1. Welcome and Purpose of This Handbook

Welcome to EFS Networks, Inc. ("EFS," "the Company," "we," "us," or "our"). This Employee Handbook ("Handbook") is intended to provide employees with general information about the Company's policies, procedures, benefits, and expectations. It applies to all EFS employees, regardless of the state in which they work, including employees based in Florida, Pennsylvania, and New Jersey.

This Handbook is not an employment contract, and it does not create any contractual rights, express or implied. It does not guarantee employment for any specific duration. Except where otherwise required by law, employment with EFS is at-will, as described in Section 2.

The Company reserves the right to interpret, modify, amend, suspend, or eliminate any of the policies, procedures, or benefits described in this Handbook, in whole or in part, at any time, with or without notice, except where restricted by applicable law. Any changes will generally be communicated to employees in writing.

Because employment laws vary by state, certain sections of this Handbook include state-specific notes that apply only to employees who work in that particular state. Where a conflict exists between this Handbook and applicable federal, state, or local law, the law will control.

2. Employment Policies

2.1 At-Will Employment

Unless an employee has a separate written employment agreement signed by an authorized officer of EFS stating otherwise, employment with EFS is at-will. This means that either the employee or the Company may terminate the employment relationship at any time, for any reason or no reason, with or without cause and with or without advance notice, subject to applicable law.

No manager, supervisor, or representative of EFS, other than an authorized officer acting in writing, has the authority to enter into any agreement for employment for a specified period of time, or to make any promises or commitments contrary to the foregoing.

2.2 Equal Employment Opportunity

EFS is an equal opportunity employer and is committed to providing a work environment that is free from discrimination and harassment. EFS makes all employment decisions — including recruitment, hiring, promotion, compensation, training, discipline, and termination — based on qualifications, merit, and business needs, without regard to any legally protected characteristic.

Protected characteristics under this policy include, without limitation: race, color, national origin, ancestry, ethnicity, religion or creed, sex (including pregnancy, childbirth, and related medical conditions), sexual orientation, gender, gender identity or expression, age, disability (physical or mental), genetic information, marital or civil union status, familial status, military or veteran status, domestic violence victim status, atypical hereditary cellular or blood trait, and any other characteristic protected by applicable federal, state, or local law.

This policy applies to all terms and conditions of employment. EFS will comply with the anti-discrimination and anti-harassment laws of Florida, Pennsylvania, and New Jersey, and of any other jurisdiction in which it employs staff, including where such laws provide broader protections than federal law.

3. Anti-Discrimination Policy

EFS strictly prohibits discrimination against any employee, applicant for employment, intern, or contractor on the basis of any protected characteristic identified in Section 2.2. This prohibition applies to every aspect of employment, including but not limited to:

• Recruitment, job postings, and advertising
• Hiring, promotion, and transfer decisions
• Compensation, benefits, and other terms of employment
• Job assignments and scheduling
• Training and professional development opportunities
• Discipline and termination decisions
• Access to facilities, equipment, and Company resources

Discrimination based on a protected characteristic will result in disciplinary action, up to and including termination of employment, regardless of the offending individual's position or tenure with the Company.

3.1 Reasonable Accommodation

EFS will provide reasonable accommodations for qualified individuals with disabilities, for sincerely held religious beliefs and practices, and for other accommodations required by applicable law (including pregnancy-related accommodations under Florida, Pennsylvania, and New Jersey law), absent undue hardship to the Company's operations.

Employees who need an accommodation should contact Human Resources (Evan Solomon) to begin an interactive, individualized discussion about the request. Requests will be handled confidentially to the extent possible and consistent with the Company's need to evaluate and implement the accommodation.

3.2 Genetic Information

Consistent with the federal Genetic Information Nondiscrimination Act (GINA) and applicable state law, EFS does not discriminate against employees or applicants on the basis of genetic information, and does not request or require genetic information except as permitted by law.

4. Anti-Harassment Policy

EFS is committed to maintaining a work environment free from harassment of any kind. This policy applies to all employees, and extends to conduct by supervisors, coworkers, and non-employees (such as clients, vendors, and contractors) who interact with EFS employees in connection with their work.

4.1 What Constitutes Harassment

Harassment is unwelcome conduct based on a protected characteristic (see Section 2.2) that is severe or pervasive enough to create a hostile, intimidating, or offensive work environment, or that is used as the basis for an employment decision (such as hiring, firing, promotion, or compensation). Harassment can be verbal, physical, or visual, and can occur in person, in writing, by phone, or electronically (including email, text message, video calls, and social media).

Examples of prohibited harassment include, but are not limited to:

• Offensive jokes, slurs, epithets, or name-calling based on a protected characteristic
• Unwelcome physical contact, gestures, or invasion of personal space
• Displaying or circulating offensive images, cartoons, or written material
• Mocking, mimicking, or ridiculing a person's accent, religious practice, disability, or other protected trait
• Threats, intimidation, or negative stereotyping based on a protected characteristic

4.2 Sexual Harassment

Sexual harassment is a specific form of prohibited harassment and includes unwelcome sexual advances, requests for sexual favors, and other verbal, visual, or physical conduct of a sexual nature when:

• Submission to the conduct is made, explicitly or implicitly, a term or condition of employment;
• Submission to or rejection of the conduct is used as the basis for an employment decision; or
• The conduct has the purpose or effect of unreasonably interfering with an individual's work performance, or creating an intimidating, hostile, or offensive working environment.

Examples include unwanted sexual advances or propositions, sexually explicit comments or jokes, unwelcome touching, displaying sexually suggestive images, and repeated unwanted requests for dates. Sexual harassment can occur between individuals of the same or different sex, and can be committed by or against any employee regardless of position.

4.3 Harassment Need Not Be Sexual or From a Supervisor

Harassment based on any protected characteristic is prohibited, whether or not it is sexual in nature, and regardless of whether the harasser is a supervisor, a coworker at the same level, a subordinate, or a non-employee such as a client, vendor, or visitor.

4.4 Reporting Harassment or Discrimination

EFS strongly encourages any employee who experiences or witnesses conduct that may violate this policy to report it immediately, using any of the following channels:

• Your direct supervisor;
• Human Resources — Evan Solomon; or
• Any member of EFS management with whom you feel comfortable, including the CEO.

Employees are not required to report to their direct supervisor first, particularly if the supervisor is the individual whose conduct is at issue. Reports may be made verbally or in writing. EFS encourages — but does not require — employees to put complaints in writing to help ensure an accurate and complete record.

EFS will not tolerate retaliation against any employee who, in good faith, reports harassment or discrimination, participates in an investigation, or otherwise opposes conduct they reasonably believe violates this policy. See Section 5 (Anti-Retaliation Policy).

4.5 Investigation Procedure

Upon receiving a report, EFS will promptly undertake a fair, thorough, and impartial investigation. The investigation will generally include:

• Interviewing the complaining employee to understand the nature and scope of the complaint;
• Interviewing the individual(s) accused of the conduct;
• Interviewing relevant witnesses identified during the investigation;
• Reviewing relevant documents, communications, or other evidence;
• Reaching a conclusion based on the evidence gathered, and communicating the outcome, to the extent appropriate, to the complaining employee.

EFS will maintain confidentiality throughout the investigation to the extent possible, sharing information only with those who have a legitimate need to know in order to investigate and resolve the complaint, comply with legal obligations, or take corrective action.

4.6 Corrective Action

If an investigation determines that this policy has been violated, EFS will take prompt and appropriate corrective action, which may include coaching, a formal warning, required training, demotion, suspension, or termination of employment, depending on the severity and circumstances of the violation. Where the offending conduct involves a non-employee (such as a vendor or client representative), EFS will take appropriate action within its control, which may include restricting that individual's access to the workplace or terminating the business relationship.

5. Anti-Retaliation Policy

EFS strictly prohibits retaliation against any employee for:

• Reporting, in good faith, suspected discrimination, harassment, or other violations of this Handbook or the law;
• Filing a complaint with a government agency (such as the EEOC, Florida Commission on Human Relations, Pennsylvania Human Relations Commission, or New Jersey Division on Civil Rights);
• Participating in an internal or external investigation, hearing, or proceeding;
• Opposing any practice made unlawful by this Handbook or applicable employment law;
• Requesting or using a legally protected accommodation or leave of absence.

Retaliation includes any adverse action taken because an individual engaged in a protected activity described above — for example, termination, demotion, unfavorable reassignment, denial of a benefit, or a significant change in job duties. Retaliation is a serious violation of this Handbook, even if the underlying complaint of discrimination or harassment is ultimately not substantiated, so long as the complaint was made in good faith. Any employee found to have engaged in retaliation will be subject to disciplinary action, up to and including termination.

Employees who believe they have experienced retaliation should report it immediately using the same reporting channels described in Section 4.4.

6. Workplace Conduct and Professional Standards

EFS expects all employees to conduct themselves professionally and respectfully, and to exercise good judgment in the workplace and when representing EFS to clients, partners, and the public (including at AWS, Zoho, and other partner-related events). Examples of conduct that may result in disciplinary action include, without limitation:

• Violation of the Anti-Discrimination or Anti-Harassment policies described above
• Insubordination or refusal to follow reasonable and lawful instructions
• Dishonesty, falsification of Company records, or misrepresentation of information to clients
• Theft, misuse, or unauthorized removal of Company or client property or confidential information
• Possession or use of alcohol or illegal drugs during work hours, or reporting to work under the influence
• Violence, threats of violence, or intimidation of any kind (see Section 10)
• Unauthorized disclosure of confidential Company, client, or partner information
• Conflicts of interest not disclosed to and approved by Company management
• Excessive unexcused absenteeism or tardiness

This list is illustrative, not exhaustive. EFS reserves the right to determine, in its discretion, what conduct warrants discipline and the appropriate level of discipline, up to and including immediate termination, based on the severity of the conduct.

6.1 Progressive Discipline

While EFS remains an at-will employer and reserves the right to terminate employment at any time, the Company generally, but not always, follows a progressive discipline approach that may include verbal counseling, written warnings, performance improvement plans, suspension, and termination. EFS may bypass any step in this process, including proceeding directly to termination, when it determines that the severity of the conduct warrants doing so.

7. Recruitment, Hiring, and Employee Classification

EFS makes hiring decisions based on qualifications, experience, and business need, consistent with the Equal Employment Opportunity policy in Section 2.2. All new employees may be required to complete a background check, reference check, and/or verification of eligibility to work in the United States (Form I-9), consistent with applicable law.

7.1 Employee Classifications

• Full-Time Employee: regularly scheduled to work the Company's standard full-time schedule and generally eligible for the Company's standard benefits, subject to plan terms and eligibility waiting periods.
• Part-Time Employee: regularly scheduled to work fewer than the Company's standard full-time hours; benefits eligibility, if any, is described in the applicable benefit plan documents.
• Exempt Employee: not eligible for overtime pay under the federal Fair Labor Standards Act (FLSA) and applicable state law, because the position meets the applicable duties and salary-basis tests.
• Non-Exempt Employee: eligible for overtime pay for hours worked over 40 in a workweek, calculated in accordance with the FLSA and applicable state law.
• Independent Contractor: not an employee of EFS; engaged under a separate written agreement and not covered by this Handbook.

Employees will be informed of their classification at hire and if their classification changes.

8. Compensation and Timekeeping

8.1 Pay Periods and Paydays

EFS pays employees on a regular, recurring schedule as established by the Company and communicated at hire. If a scheduled payday falls on a Company holiday or weekend, employees will generally be paid on the preceding business day.

8.2 Timekeeping

Non-exempt employees are required to accurately record all hours worked, including start and end times and any meal or rest breaks, using the Company's designated timekeeping system. Falsifying time records, or recording time for another employee, is prohibited and may result in disciplinary action, up to and including termination.

8.3 Overtime

Non-exempt employees will be paid overtime at one and one-half times their regular rate of pay for all hours worked over 40 in a workweek, in accordance with the FLSA and applicable state law. All overtime must be approved in advance by a supervisor. Working unapproved overtime may result in disciplinary action, but approved or required overtime hours worked will always be paid as required by law.

8.4 Meal and Rest Breaks

EFS will provide meal and rest breaks in accordance with applicable state law. Neither Florida nor Pennsylvania currently mandates general meal or rest breaks for adult employees under state law (federal law governs whether short breaks, if provided, must be paid); New Jersey likewise does not mandate general meal breaks for most adult employees, though minors are subject to specific break requirements under state law. Employees with questions about break policies should contact Human Resources.

8.5 Expense Reimbursement

Employees who incur reasonable, pre-approved business expenses on behalf of EFS will be reimbursed in accordance with the Company's expense reimbursement procedures. Employees should retain receipts and submit expense reports promptly.

9. Attendance, Punctuality, and Remote Work

Regular attendance and punctuality are important to EFS's ability to serve its clients and partners. Employees are expected to report to work as scheduled and to notify their supervisor as far in advance as possible if they will be late or absent.

Where a role is approved for remote or hybrid work, employees are expected to be available and responsive during agreed working hours, to maintain a secure and professional home working environment, and to protect the confidentiality of Company and client information consistent with Section 11.

10. Health, Safety, and Workplace Violence Prevention

EFS is committed to providing a safe workplace and complies with applicable federal and state occupational safety requirements, including the Occupational Safety and Health Act (OSHA) and corresponding state requirements. Employees should report any unsafe condition, equipment, or practice to their supervisor or Human Resources immediately.

10.1 Workplace Violence Prevention

EFS has zero tolerance for workplace violence, threats of violence, or intimidating behavior. This includes physical altercations, threats (whether direct or implied, verbal or written), intimidation, stalking, or possession of a weapon on Company premises or at Company-sponsored events, except as expressly permitted by law and Company policy. Any employee who becomes aware of a threat or act of violence should report it immediately to Human Resources or, where there is an immediate safety concern, to law enforcement (911) first.

10.2 Drug and Alcohol Policy

Employees are prohibited from possessing, using, or being under the influence of illegal drugs or alcohol during work hours, on Company premises, or while conducting Company business (including client site visits). This policy is not intended to discriminate against individuals in treatment or recovery, or to interfere with an employee's legally protected use of medication prescribed by a licensed healthcare provider, consistent with EFS's reasonable accommodation obligations.

11. Confidentiality, Technology, and Social Media

11.1 Confidential Information

In the course of employment, employees may have access to confidential information belonging to EFS, its clients, or its partners (including AWS, Zoho, and Cetec ERP-related materials), such as client data, pricing, proposals, source code, business strategy, and personnel information. Employees must protect this information both during and after employment, and may not disclose it except as required for legitimate business purposes or as required by law.

11.2 Technology and Electronic Communications

Company-provided technology, including computers, email, and software accounts, is intended primarily for business use. Incidental personal use is generally permitted so long as it does not interfere with job performance, violate this Handbook, or involve inappropriate content. EFS reserves the right to monitor Company systems and accounts to the extent permitted by applicable law.

11.3 Social Media

Employees are personally responsible for the content they publish on personal social media accounts. Employees should not disclose confidential or proprietary Company or client information online, and should make clear that personal opinions expressed online are their own and do not represent EFS. Nothing in this policy is intended to restrict employees' rights to discuss wages, hours, or other terms and conditions of employment as protected by applicable law.

12. Employee Benefits

EFS offers eligible employees a benefits package that may include health insurance, paid time off, and other benefits as described in separate plan documents, which are incorporated by reference and control in the event of any conflict with this Handbook summary. Eligibility, waiting periods, and specific terms are governed by the applicable plan documents and summary plan descriptions, which employees should review carefully and which are available from Human Resources.

12.1 Paid Time Off (PTO)

EFS provides paid time off in accordance with the Company's PTO policy communicated separately to employees. Accrual rates, carryover rules, and payout upon separation (where applicable) are governed by that policy and by applicable state law.

12.2 Holidays

EFS observes a set of paid holidays each year, communicated separately to employees. Eligibility for holiday pay may depend on employee classification and scheduled work status.

13. Leaves of Absence

EFS provides leaves of absence in accordance with applicable federal, state, and local law, and Company policy. Because leave entitlements depend on factors such as employee headcount, length of service, and the state in which the employee works, employees should contact Human Resources as early as possible to determine which leave(s) may apply to their specific situation.

13.1 Family and Medical Leave

The federal Family and Medical Leave Act (FMLA) generally applies only to employers with 50 or more employees within a 75-mile radius, and to employees who meet certain service-hour requirements. Based on EFS's current employee count, the federal FMLA generally does not apply company-wide at this time; EFS will reassess this as the Company's headcount changes.

13.2 Pregnancy, Childbirth, and Related Accommodations

EFS will provide reasonable accommodations related to pregnancy, childbirth, and related medical conditions, and, where legally required, related leave, consistent with the federal Pregnant Workers Fairness Act and applicable Florida, Pennsylvania, and New Jersey law. Employees should contact Human Resources to discuss any needed accommodation or leave.

13.3 Domestic and Sexual Violence Leave

13.4 Jury Duty and Voting Leave

EFS provides leave for jury duty and voting in accordance with the requirements of the state in which the employee works. Employees should provide advance notice and any required documentation (such as a jury summons) to their supervisor and Human Resources.

13.5 Military Leave

EFS complies with the Uniformed Services Employment and Reemployment Rights Act (USERRA) and applicable state law regarding leave, reemployment, and non-discrimination for employees who serve in the uniformed services.

13.6 Other Leave

EFS will comply with any other leave of absence required by applicable federal, state, or local law not specifically enumerated above (including, for example, leave related to organ or bone marrow donation, or civil air patrol service, to the extent applicable). Employees should direct questions about any specific leave situation to Human Resources.

14. Separation of Employment

Employment with EFS may end voluntarily (resignation or retirement) or involuntarily (termination or layoff), consistent with the at-will employment policy in Section 2.1. Employees who resign are asked, but not required, to provide at least two weeks' written notice to allow for an orderly transition.

Upon separation, employees must return all Company property, including laptops, access badges, and any confidential or proprietary materials. Final pay will be issued in accordance with applicable state law governing the timing of final wage payments, which varies among Florida, Pennsylvania, and New Jersey. Continuation of group health coverage, if applicable, will be offered in accordance with COBRA or applicable state mini-COBRA law.

15. General Provisions

15.1 Not a Contract

This Handbook is a summary of Company policies and does not constitute an express or implied contract of employment, and does not guarantee any specific term of employment or any particular benefit or procedure. Nothing in this Handbook alters the at-will nature of employment described in Section 2.1, except as required by a separate written agreement signed by an authorized officer of EFS.

15.2 Handbook Modification

EFS reserves the right to modify, amend, or discontinue any policy in this Handbook at any time, with or without notice, except where a specific advance notice period is required by law. The most current version of this Handbook, as communicated by the Company, controls.

15.3 Questions

Employees with questions about any policy in this Handbook should contact Human Resources (Evan Solomon) or their supervisor.