver license history upon hire and may be required to produce or authorize a review of their driv'ng record and driver license history periodically or on an annual basis. Also. those drivers will be required to fumish the following as a condition of employment upon hire and annually thereafbr. . A valid driver?s license . Proof of current personal vehicle insurance If an employee is involved in an accident while driving their personal vehicle on company business. it 's mandatory that the police are called to the scene and the poles report obtained. Whenever possible the accident scene should be photographed or recorded. Upon returning to the office, the accident should be reported immediably to the employee's smervisor. The employee must report insurance claims related the accident to their personal auto insurance carrier. In accordance with the Free Workplace Policy post-accident testing procedures, the employee is required to submit a drug Ialcohol immediately or as soon as possible after the accident ifreasonable cause exists indicating that the employee may be under the influence of drugs or alcohol, 'n the Company's judgment. and (1 if the employee caused the accident or contributed to the accident. and/or (2) if personal injury to employees or others which neoessitabs medical attention; or results in lost work time; and/or (3) if damage to Sinclair property which may be reasonably believed to have a cost of repair of $1,000.00 or more; and/or (4) if reasonable cause exists indicating that the employee may be underthe in?uence of drugs or alcohol and. in the Ccmpany'sjudgment, to have contributed to the accident; unless prohibited by law. mponam Nob: It is not possble to de?ne in advance every possible situation which may cause the Company to revoke or suspend driving privileges and the Company reserves to itself the absolute right to determine in is discretion what condud falls under the provision. Failure to follow procedures may result in disciplinary action. up to and including termination. No Harassment Policy The Company does not tolerate harassment of our job applicants. employees, interns. clients. or visitors. Any form of harassment related to an individual's race. creed. color. sex. religion. national origin. age. citizenship status, disability or handicm. or genetic information is a violation of this policy and will be treated as a disciplinary matter. For these purposes. the term harassment includes. but is not limited to slurs. jokes. other verbal, graphic. or physical conduct relating to an individual's race, creed, color, sex, religion, national origin, age. citizenship status. disability or handicap, genetic information or any other legally protected character'stic. Harassment includes. but is not limited to sexual advances, requests for sexual favors, and other verbal, graphic. or physical conduct of a sexual nature including w'ewing inappropriate sites on the Internet Harassment also includes making submission to or rejection ofsuch conduct the basis of any employment-related decision and includes creating an intimidating. hostile, or offensive working environment by such conduct. Violation of this policy by an employee shal subject that employee to disciplinary action. up to and including 'rnmediate discharge. Employees should not assume that the Company is aware of any harassment. It is each employee's responsibility to report incidents about which the employee receives knowledge. If an employee believes that he or she is be'ng harassed based upon his or her race, creed. color. sex. religion. national origin. age. citizenship status. disability or handicap. genetic information or any other legally protected characteristic the employee should report this immediately his or her Department Head who will investigate the complaint and -9- attempt to resolve the matter. If the employee is not satisfied with the action taken by the Department Head, or if the employee does not believe the matter can be discussed with the Department Head. the employee should bring the complaint to the attention of the General Lhnager, Regional/Group Manager, Vice President of Human Resources, or the Office of the President of the Company (see Open Door Policy section). While compleb con?dentiality cannot be guaranteed, all actions taken to resolve complaints of harassment through internal investigations will be conducted as d'screetw as possible under the circumstances. The employee(s) concerned will be advised of the ?ndings and conclusions of the investigation, if mpropriate. Any Department Head or other employee who is found. after appropriab investigation, to have violated this policy, will be sibject to d'sciplinary action, to and including d'scharge. The Company views it as one of your responsibilities to advise the Company of any situation constituting unlawful harassment, whether you are the victim or a witness. Therefore. no retaliatory measures will be taken against an employee as a result of a complaint. Retaliation in any form against an employee who complains of harassment or provides information about harassment is strictly prohibited and will itself result in disciplinary action up to and including discharge. Any employee who feels he or she has been retaliated against for reporting harassment is responsible for reporting the retaliation to management in the same manner as any other form of harassment should be reported. This policy refers not only supervisor/subordinab actions. but also to actions between co-workers. Harassment of our employees in connection with their work by non-employees may also be a violation of this policy. Any employee who becomes aware of harassment by a non-employee should report such to his or her smervisor. Appropriate action will be taken with respect to violation of this policy by any non-employee. Employees should be aware that all allegations of harassment are taken very seriously and will be investigated. Allegations of harassment can permanently affect an individual's reputation; therefore. any employee making false allegations of harassment or providing false information or withholding material information in connection with any investigation will be subject to disciplinary action. up to and including discharge. Open Door PolicyIGrievance Procedure Sinclair Broadcast Group. Inc. strongly believes in good communication at all levels of the organization. It has been the long-standing policy and tradition of the Company to encourage all employees to share information, ideas. suggestions. problems, and questions. Your station's managers and Department Heads, as well as Corporate Management maintain an Open Door Policy. Problems and misunderstandings can arise in almost any work situation. We endorse the importance of bringing to light. preventing. and seeking early. informal and inbmal resolution of employment-related dispubs. If an employee is dissat'sfied with anything involving his/herjob. believes that he/she is not being treated fairly. does not understand the reasons behind Company actions, or has a question regarding working conditions. they are to discuss their concerns directly and honestly with their Department Head who will take the time to objectively evaluate the issues. Very few problems will remain unsolved after consulting with your Department Head. However, ifyour problem remains unsolved, you are welcome to arrange a meeting with your General Manager. If your issue cannot be resolved at the station level. you may speak with the Regional Manager! Group Manager. If you remain dissatisfied. contact the Senior! Vice President, Human Resources at the Corporab office or Chief Operating Of?cer and explain your concern. If the Senior/Vice President, Human Resources, in consultation with Legal Counsel and/or Corporab Management. cannot provide a result to your sat'efaction, you may contact the Office of the President of the Company directly. Department General Regional/Group SNP Company Head Manager Manager Human Resources President This process is intended to help you bring your concerns to the right people and is expected to result it prompt decisions. If for some reason you are uncomfortable discussing a particular problem with any of the people listed above. you may go directly to the next level. Following this process in good faith will not adversely impact an employee's standing with any member of management or call into question the employee's employment. Sinclair also encourages and welcomes employees' ideas and suggestions. We believe that the person doing the job usually knows the most about it and is in the best position to suggest improvements. Your ideas for improvements and suggestions for reducing costs or operating more profitably are always appreciated. Feel free to use this Open Door policy to share your ideas with your Department Head. Open-Door Feedback Form To support Sinclair's Open Door Policy. an Open Door Policy Submission Form is available on SinclairNer. the Company's intranet sin. To access Sinda'rNet, employees can simply log onto from any computer on the Sinclair Network. A link to access the Open Doorform is on the front page of SinclairNet, or may be accessed by visiting the Human Resources section. The Open Door Policy Submission form may be used for any purpose and may be sent anonymously. Only the information provided by the employee will be sent the Corporab Office. Employees are encouraged utilize the Open Door Submission form to submit ideas. suggestions. comments. and concerns at any time. Additionally. this form has been set up to field employee concerns regarding Sinclair accounting practices, in accordance with the Sarbanes-Oxley Act. Employees utilizing the form for this purpose should know that those concerns directly bypass the Sinclair Corporae Of?ce and route directly a member of our Board. Con?ict of Interests It is the policy of the Company prohbit its employees from engaging in any activity or practice in conflict with the interests of the Company, its customers. or the people it serves. All employees must avoid any actual or potential conflict between their personal interests and the interests of the Company in dealing with fellow employees, other organizations. cients, or individuab seeking to do bushess with the Company. Situations should be avoided where it would be reasonable for an objective observer to believe that the judgment or loyalty of the employee may be adversely affected by his or her own. or a close family member's extemal relationship. This can include arrangements or circumstances which may influence an employee from acting in the best 'nterests of the Company. Some examples of con?icts of interest which should always be avoided are as follows: A. No employee. or member of his/her inmediate family. will accept a gift of more than a bken value service. money, loan or any full-t'me, part-time, or bmporary employment from any organization which does business with the Company, is seeking to do business with the Company. or is a competitor of the Company, unless authorized to do so by the Company. B. No employee or member of his/her ?mmediate famiy may participate in any contest. drawing. or promotion sponsored by the Company solely or 'n association with its advertisers. C. An employee or membersof his/her immediate family may not participate in any 'ndustry audience measurement study. Should you receive a diary or any request from a survey firm Nielsen) to participate in an audience measurement study. please decine. Employees also may not in?uence, either directly or indirectly. a survey participant in his/her responses. D. Serving as a director. officer. partner, consultant. or in a managerial or technical capacity with an outside enterprise which does or is seeking to do business with or is a competibr of the Company. The Company prohibits any employee from accepting or agreeing to accept from any entity. other than Sinclair. any money. service, or other valuable consideration in retum for, or in connection with. the broadcast of any matter over the station. Apart from this Company policy, Section of the Communications Act requires any employee of a radio or blevision station who accepts or agrees I) accept from any person (other than Sinclair) any money. service. or other valuable consideration in retum for. or in connection with, the broadcast of any matter over a station, disclose the Company the fact of acceptance or agreement to accept. Section also requires that this disclosure be made 'n advance of the broadcast in question. The purpose of this disclosure requirement is to enable the Company determine whether a sponsorship identi?cation announcement pursuant to Section 317 of the Communications Act is required to be broadcast as the consequence of an employee's acceptance or agreement to accept consideration for or in connection with the broadcast of any matter over the station. In addition to any action which the Company may take. Section 508(6) of the Communications Act provides that any employee who fails to make the required disclosures shall. for each violation. be fined up to 310.000 or imprisoned up to one year. Outside employment must not conflict in any way with an employee's regular job with the Company. All employees will be subject to the Company's scheduling demands and performance expectations without regard to any 'rnpact from outside employment. The Company reserves the right to decide when outside activities conflict with job performance or Company 'nterests. and may ask the employee to make changes or refrain from it In accordance with applicable SEC rules. the adheres to the Related Person Transaction Policy. which can be found on the intranet. Any actions or conditions in con?ict with the Company's interests will result in disciplinary action up to and including discharge. Employees who are uncertain as to conformity with Company policy should discuss such circumstances with their Department Head or 'mmediab Smervisor. Non -Disclosu relConfidentigI Nature of Company Affai_rs As a publicly traded company, the Company is under statutory and other obligations to probct the confidentiaity of its business affairs. It ?s the policy ofthe Company, therefore, that the bushess affairs of the Company should be discussed with no one outside the organization, except when required it the normal course of business and only to the extent necessary to perform the particular business. The duties performed by you for the Company may place you in a position of trust and con?dence with respect to certain trade secrets and other con?dential and proprietary information relating to the conduct of the Company's business Miich is not generally known to the public. The protection of con?dential information is essent'al the inbrests and success of Sinclair. Such information includes, but is not limibd b, price lists, personnel data, management discussions, considerations, and actions, advertising, marketing and promotional ideas and strategies, contest information, customer lists, financial or securities information, programming (including topics, content, development of program schedules, and the like), pending projects or proposals, rate mrds, technological data, contracts, and research and development strategies. This provision is intended to protect con?dential information of the Company which employees may possess and is not intended to, and does not. restrict any employee, as permitted by federal, state or local labor laws, from discussing his/her terms and conditions of employment with other employees or individuals. An employee must not, while employed or thereafter, directly or indirectly: A. Disclose or fumish any person, firm, agency, corporation, client business, or any confidential information acquired during employment with the Company, except as may be required by law or governmental process; 8. individualy or in conjunction with any other person, firm, agency corporation, client, business, or use or cause to be used any con?dential information in any manner whatsoever, except in the furtherance of the business of the Company, or C. publish, deliver. or commit to such, any copies. disks. recordings, abstracts. or summaries of any ?les. records. conversations, documents, lists, proposals, or contracts, of con?dential information, except to the extent required by the ordinary course of Company business. All confidential infomiation relating the business of the Company, whether prepared by you or otherwise coming in: your possession, will remain the emlusive property of the Company and you agree return to the Company all such information. copies, or extracts immediately upon separat?ng from the Company's employment or at any time the Company requests. An employee's disclosure of con?dential information is prohibited and will not be tolerated, whether or not the employee actually benefits from the disclosed information. The Company has establ'shed procedures with resped to communications between Company personnel and ?nancial securities brokers, members of the press and s'rnilar persons who may from time to time seek information from the Company as such information reflects on the business prospects of the Company. Such persons are referred to as may ammpt to initiate communications by blephone or in writing and may indies? that they are writing a report or article or are generely interested in the Company. They may indicate that they are seeking to "verifY' information from another source either inside or outside the Company. All such inquiries should be addressed substantially as follows: "All such questions are handled by our Investor Relations Department. Please call our Corporab office at 410-568-1500.? If the Analyst persists, the employee should state substantially the following: am not at liberty to discuss Company information outside the Company", and then terminate the conversation. After any such conversation, please contact our Investor Relations Department and supply to them the name of the Analyst and describe the inquiry. Buying and Selling Comgny Stock/Insider Trading Generally speak'ng. Sinclair employees may freely buy and sell Sinclair Broadcast Group, Inc. (Sinclair) stock. However, federal securities laws and Company policy prohibl transactions in any Company stock at a time when you may be in possession of material information about the Company which has not been publicly disclosed. Insider trad?ng prohibis any person from trading on the basis of material, non-public information or tipping such information to others or recommending the purchase or sale of securities. This includes any information which could affect the Compaan stock price. In addition to criminal and civil consequences for individuals who trade on insider information or provide information to others, failure to comply with this policy shall be grounds for dismissal or other disciplinary action. For purposes of this policy, the procedures set forth below mply to all persons who in the course of employment are expected to come into possession of material non-public 'nformation regarding the business of the Company and/or regarding the business of other public companies. Trading by Company insiders, Executives and Corporate personnel of Sinclair Common stock is prohibled thirty (30) days prior and two (2) business days following the actual scheduled date of the public release of quarterly or annual financial infonnation aboutthe No director, officer or employee -12- of Sinclair Broadcast Group. Inc.. or their subsidiaries may trade in Common Stock while actually in possession of material non-public information about the Company. No trade may be made in any publicly traded securities of another corporation while actually in possession of mahrial non-public information ccnceming the issuer thereof. if such information is obtained by virtue of such person's employment or other association with the company. No director, officer or employee of the Company may trade in any interest or position relating the future price of Company securities, such as a put. call. short sale crother derivative, whether or not permission trade is sought from orgranted by a Designated Contact. A full copy of the Policy Memorandum Concerning Securities Trading is available in the Business Office and on the Company?s intranet Ethics and Whistleblower Policies The Board ofDirecbrs of Sinclair has a Code of Bushess Conductand Ethics Code and employees of the Company. This Code ?5 intended to identify the ethical duties and responsibiities of directors and employees. provide guidance and assist them with ethical issues. provide mechanisms to report unethical conduct. and foster a culture of honesty and accountability. Each director and employee must comply with the letbr and spirit of this Code. Section 301 of the Sarbanes-Oidey Act requies the Audit Committee of the Board of Directors of Sinclair to also establish procedures for. the receipt. rebntion. and treatment of complaints received by the Company regarding account'ng. internal accounting controls and auditing matters ("Accounting Matters"); and the submission by of the Company. on a confidential and anonymous basis. of good faith concerns regarding questionable accounting or auditing matters. This procedure only mplies Accounting Matters. All other should be directed through mpropriate channels. A full copy of the Whistieblower Policy for Accounting. Internal Accounting Controls and Auditing Matters and Ethic Policy are presented upon employment and is abo avaidile in the Business Office and on the Company's intranet. Travel Policy Employees who travel in connection with their work must learn and observe the Company's Travel Policy. The travel policy establishes shndards and process related to travel. hotel. and rental car reservations. as well as emense reports. This Policy is avaihble on SinclairNeror may be obtained from the Business Office. Telephones and Mail The telephone is one of the most vital tools we have in our business. Our telephone system must be free from non- essential incom'ng and outgoing calls. It is the polcy of the Company that its blephone facilities will be available during working hours for effective with the Company's customers. business associates. and members of the public. Accordingly. the use of Company facilities for personal calls should be avoided. In like manner. do not have personal mail (electronic or physical) delivered to the station or use Company stationary or mail systems for personal correspondence. COMPUTER. EMAIL, INTERNET. SOCIAL MEDIA AND OTHER ELECTRONIC RESOURCES OWNERSHIPI QSE AND PRIVACY All electronic resources provided by Sinclair are the sole property of the Company. Users should be aware that the data they create on Sinclair's electronic resources remains the property of Sinclair. In general the use of the Ccn'paan electronic resources should be for business-related purposes. serving the interests of Sinclair. its clients. and associated parties in the course of normal operations. Because of the need to protect Sinclair's electronic resources. the Company cannot guarantee that private information stored on any resource belonging to S'nclair will not be accessed or viewed. For security and network maintenance purposes. authorized 'ndividuals within Sinclair may monitor. inbrcept. and review. without further notice. every employee's activities using the Company's electronic resources and communications including but not limibd to email ('nooming and outgoing). voice mail recordings. instant messages. and Inbmet and social media postings and activities. and you consent to such monitoring by your acknowledgment of this Poliqr. This includes any personally owned orthird-party systems intentionally or uninbnticnally connected Sinclair?s networks and systems. including wireless access points. To be very clear. you should not have any expectation of personal privacy in any using Company owned equipment. Please understand that everything you send electronically is recoverable and discoverable material. For instance. if another employee initiates legal proceedings with the Company based on something you said or did. your email correspondence. both Company and personal, can be sibject to discovery. Also. be aware that deletion of electronic -i3- material. such as email and instant messages. does not necessarily remove messages from the system and. they may remain accessible. GENERAL INFORMATION SECURITY REQUIREMENTS Effective information security is a ?team effort' involving the participation and support of all Sinclair employees. contractors. consultants, and others who deal with information and/or information systems. Individuals must exercise appropriate judgment when accessing electronic resources, and make every reasonable effort to protect the confidentiality. integrity. and availability of Sinclair. client. and associated party data. Email. social media. and downloading from the Internetare prime sources of viruses and other malicious software. With this in mud, all employees. contracbrs, consultants, and others using Sinclair electronic resources are required to adhere to the following: . Users are responsible for the security of their user ms and passwords at all times and should not share them with anyone. All user and system account passwords must be changed every ninety (90) days. maintained in a secure manner, and must conform to policy requirements for length, age, hisbry, and complexity. Employees may not use other empbyee passwords or access the systems of other employees. Users should never save or store passwords within applications or web browser sessions. Users must lock or log off of their computer when not actively using it. As an additional security measure. PCs. lmtops. and workstations with'n certain environments may be secured with a password-protected screensaver that l0d