SAMC Manual

Company Manual

TABLE OF CONTENTS

	TABLE OF CONTENTS ………………………………………………………..		1
I.	INTRODUCTION .................................................................................................		5
II.	EMPLOYMENT POLICIES ...............................................................................		6
	STATEMENT OF PERSONNEL POLICIES ........................................................		6
	EQUAL EMPLOYMENT OPPORTUNITY AND AMERICAN DISABILITY ACT POLICY AND AFFIRMATIVE ACTION POLICY ......................................................................		6
	CATEGORIES OF EMPLOYMENT .....................................................................		7
	A.	Regular Full-Time Employment ..................................................................	7
	B.	Regular Part-Time Employment ..................................................................	7
	C.	Part-Time Employment ................................................................................	7
	D.	Temporary and Seasonal Employment ........................................................	7
	ORIENTATION ......................................................................................................		7
	PROBATIONARY PERIOD OF EMPLOYMENT ...............................................		7
	WORK HOURS ......................................................................................................		8
	EXEMPT AND NON-EXEMPT EMPLOYEES ....................................................		8
	ATTENDANCE AND PUNCTUALITY ...............................................................		8
	TIME RECORDS ....................................................................................................		9
	OVERTIME ............................................................................................................		9
	MEAL PERIODS ....................................................................................................		9
	SALARY PLAN .....................................................................................................		10
	PAY DAY AND METHOD ...................................................................................		10
	PERFORMANCE APPRAISAL .............................................................................		10
	PERSONNEL RECORDS ......................................................................................		11
	PROMOTIONS .......................................................................................................		11
	VACATIONS ..........................................................................................................		11
	A.	Officers .........................................................................................................	11
	B.	Regular Full-Time Employees .....................................................................	11
	C.	Part-Time Employees ...................................................................................	12
	HOLIDAYS ............................................................................................................		12
	LEAVE OF ABSENCE POLICIES ........................................................................		12
	A.	Sick or Personal Day Leave of Absence ......................................................	12
	B.	Excused Absences / Leaves with Pay ..........................................................	13
	LEAVES WITHOUT PAY .....................................................................................		13
	A.	Family and Medical Leave ...........................................................................	13
	B.	Non-Medical Leave of Absence ..................................................................	20
	C.	Military Leave ..............................................................................................	20
	TERMINATION AND RESIGNATION ................................................................		20
	A.	Resignation Notice .......................................................................................	21
	B.	Exit Interview ...............................................................................................	21
III.	GROUP BENEFITS ..............................................................................................		21
	INSURANCE PROGRAMS ...................................................................................		21
	A.	Medical Insurance ........................................................................................	21
	B.	Dental ...........................................................................................................	21
	C.	Continuing Health Care Coverage (COBRA) ..............................................	21
	MORTGAGE SERVICES ......................................................................................		22
	A.	Loans ............................................................................................................	22
	EDUCATION ..........................................................................................................		22
	A.	Education .....................................................................................................	22
	LETTERS OF RECOMMENDATION/REFERENCE LETTERS ........................		22
	PERSONAL APPEARANCE .................................................................................		22
	CONFIDENTIALITY .............................................................................................		23
	OUTSIDE EMPLOYMENT ...................................................................................		23
	EMPLOYMENT OF RELATIVES ........................................................................		23
	SUBSTANCE ABUSE POLICY ............................................................................		23
	SAFETY MEASURES ...........................................................................................		24
	SAFETY AT WORK PREMISES ..........................................................................		24
	WORKPLACE VIOLENCE POLICY ....................................................................		24
	FIRST AID SUPPLIES ...........................................................................................		25
	SECURITY PROCEDURES ..................................................................................		25
	POLICY ON SMOKING ........................................................................................		25
	OUTSIDE ACTIVITIES .........................................................................................		25
	TELEPHONE CALLS ............................................................................................		26
	NO SOLICITATION / NO DISTRIBUTION ........................................................		26
	PERSONAL MAIL .................................................................................................		26
	E-MAIL, VOICE MAIL, AND OTHER MESSAGING SYSTEMS .....................		26
	VISITORS ...............................................................................................................		27
	HOUSEKEEPING ..................................................................................................		27
	CARE OF FACILITIES ..........................................................................................		27
	USE OF COMPUTER SYSTEMS AND SOFTWARE PROGRAMS ..................		27
	INTERNET USE POLICY .....................................................................................		28
	INSPECTIONS .......................................................................................................		30
	PROPERTY OF EMPLOYER ................................................................................		30
	DISCLOSURE OF EMPLOYEE INFORMATION ...............................................		30
	SUGGESTIONS ......................................................................................................		30
	ANTI-HARASSMENT/ANTI-DISCRIMINATION POLICY ..............................		31
	GRIEVANCE PROCEDURE .................................................................................		33
	DISCIPLINARY ACTION .....................................................................................		34
	A.	General Policy ..............................................................................................	34
	B.	Disciplinary Actions ....................................................................................	34
IV.	LOAN FRAUD POLICY DISCLOSURE (L.F.P.D.) AND CODE OF ETHICS …………………………………...........................................		36
	CODE OF ETHICS...............................................................................................		38
	WHAT EMPLOYEES CAN EXPECT FROM THE COMPANY .........................		38
	WHAT THE COMPANY EXPECTS FROM EMPLOYEES ................................		38
	RESPONSIBILITY OF EMPLOYEES TO AVOID POSSIBLE CONFLICTS OF INTEREST ........................................................................................................		39
	OUTSIDE FINANCIAL INTERESTS ...................................................................		39
	GIFTS ......................................................................................................................		40
	LOANS ....................................................................................................................		40
	PRIVACY RIGHTS ................................................................................................		40
	RESPONSIBILITY IN THE MARKET PLACE ...................................................		40
	CIVIC RESPONSIBILITY .....................................................................................		41
	POLITICAL CONTRIBUTIONS ...........................................................................		41
	IMPLEMENTATION .............................................................................................		41
	RESPONSIBILITY OF EMPLOYEES TO REPORT VIOLATIONS OF THE CODE OF ETHICS ................................................................................................		42
V.	SUPPLEMENTAL CODE OF ETHICS FOR OFFICERS ..............................		42
	INTRODUCTION ...................................................................................................		42
	A.	FIRST STANDARD ....................................................................................	42
	B.	SECOND STANDARD ...............................................................................	43
	C.	THIRD STANDARD ...................................................................................	43
	D.	FOURTH STANDARD ...............................................................................	45
	E.	FIFTH STANDARD ....................................................................................	46
VI.	L.F.P.D. CONTRACTUAL AGGREEMENT/MANUAL AGGREEMENT ..		47
	CONDENSED CODE OF ETHICS/ L.F.P.D. .......................................................		47
	EMPLOYEE MANUAL ACKNOWLEDGMENT FORM ....................................		48

I. INTRODUCTION

Welcome to South Atlantic Mortgage, (herein called S.A.M.C.) You are now a member of a team of dedicated professionals who seek to excel in their careers and make S.A.M.C. a great place to work.

Good communication is essential to creating a positive environment where employees can work together to reach the company’s goals. Therefore, S.A.M.C. encourages all employees to discuss any problems with the appropriate supervisor or the Human Resources Department.

S.A.M.C. aims to serve its community, please its customers, and be a high-performance company. To attain these goals, S.A.M.C. depends on you to conduct yourself in a professional manner. You are expected to perform your duties and carry out your responsibilities with diligence and dedication, and to treat the public and your fellow employees in a friendly, respectful manner. All employees are expected to comply with the laws that govern our business activities, as well as S.A.M.C’s policies, and maintain the highest standards of ethical conduct.

This manual provides only general information about the various regulations and benefits of employment at S.A.M.C. The Manual also summarizes the very detailed plan provisions of the benefits programs. If a difference exists between the material in this Manual and the terms of the official plan documents, the official plan documents will govern.

Nothing in this Manual is intended to create either an express or implied contract of employment for any period of time. Rather, at all times during employment, any employee not having an express, written employment contract retains the right to leave S.A.M.C. at will, and S.A.M.C. retains the right to terminate the employment of any person for any reason that does not violate applicable state or federal law.

Because economic and business conditions frequently change, S.A.M.C. retains the sole discretion to change, amend, or terminate provisions in this Manual.

L.F.P.D. is a contractual agreement and code of ethics. The L.F.P.D. is an agreement entered into by S.A.M.C. and the loan organization, agents, contractors, employees, and third party vendors. This agreement legally binds you to potential consequences that S.A.M.C. reserves the right to pursue under this agreement.

II. EMPLOYMENT POLICIES

STATMENT OF PERSONNEL POLICIES

S.A.M.C. is committed to attracting, retaining, motivating, training, and rewarding the best possible work force. To achieve those goals, S.A.M.C. strives to maintain competitive salary programs, and efficient work environment, and a free flow of communication among all staff members.

EQUAL EMPLOYMENT OPPORTUNITY, AMERICAN DISABILITY ACT (ADA) AND AFFIRMATIVE ACTION POLICY.

S.A.M.C. is an affirmative action employer. It is the policy of S.A.M.C. to promote and assure equal opportunity employment for all current and protective employees without regard to race, creed, color, religion, sex, age, handicap, disability, sexual orientation, marital status, national origin, citizenship status, status as a disabled veteran or veteran of the Vietnam era, or any legally recognized status entitled to protection under stat or federal anti-discrimination laws. This policy governs all matters related to recruitment, advertising, and initial selection or employment. It shall also apply to all other aspects of employment, including, but not limited to, aspects of compensation, promotion, demotion, transfer, lay-offs, terminations, leave of absence, and training opportunities.

If you have any questions about equal employment opportunity, please contact the Human Resources Department.

S.A.M.C. is committed to complying with all applicable provisions and the Americans with Disabilities Act (ADA). It is S.A.M.C.’s policy not to discriminate against any qualified employee or applicant with regard to any terms or conditions of employment because of such individual’s disability. Consistent with this policy of non-discrimination, S.A.M.C. will provide reasonable accommodation to a qualified individual with a disability, providing such accommodation does not constitute an undue hardship to S.A.M.C.

Any employee or job applicant who has questions regarding this policy or believes that he or she has discriminated against based on a disability may notify the Human Resources Department. All such inquiries or complaints will be treated as confidential, and will only be disclosed on a need-to-know basis.

CATEGORIES OF EMPLOYMENT

The following categories of employment are applicable to benefit participation:

A. REGULAR FULL-TIME EMPLOYMENT

A regular full-time employee is any employee who customarily works a thirty (30) hour work-week or more. Such employees may participate in all Group Benefit Programs of S.A.M.C. after meeting the eligibility requirements.

B. REGULAR PART-TIME EMPLOYMENT

Any employee who is customarily employed for less than a thirty (30) hour work-week, but more than a 15-hour work-week is considered a Regular Part-Time employee. These employees are not eligible for participation in Group Benefits.

C. PART-TIME EMPLOYMENT

Any employee who is customarily employed for less than a thirty (30) hour work-week, but more than a 15-hour work-week, after three years of employment with S.A.M.C. is considered a part-time employee. These employees are eligible for participation in Group Benefits. These employees may be eligible for participation in S.A.M.C.’s 401K Plan, if applicable.

D. TEMPORARY AND SEASONAL EMPLOYEMENT

Any employee is employed for a specific period of time or for a special job or project, or on an “on-call basis” is considered a temporary or seasonal employee. Employees in this category are not eligible for participation in any Group Benefits.

ORIENTATION

A new employee will receive an orientation to help insure a complete understanding of the mission, personnel policies and employee benefits, and they will receive a tour of the facility at which they will work.

PROBATIONARY PERIOD OF EMPLOYMENT

The first ninety (90) calendar days of employment is considered a probationary period for all personnel. The probationary period does not change the ability of either S.A.M.C. or the employee to terminate employment with or without any cause, at any time.

WORK HOURS

The S.A.M.C. work-week is forty (40) hours. Non-exempt employees are offered three work schedules:

1. Work 8:30 am to 5:00 p.m. with 60 minutes for lunch.

2. Work 9:00 am to 5:30 p.m. with 60 minutes for lunch.

3. Work 9:00 am to 5:00 p.m. with 30 minutes for lunch.

Certain jobs require special hours. Supervisors will inform employees of their particular schedules. Employees should not report to work areas before their assigned starting times without prior supervisor approval.

EXEMPT AND NON-EXEMPT EMPLOYEES

Your employment with S.A.M.C. will be classified as either “exempt” or “non-exempt”, based on regulations established by the Federal Fair Labor Standards Act. All S.A.M.C. employees are covered by the Act, which requires employers to pay:

One break
The statutory minimum wage for all hours worked up to 40 hours of work per week and;
1 ½ times the employee’s regular pay rate for all hours worked over 40 hours per week.

If you are an exempt position employee, both provisions of the Fair Labor Standards Act apply to you. Your supervisor may request that you work overtime in order to meet the needs of your department. Overtime work must be approved in advance by your supervisor.

ATTENDANCE AND PUNCTUALITY

Employees are expected to be punctual and observe the work hours. Failure to do so may result in disciplinary action.

Employees who are absent due to illness or other legitimate reason should notify their supervisor as early as possible as and certainly no later than their normal reporting time. Employees absent for more than one day should keep their supervisor informed of their situation on at least a daily basis. Absence for three (3) or more consecutive days because of illness may be required to be supported by the attending health care provider’s statement. Employees who are repeatedly late or have excessive unauthorized absences may be subject to disciplinary action and/or termination. If an employee is on authorized Family and Medical Leave Act (“FMLA”) leave, S.A.M.C. will not consider it to be an excessive absence. An unauthorized absence of three (3) or more consecutive days will be considered job abandonment and may be caused for immediate dismissal.

TIME RECORDS

S.A.M.C. is required by law to maintain daily records of all hours worked by non-exempt employees. Accuracy is extremely important in maintaining these records. Therefore, non-exempt staff must record actual hours worked each day and will be paid for those hours only. The record must include the arrival time, departure time, meal breaks of 30 minutes or more, overtime, and time spent away from the job. This record must reflect actual time worked, not a schedule. Any changes made on the time records must be initiated by the employee and supervisor.

Non-exempt employees are not permitted to work without properly “clocking” in and out via the time card or other means provided at your work location. Failure to comply with these regulations may be considered cause for dismissal. An employee signing a time card or “clocking in and out” for another employee will be subject to disciplinary action, up to and including, termination.

OVERTIME

S.A.M.C. seeks to avoid unnecessary overtime through efficient arrangement of schedules and work loads. Compensation for required an authorized overtime hours will be paid to non-exempt employees at the rate of one and one-half (1 1/2 ) times the base hourly rate for work performed in excess of forty (40) hours worked per week. Holidays and paid leave including vacation, jury duty, and other authorized personal leaves with pay are not counted as time worked for purposes of calculating overtime pay.

MEAL PERIODS

All employees are entitled to a sixty (60) minute break per full shift for a meal. S.A.M.C. encourages you to take advantage of these meal breaks whenever possible. Since meal breaks of 30 minutes or more are not part of your working hours, you are not paid for them.

S.A.M.C. is not required to provide breaks throughout the day. Any breaks should be scheduled with your supervisor.
SALARY PLAN

S.A.M.C. regularly participates in salary surveys with comparable businesses in the marketplace to ensure a competitive level of pay for each position. This information is carefully analyzed and used to establish a salary structure. Within this salary structure, positions are grouped according to pay grades, and the value of each position in the pay grades is expressed in terms of salary range. While many of these jobs differ in function, all jobs within a group have similar value to S.A.M.C. for pay purposes. Each salary range has a dollar value expressed as the minimum, midpoint, and maximum.

Salary arrangements are confidential, and employees are expected to respect and maintain this confidentiality. Salary should only be discussed with an employee’s supervisor or the Human Resources Department. Failure to comply with this policy may result in disciplinary action, up to and including termination.

PAY DAY AND METHOD

Employees are paid every two weeks. A statement is delivered each pay period to the employee, itemizing gross pay, tax, deductions and net pay.

PERFORMANCE APPRAISALS

S.A.M.C.’s performance appraisal program is designed to achieve the following results:

To establish performance expectations and standards.
To provide feedback on how the employee is doing; including praise and recognition for jobs well done.
To reinforce and relate the individual’s performance to that of his or her coworkers and department.
To assist the employee in the training and development process for job mastery and potential promotion.
To use job-related criteria for making merit pay increase decisions.
To make a record of discussions concerning job performance problems.

The performance appraisals will be conducted in a non-discriminatory fashion, and to the extent possible, using objective criteria. During the performance review, the supervisor will discuss the employee’s strengths and weaknesses, and identify areas which need improvement. The supervisor will then prepare a written review for the employee to read, provide comments, and sign, indicating that the supervisor has discussed the review with the employee.

S.A.M.C. strives to conduct annual performance appraisals, however, circumstances may occur which causes a review to be held at some other time. S.A.M.C. reserves the right to modify the time frames within which performance reviews will be conducted. You are encouraged to discuss your job and performance with your supervisors at frequent intervals. This policy does not modify an employee’s at-will employment.

PERSONNEL RECORDS

S.A.M.C. will maintain a personnel record for each employee. The Human Resources Department has designated the following class of people who are authorized to maintain, review, or use personnel records: Executive Management. The Human Resources Department retains the right to decide what will be kept in the personnel file.

An employee wishing to review his or her personnel file must make a prior written request to the Human Resources Department. A member of the Human Resources Department will be present when the employee reviews his or her file. No copies may be made of this material, and an employee is not permitted to remove anything from the personnel file. The employee may not review the confidential material.

PROMOTIONS

It is the policy of S.A.M.C. to promote from within whenever possible and practical. Adequate differentials are provided in S.A.M.C. salary grade levels to recognize advancement from one grade to another. The exact amount of salary increase concurrent with a promotion is determined within S.A.M.C.’s guidelines by the employee’s ability to meet the requirements of the higher level position and by the upper and lower limits of the new salary grade.

VACATIONS

Vacation time starts accruing on January 1st every year. Vacations are scheduled each year by the Human Resources Department. Your vacation period eligibility is determined based on your length of service as of January 1st of each year. Two (2) non-consecutive weeks vacation time must be taken each year. Employees who have satisfied all eligibility requirements may submit vacation requests to their supervisors. Requests will be evaluated based upon various factors, including anticipated requirements and staffing considerations during the proposed period of absence. Priority in scheduling vacation time will be based on seniority of title first and time of service second. Officers and employees with seniority must schedule their vacations promptly and go when scheduled. After the vacation schedule has been approved, an employee with less seniority will not be bumped by a senior’s switching vacation time. Vacation time cannot be exchanged for the cash equivalency. After six months of employment vacations must be taken according to the following schedule:

A. OFFICERS

If employed prior to May 1st. ..... 2 weeks

1 to 4 years .................................. 3 weeks

5 years or more ............................ 4 weeks

B. REGULAR FULL-TIME EMPLOYEES

If employed prior to May 1st. ..... 1 week

1 to 4 years .................................. 2 weeks

5 to 10 years ................................ 3 weeks

Over 10 years .............................. 4 weeks

If a paid holiday occurs during vacation period, the employee will be allowed and additional paid day off.

C. PART-TIME EMPLOYEES

Part-time employees, as defined on page 3,C. Part Time Employment, are entitled to vacation time otherwise qualifying in the same manner as full time employees, paid by the average number of hours worked per work week for the previous three (3) months.

HOLIDAYS

S.A.M.C. recognizes certain holidays as determined by the Federal Reserve Bank of Atlanta, Miami Branch.

Regular Full-time employees will receive pay for eight (8) hours.
Part-time employees, as defined on page 3,C. Part Time Employment, will receive prorated pay according to their standard work schedule.
Employees may utilize personal days to observe religious holidays. S.A.M.C. will accommodate an employee’s religious beliefs, if such accommodation is not unduly burdensome.

LEAVE OF ABSENCE POLICY

A. SICK or PERSONAL DAY LEAVE OF ABSENCE

Regular full-time employees and part-time employees, as identified on page 3,C. Part Time Employment, are eligible for paid sick or personal day leave of absence. Paid leave for a personal illness or injury or personal day is authorized for a maximum of six (6) days per calendar year. This policy will be administered in a non-discriminatory manner. Employees accrue sick or personal leave eligibility at one half ( ½ ) day per month. Part-time employees will accrue sick or personal leave days based on the average number of hours of work per week. Employees who take a leave of absence during the probationary period will not be paid. Sick or personal days will be carried over from one year to the next (up to a maximum of 30 days.) This is to help in the event of a short term illness that may force the employee to take an extended sick leave. Unused sick or personal days are not paid at termination of employment.

The employee must provide 30 days advanced written notice to his or her supervisor when the need for leave is foreseeable. If the employee is unable to provide the 30 days notice, the employee must give such notice as soon as is practicable.

The employee is to notify his or her supervisor (or the manager in the supervisor’s absence) by 8:30 a.m. (or the beginning of the regular work schedule, whichever is earlier) of an illness or tardiness.

Upon the employee’s return to work, a Notice of Absence must be completed, signed by the employee and supervisor, and forwarded to the Human Resources Department.

Absence of three (3) or more consecutive days due to serious health condition may be requested to be confirmed in writing by a licensed physician.

Remuneration received from any Group Benefit Plan and/or Worker’s Compensation will be deducted from sick leave pay.

B. EXCUSED ABSENCES/LEAVES WITH PAY

Employees approved for these excused absences/leaves will receive their normal pay during the absence without disruption of benefits or seniority.

Excused absence for death or serious health condition in immediate family.

An excused absence with pay is not granted prior to successful completion of the probationary period. S.A.M.C. will allow the following leave for death in the immediate family:

a. In State – Up to three (3) working days.

b. Out of State – Up to five (5) working days.

For the purpose of this policy, immediate family includes spouse, children, parents, grandparents, or sibling (brother or sister).

Jury Duty.

Employees called for jury duty will receive their salary during the normal period of such duty. After receiving a jury summons, the employee must immediately notify the supervisor and furnish them with a copy of the summons.

Upon returning to work, the employee must provide their supervisor and the Human Resources Department with a copy of the Certificate of Service, which can be obtained from the Clerk of the jury pool. This Certificate should be attached to a notice of absence form signed by the employee and his or her supervisor.

Voting.

S.A.M.C. will allow excused absences, not to exceed two (2) hours, for voting, provided the voting is conducted during regular work time. An employee should request this time from the supervisor prior to Election Day.

LEAVES WITHOUT PAY

A. FAMILY AND MEDICAL LEAVE

INTRODUCTION

This policy is being adopted to comply with the Federal Family and Medical Leave Act of 1993 (FMLA) and the Miami-Dade County Ordinance. This policy governs leave qualifying under FMLA and S.A.M.C.’s other leaves, such as sick leave, vacation leave, short-term disability leave, and personal days. If you are taking leave other than FMLA leave, please review S.A.M.C.’s specific policy on that type of leave.

S.A.M.C. provides unpaid family and medical leave to eligible employees. To the extent permitted by law, FMLA and any family/medical leave provided under state or local law will run concurrently. Any questions not covered by this policy or S.A.M.C.’s other leave policies should be directed to the Human Resources Department.

DEFINITIONS

S.A.M.C. adopts the definitions of FMLA. This policy lists some of the commonly used definitions.

A. “Serious health condition” is defined as an illness, injury, impairment, or physical or mental condition that involves one of the following:

Hospital Care: Inpatient care (i.e. an overnight stay) in a hospital, hospice, or residential medical care facility, including any period of incapacity or subsequent treatment in connection with or consequent to such inpatient care. “Incapacity,” for purposes of FMLA, is defined to mean inability to work, attend school or perform other regular daily activities due to the serious health condition, treatment therefore, or recovery there from.

Absence Plus Treatment: A period of incapacity of more than three consecutive calendar days (including any subsequent treatment or period of incapacity relating to the same condition), that also involves: a) Treatment two or more times by a health care provider, by a nurse or physician’s assistant under direct supervision of a health care provider, or by a provider of health care services (e.g., physical therapist) under order of, or on referral by, a health care provider; or b) Treatment by a health care provider on at least one occasion which results in a regimen of continuing treatment under the supervision of the health care provider.

Pregnancy: Any period of incapacity due to pregnancy, or for prenatal care.

Chronic Conditions requiring Treatments: A chronic condition which: a) Requires periodic visits for treatment by a health care provider, or by a nurse or physician’s assistant under direct supervision of a health care provider; b) Continues over an extended period of time (including recurring episodes of a single underlying condition); and c) May cause episodic rather than a continuing period of incapacity (e.g. asthma, diabetes, epilepsy, etc.)

Permanent/Long-Term Conditions Require Supervision: A period of incapacity which is permanent or long-term due to a condition for which treatment may not be effective. The employee or family member must be under the continuing supervision of, but need not be receiving active treatment by, a health care provider. Examples include Alzheimer’s, a sever stroke, or the terminal stages of a disease.

Multiple Treatments (Non-Chronic Conditions): Any period of absence to receive multiple treatments (including any period of recover there from) by a health care provider or by a provider of health care services under orders of, on referral by, a health care provider, either for restorative surgery after an accident or other injury, or for a condition that would likely result in a period of incapacity of more than three consecutive calendar days in the absence of medical intervention or treatment, such as cancer (chemotherapy, radiation, etc), sever arthritis (physical therapy), and kidney disease (dialysis).

B. “Intermittent Leave” means leave taken in separate periods of time due to a single illness or injury rather than for one continuous period of time, and may include leave of periods from an hour or more to several weeks.

C. “Grandparent” means any grandparent of an employee for whom the employee has assumed primary financial responsibility.

WHO IS ELIGIBLE FOR FMLA LEAVE?

An employee is “eligible” for FMLA leave if he or she has worked for S.A.M.C. for at least one year, for 1,250 hours or more during the previous 12 months, and if there are at least 50 employees within 75 miles of the worksite.

WHEN IS FMLA LEAVE PERMITTED?

An eligible employee may take up to 12 workweeks of unpaid FMLA leave during any 12 month period for one ore more of the following:

The birth and care of the employee’s newborn child.

The placement of a child with the employee for adoption or foster care.

To care for an employee’s immediate family member (i.e. spouse, child, grandparent, or parent of the employee), if such person has a serious health condition.

When a serious health condition makes the employee unable to perform the functions of his or her position.

A. Restrictions on FMLA Leave.

Birth of a Child. An employee cannot take leave for the birth, adoption, or foster care of a child if 12 months have passed since the birth or placement of the child.

Spouses working for S.A.M.C. If both spouses are employed by S.A.M.C. the total amount of FMLA leave to which both are entitled to is limited to 12 workweeks during any 12 month period of FMLA leave is taken under Subsections 1 or 2, above, or to care for a sick parent under Subsection 3.

Computation of the 12-week period.

An eligible employee is entitled to 12 weeks of FMLA leave in a fixed 12 month period. Each time an employee takes FMLA leave, the remaining FMLA leave entitlement would be any balance of the 12 weeks which has not been used during the present 12 months of the calendar year. (The 12 month period in which the 12 weeks of FMLA leave entitlement occurs is based on the calendar year.)

WHAT NOTICE DOES S.A.M.C. REQUIRE?

If the employee’s request for FMLA leave or any other type of leave is based on foreseeable medical treatment or for the birth or placement of foster child, the employee must give at least 30 days’ written notice of his or her intention to take FMLA leave or other leave. If the employee is unable to provide the 30 days’ notice, the employee must give such notice as soon as is practicable. If the medical treatment is foreseeable, the employee must make a reasonable effort to schedule treatment to avoid unduly disrupting S.A.M.C.’s operations, subject to the approval of the health care provider. Employees are also required to give 30 days written notice of their intent to take all other leave, where such leave is foreseeable (e.g. vacation leave). When FMLA leave or any other type of leave is not foreseeable (e.g. sick leave), S.A.M.C. requests that the employee provide notice as soon as is practicable. The employee must advise S.A.M.C. as soon as is practicable (e.g. within 2 business days) if the dates of a scheduled leave change, are extended, or become known if not known initially.

A. Consequences if the Employee Fails to Give S.A.M.C. the Require Notice.

If the employee fails to give timely notice for a foreseeable leave as required by this Section, S.A.M.C. may deny the taking of leave until 30 days after the date the employee provides notice.

PHYSICIAN’S CERTIFICATE

When requesting leave based on the serious health condition of an employee or family member, the employee must give S.A.M.C a physician’s certificate which includes all the information required by FMLA.
S.A.M.C. requires employees to provide a physician’s certificate when taking sick leave in excess of 3 days, short-term disability, workers compensation injury, or when the employee is using vacation leave or a personal day for medical or health reasons.
The employee can obtain the necessary certification form from the Human Resources Department.

A. The Consequences if an Employee Fails to Obtain the Required Certificate.

The employee must give the Human Resources Department a copy of the physician’s certificate 15 calendar days prior to the start of any leave for medical or health reasons, including FMLA leave, or within 15 days after being requested. If the certificate is incomplete, the employee will have a reasonable opportunity to provide the missing information. If the leave is foreseeable and the employee fails to provide the certificate within the required time, the employee will be denied leave until the required certificate is provided. If the leave is unforeseeable, the employee must provide the certificate as soon as is practicable after the leave starts. If an employee never produces the requested medical certification, the leave is not an FMLA-qualifying leave and will be governed by S.A.M.C.’s other leave policies.

B. Additional Medical Opinions

For any leave requiring a physician’s certificate, S.A.M.C. may request the employee to obtain a second medical opinion from a health care provider designated or approved by S.A.M.C. If this second opinion differs from that provided by the employee’s physician, S.A.M.C. may require the opinion of a third health care provider, designated or approved jointly by S.A.M.C. and the employee. The third opinion shall be final and binding. S.A.M.C. will pay for any second or third opinion it requires.

Pending the receipt of the additional opinion, the employee will be considered as provisionally entitled to FMLA. If the additional opinion does not ultimately establish the employee’s entitlement to FMLA leave, the leave will not be considered as FMLA leave and will be treated as unpaid leave under S.A.M.C. leave practices. S.A.M.C. will provide the employee with a copy of the additional opinion, if requested. If S.A.M.C. requires an additional opinion, it will reimburse the employee or family member for any reasonable “out of pocket” travel expenses incurred to obtain the opinion.

C. Recertification Requirements.

While the employee is on FMLA leave or any other type of leave used for medical or health reasons, the employee must obtain recertification of the condition of the employee or family member on reasonable bases. The Human Resources Department will inform the employee how often the recertification must be submitted, depending on the type of leave being taken.

INTERMITTENT OR REDUCED SCHEDULE LEAVE

An employee may not take FMLA leave on an intermittent or reduced schedule bases for the birth or adoption of a child without the prior written approval of S.A.M.C. A pregnant employee may take leave intermittently for prenatal examinations or for her own condition, such as for periods of sever morning sickness. An employee may take FMLA leave on an Intermittent or reduced schedule if medically necessary because of the employee’s or family member’s serious health condition. The reduced leave schedule will not decrease the total amount of FMLA leave available under this policy. For every hour the employee takes on a reduced FMLA leave schedule, an hour will be subtracted from the total number of hours available under this policy.

A. S.A.M.C. May Transfer the Employee to Another Position During an Intermittent or Reduced Schedule Leave.

If an employee requests FMLA leave on an intermittent or reduced schedule because of the employee’s or family member’s serious health condition, and the requested leave is foreseeable because of a planned medical treatment, S.A.M.C. reserves the right to transfer the employee temporarily to an available alternative position that better accommodates recurring FMLA leave. The alternative position will have equivalent pay and benefits as the previous position.

REPORTING TO S.A.M.C. WHILE ON LEAVE

An employee on FMLA leave or any other type of leave for medical or health reasons is required to report on a periodic basis regarding his or her status and intention to return to work. If circumstances change and the employee needs either more or less leave, S.A.M.C. requires that the employee provide S.A.M.C. with reasonable notice (i.e. within 2 business days) of the changed circumstances where foreseeable. The supervisor or Human Resources Department will inform the employee how often the employee must report to S.A.M.C. while on leave.

WHAT RELATIONSHIP DOES FMLA LEAVE HAVE TO PAID LEAVE?

S.A.M.C. requires that the employee substitute any unused, accrued paid vacation, personal, or family leave for FMLA leave taken for the birth or adoption of a child as well as to take care for a seriously ill family member. S.A.M.C. also requires the employee substitute unused, accrued paid vacation, personal, medical, or sick leave for FMLA leave taken because of the serious health condition of the employee or family member. Once S.A.M.C. knows that the leave to be taken is for FMLA purposes, S.A.M.C. will give the employee timely notice as required by FMLA, which will indicate that paid leave will count toward the employee’s FMLA leave.

A. Worker’s Compensation Injury and Substitution of Paid Time Off.

If the employee is injured on the job and the injury qualifies as a serious health condition under FMLA, S.A.M.C. requires that the time off for the worker’s compensation injury can be counted against the employee’s FMLA leave entitlement. Under those circumstances, neither S.A.M.C. nor the employee may substitute accrued paid time off for any portion of the leave.

B. The Effect of the Employee’s Use of S.A.M.C.’s Short-term Disability Plan While the Employee is on the FMLA Leave.

If the employee is eligible for and is using S.A.M.C.’s short-term disability plan for a serious health condition, S.A.M.C. will count the time off taken under the disability plan against the employee’s FMLA entitlement.. Under those circumstances, neither the employee nor S.A.M.C. can substitute accrued paid time off for the short-term disability payments. The employee must comply with the requirements of S.A.M.C.’s short-term disability plan unless the employee elects to use the unpaid FMLA leave or substitute available accrued time off.

INSURANCE BENEFITS WHILE ON FMLA LEAVE

S.A.M.C. will continue to provide health insurance benefits to an employee pursuant to S.A.M.C.’s group health plan while the employee is on FMLA leave. The employee must pay his or her dependent’s premium while on FMLA leave. If FMLA leave is foreseeable, the employee may pre-pay the required premium by withholding this additional amount from his or her paycheck prior to the start of FMLA. Otherwise, the employee must pay the premium on the first day of the month during FMLA leave. If FMLA leave is taken with paid leave, the premiums will be deducted from the employee’s paycheck during FMLA leave. An employee who fails to pay the required premium risks losing health insurance coverage for his or her dependent. S.A.M.C. has chosen to pay the employee’s portion of the premium during FMLA leave. Therefore, the employee is required to repay this amount if the employee does not return to work at the end of FMLA leave period.

ISSUES INVOLVING AN EMPLOYEE RETURNING FROM FMLA LEAVE.

A. Fitness to Return to Duty Certification

To return to work from FMLA leave for the serious health condition of the employee, or form any other type of leave taken for medical or health reasons in excess of 3 days (including but not limited to sick leave, short-term disability, worker’s compensation injury, and vacation or personal days used for medical or health reasons), the employee must provide S.A.M.C. with a physician’s certificate that states that the employee is able to resume work. S.A.M.C. will not require a fitness for duty certification for intermittent leave. If the employee fails to provide such a certificate before the FMLA leave ends, the employee may be terminated.

The employee must pay the cost of obtaining the fitness for duty certification. Further, the employee is not entitled to be paid for the time or travel costs spent to obtain the certification.

B. Can Leave be Designated as FMLA Leave After the Employee Returns to Work?

Generally, S.A.M.C. cannot designate leave as FMLA qualifying after the employee has returned to work from the leave. There are some exceptions. First, if the employee was absent for a FMLA reason and S.A.M.C. did not learn about the reason until the employee returned, S.A.M.C. may promptly (i.e. within 2 business days of the employee’s return to work) designate the leave retroactively with appropriate notice to the employee.

The employee may also request that the completed leave be considered FMLA qualifying after the fact if the employee notifies S.A.M.C. within 2 business days after returning to work. In the absence of such timely notice by the employee, the employee may not subsequently assert FMLA protection of the absence.

D. Certification Required If the Employee is Unable to Return to Work.

An employee failing to return to work at the end of FMLA leave period is responsible for repaying any health insurance premiums paid on his or her behalf during FMLA leave unless the employee does not return to work for a reason other than the continuation, recurrence, or onset of a serious health condition that would entitle the employee to FMLA leave, or other circumstances beyond the employee’s control. If the employee is unable to return to work after a FMLA leave or any other type of leave taken for medical or health reasons because of the continuation, recurrence, or onset of a serious health condition, the employee must provide S.A.M.C. with a medical certification of the employee’s or the family member’s serious health condition. The Human Resources Department will provide the employee with the required form. The employee must pay the cost for obtaining the certificate , and the employee is not entitled to be paid for the time or travel costs spend in acquiring the certification. If the employee is unable to return to work after FMLA leave because of other circumstances beyond the employee’s control, the employee must demonstrate this fact to the Human Resources Department, which will make the final decision concerning repayment of health insurance premium payments.

WHAT RIGHTS DOES AN EMPLOYEE HAVE WHEN HE OR SHE RETURNS TO WORK FROM FMLA LEAVE?

When the employee returns from FMLA leave, he or she will be restored to the position held when FMLA leave started, or to an equivalent position with equivalent benefits, pay, an other terms and conditions of employment. S.A.M.C. will not guarantee reinstatement of a position to an employee on any other type of leave, unless required by law. An employee has no greater right to reinstatement or to other benefits and conditions of employment than if he or she had been continuously employed during FMLA leave.

A. KEY EMPLOYEE EXCEPTION

Salaried eligible employees (who are among the highest paid 10 percent of the employee employed by S.A.M.C. within 75 miles of the facility at which the employees are employed) will not be guaranteed restoration to the position held at the start of FMLA leave or to an equivalent position on the return to work from FMLA leave if restoration would create (1) a substantial and grievous economic injury to S.A.M.C.’s operations, (2) if S.A.M.C. notifies the employee of its intent to deny restoration when S.A.M.C. determines such injury would occur, and (3) if FMLA leave has started prior to S.A.M.C. providing notice under this Section, the employee elects not to return to work.

WHAT HAPPENS IF THE EMPLOYEE FAILS TO RETURN TO WORK FROM FMLA LEAVE?

Failure to return to active employment at the end of FMLA leave period or any other leave period will be regarded as abandonment of the employee’s job.

ADMINISTRATION OF THIS POLICY

An employee on FMLA or any other type of leave may not work at another job during the duration of the leave. An employee must return to work as soon as the condition for which the leave was granted no longer applies or at the end of the authorized leave, which occurs first.

S.A.M.C. will administer this policy in a uniform, nondiscriminatory fashion in accordance with all applicable laws, including but not limited to, the Americans with Disabilities Act.

B. NON-MEDICAL LEAVE OF ABSENCE

Personal Leave is provided for eligible employees for emergency situations other than described elsewhere in this manual. If an emergency situation arises which creates a need for you to be away from work for one month or less, you may request approval for an unpaid personal leave of absence.

Your request for an unpaid non-medical leave must be submitted in writing to your department manager and Human Resources Department, providing complete details of the need for the leave and how long you expect to be away from work. All requests must be approved by the Personnel Committee.

If your leave is approved, your job position will be held open for a four week period, however, you must pay for all employee and dependent benefit costs received by you. If subsequently authorized, your unpaid leave may be extended for a period of up to six months; however, if you are on personal leave for more than one month, your return to work is subject to the availability of an appropriate job opening. At the end of the approved non-medical leave, your job status ends and all benefits cease.

If you take a non-medical leave of absence, eligibility for certain employee benefits may be affected. Please contact the Human Resources Department for additional information.

C. MILITARY LEAVE

Military leave will be granted in accordance with the law. Please contact the Human Resources Department for additional information.

TERMINATION AND RESIGNATION

Severance pay policy, when applicable, consists of one week. S.A.M.C. reserves the right to increase severance pay depending on employee’s length of time with company.

A. RESIGNATION NOTICE

If an employee wishes to resign, a resignation letter should be filed with the supervisor at least two (2) weeks prior to the effective date.

B. EXIT INTERVIEW

All terminating employees (voluntary or involuntary) receive an exit interview conducted by the Human Resources Department or designate. These exit interviews will be scheduled by the Human Resources Department.

The employee is required to turn in his or her Employee Policies Manual, all S.A.M.C. keys, and any other S.A.M.C. property.

III. GROUP BENEFITS

INSURANCE PROGRAMS

S.A.M.C. provides an insurance program to all regular full-time and part-time employees, as defined on page 3, C. Part Time Employment. For regular full-time employees, the coverage begins on the first day of the month following the employee’s probationary period. For part-time employees, the coverage begins on the first day of the month following three (3) years of employment. The following types of insurance coverage are available:

A. MEDICAL INSURANCE

S.A.M.C. pays 80% of the employee insurance premium for a selected type of coverage. Other types of coverage may require an employee contribution. The Dependent coverage premium is payable by the employee in all cases.

B. DENTAL INSURANCE

S.A.M.C. pays the premium for employee dental insurance coverage. The Dependant coverage premium is payable by the employee.

CONTINUING HEALTH CARE COVERAGE (COBRA)

In certain situations, your health coverage may qualify for continuance even though you are no longer with S.A.M.C. For further details regarding continuing or converting your group health insurance benefits, please contact the Human Resources Department.

MORTGAGE SERVICES

A. LOANS

S.A.M.C. offers loans to eligible employees.

The employee must not be under probation or any other type of disciplinary status when requesting a loan through S.A.M.C.

A favorable interest rate may be offered for employee personal loans to those who otherwise qualify for such loans as allowed by law.
All employee loan requests are subject to loan policy manual requirements and underwriting approval.

EDUCATION

A. EDUCATION

Officers and employees are encouraged to develop and maintain a program of study to enlarge their knowledge and skills in industry. S.A.M.C. provides a text book plan through which regular full-time employees are reimbursed for educational costs after the probationary period. Full tuition cost is reimbursed upon successful completion of the course with the student having passed the course with a grade no less than a “C”. All courses taken must pertain to the employee’s position in S.A.M.C. and must be approved by the Human Resources Department prior to employee registration. The course load eligible for tuition refund may not exceed nine (9) credit hours per semester. Reimbursement is limited to the average cost per credit hour charged at Florid International University (FIU).

LETTERS OF RECOMMENDATION / REFERENCE LETTERS

S.A.M.C., as a matter of policy, does not provide letters of recommendation to former employees. However, S.A.M.C. may provide a letter listing dates of employment and job title to those who request such a letter. This is the same information which is provided in answer to reference requests from prospective employers.

PERSONAL APPEARANCE

Departure from conventional business attire or personal grooming is not permitted, regardless of the nature of the job performed.

Male Officers of the company: Shirt, tie, belt, trousers, socks and shoes
All other men: Are to dress as stated above plus a jacket or business suit.
Women: Dress, suit, blouse and skirt, or pant suit and shoes.

A. Every employee has some contact with the public and therefore represents S.A.M.C. in appearance as well as by actions. The properly attired employee helps to create a favorable image for S.A.M.C. Accordingly, personal appearance will be governed by the following standards:

Employees are expected to dress in a manner that is normally acceptable in professional business establishments doing business with the public.

B. Supervisors will enforce this policy in a non-discriminatory manner when and employee’s appearance is unacceptable. In the event of an unacceptable appearance, the supervisor may request that the employee return home to change or take another appropriate corrective action. The employee generally will not be compensated for any such time away from work, and repeated violations of this or take other appropriate corrective action. The employee generally will not be compensated for any such time away from work, and repeated violations of this policy will be cause for disciplinary action.

CONFIDENTIALITY

S.A.M.C. requires employees to maintain strict confidence regarding all of S.A.M.C.’s, customer and/or employee information, records, correspondence and all other related data. Failure to comply with this most important condition of employment is grounds for immediate dismissal and, if appropriate, prosecution by civil or criminal courts.

OUTSIDE EMPLOYMENT

Other jobs outside S.A.M.C. are not permitted, unless approved by S.A.M.C.’s Personnel Committee. Requests must be in writing and must disclose any possible conflict of interest between outside employment and at S.A.M.C. If at any time it is apparent that the performance of an employee is suffering due to the outside employment, S.A.M.C. reserves the right to ask for resignation from the outside position. Failure to comply with these requests will constitute grounds for dismissal.

EMPLOYMENT OF RELATIVES

It is the general policy of S.A.M.C. not to employ relatives of employees unless approved by the Personnel Committee or the Chief Executive Officer.

SUBSTANCE ABUSE POLICY

S.A.M.C. strives to provide a safe work environment, encourages personal health and considers the abuse of drugs or alcohol on the job to be an unsafe and unacceptable practice. Quite simply, our goal is to maintain a work environment that is free from the effects of alcohol and drug abuse. To achieve this goal and is permitted by law, applicants and employees may be required to pass a drug screening test.

S.A.M.C. expects employees to report for work able to perform their duties. An employee found impaired by alcohol or illegal drugs in his or her system, in possession of, using, selling, or trading illegal drugs or alcohol during working hours, may be subject to disciplinary action up to and including termination, in accordance with state and federal law.

SAFETY MEASURES

All employees are expected to cooperate fully in periodic fire drill, evacuation and other safety procedures. All perceived safety hazards are to be reported immediately to the Management..

SAFETY AT WORK PREMISES

Accidents can occur even when safety standards are met. Should an employee be injured on the job, the injury should be reported to his or her immediate supervisor regardless of the assumed extent of the injury. Failure to report the injury may result in loss of workers’ compensation benefits. The employee’s supervisor will assist the employee with obtaining medical treatment. If the supervisor or manager is not available, the employee should contact the Human Resources Department immediately. Employee supervisors and the Human Resources Department are available to answer any questions about Workers’ Compensation.

WORKPLACE VIOLENCE POLICY

Purpose

This policy outlines S.A.M.C.’s policy regarding violence in the workplace and establishes guidelines and expectations regarding minimum standards of conduct in the work environment.

Objectives

The objective is to ensure the highest standard of health and safety for all employees, customers, vendors, dealers, contractors, and the general public, and those acting for them (hereinafter referred to as employees and business partners), and to provide for the efficient and effective operation of S.A.M.C.

Policy

No employees or business partners shall be allowed to harass any other employee or business partner by exhibiting behavior including, but not limited to, the following:

Verbal Harassment: Verbal threats toward persons or property; the use of vulgar or profane language toward others, disparaging or derogatory comments or slurs, offensive sexual flirtations and propositions (as defined by S.A.M.C.’s sexual harassment policy), verbal intimidation, exaggerated criticism, name calling or belittling behavior.

Physical Harassment: Any physical assault such as hitting, pushing, kicking, holding, impeding, or blocking the movement of another person or using, threatening or implying the use of any offensive weapon or any article or object that could be used as such.

Visual Harassment: Derogatory or offensive posters, cartoons, publications or drawings, or items, for example, mentioned in S.A.M.C.’s sexual harassment policy.

Prohibited items on S.A.M.C. property: including parking areas and in S.A.M.C. vehicles: all types of firearms; switchblade or other knives (except small pocket knives); dangerous chemicals; explosives including blasting caps, chains or other items carried or used for the purpose of injuring or intimidating others.

Reporting Workplace Violence

All S.A.M.C. employees are responsible for notifying management of any threats which they have witnessed, received, or have been told that another person has witnessed or received. Even without an actual threat, personnel should alert management to any behavior they have witnessed which they regard as threatening or violent, when that behavior is job-related or might be carried out on an S.A.M.C. controlled site, or is connected to S.A.M.C. equipment. Employees are responsible for making this report regardless of the nature of the relationship between the individual who initiated the threat or threatening behavior

Reporting Procedure

All reports of threats should be made in person or in writing, and reported to an Officer.

FIRST AID SUPPLIES

S.A.M.C.’s first aid supplies are located in the Human Resources Department of the main office. The first aid supplies of all other departments can be found in each department’s respective lunch room.

SECURITY PROCEDURES

All employees are provided with a briefing of the Security Program of S.A.M.C. In summary, this program requires each employee to exercise due caution and responsible judgment in maintaining personal and S.A.M.C. security. Periodic seminars are conducted in security measures and attendance buy all employees is required.

POLICY ON SMOKING

S.A.M.C. is a smoke-free workplace. Smoking is prohibited inside all S.A.M.C. facilities.

OUTSIDE ACTIVITIES

While remaining a nonpartisan organization, S.A.M.C. hopes that each of its employees will participate in worthwhile, civic, charitable, and political affairs.

An employee’s support of a candidate for public office is solely a personal choice. The employee must make clear that he or she does not speak or act for S.A.M.C.

To eliminate the possibility of conflicts of interest between corporate employment and governmental bodies, public activities involving election and/or appointment to public office must be approved by the Board of Directors.

TELEPHONE CALLS

S.A.M.C.’s telephone equipment is provided for the purpose of serving customers. Use of the telephone for personal reasons should be limited.

NO SOLICITATION / NO DISTRIBUTION

Solicitations of any type are not permitted by any employee on S.A.M.C.’s premises during those periods of the day when the employee is engaged in performing his or her work tasks. Anyone who does not so and thereby neglect his or her work or interferes with the work of others will be subject to disciplinary action. Solicitations, as described above, are not permitted at any time on S.A.M.C.’s premises by persons not employed by S.A.M.C.

Distribution of pamphlets, handbills, or other materials by an employee on S.A.M.C. premises is not permitted during those times when an employee is engaged in performing his or her tasks. Nor are they permitted by employees at any time in working areas. Any employee who violates this rule will be subject to disciplinary action. Distributions, as described above, are not permitted at any time on S.A.M.C. premises by persons not employed by S.A.M.C.

S.A.M.C. employees are prohibited from wearing non- S.A.M.C. promotional buttons and insignia during those periods of the day when the employees are engaged in performing their work tasks which require contact with the public.

The only exceptions to the above rules concern certain organizations which, from time to time, may be permitted to conduct fund-raising drives, or other activities on S.A.M.C. premises. Violations of any of the above-described rules will subject an employee to disciplinary action.

PERSONAL MAIL

Employees are not permitted to receive personal mail at S.A.M.C. The mail and postage meter are not be used for an employee’s personal mail.

E-MAIL, VOICE MAIL, AND OTHER MESSAGING SYSTEMS

E-mail, voice mail and other messaging systems are subject to review by authorized information security or other management representatives. In the event that concerns arise about the use of electronic media being in compliance with the law and/or company policy, S.A.M.C. may review E-mail and other online access. Confidentiality or information entrusted to S.A.M.C. is key to the means of private personal communication. E-mail messages are considered to be business records of S.A.M.C. and may be subject to discovery in the event of litigation. The E-mail system may not be used for personal reasons. Please be advised that employees have no reasonable expectation of privacy in any E-mail sent or received on S.A.M.C.’s system.

Employees are not to use unauthorized codes, passwords, or other means to gain access to E-mail belonging to others. Employees shall not disclose their codes or passwords to others, unless requested by their supervisor.

S.A.M.C. policy prohibits the use of S.A.M.C.’s E-mail system for any solicitation, sale or promotion of any goods or services not directly related to, sponsored or approved by S.A.M.C. The E-mail system should not be used by employees to support, promote or identify social or political issues or religious matters.

VISITORS

Due to the confidential nature of S.A.M.C.’s business, personal visits from family and friends are discouraged. Visits are not permitted to restricted work areas. Individuals picking up employees after working hours should remain outside restricted areas.

HOUSEKEEPING

S.A.M.C. strives to maintain a pleasant and comfortable working environment. All employees are expected to keep their work areas as well as the lunch room in a neat, professional and orderly manner.

CARE OF FACILITIES

S.A.M.C. makes large investments in equipment and facilities to provide each employee with the necessary resources to accomplish his or her duties.

It is the responsibility of management and each employee to treat equipment and facilities with respect and care. Neatness and cleanliness are required to maintain these resources in good working condition. Damage or misuse of equipment or facilities will not be tolerated and will result in disciplinary action.

USE OF S.A.M.C.’S COMPUTER SYSTEM AND SOFTWARE PROGRAMS

S.A.M.C.’s computer system and software programs are very costly. The information in the computer systems represents the efforts of many employees and is an important asset of S.A.M.C. In order to protect this valuable information, no employee is allowed to bring to work any computer games, hardware, diskettes or software which are not licensed and registered under S.A.M.C.’s name, or install or otherwise use any such items unless they have been approved in advance, in writing, by the Officer in charge of the Management of Computer systems approval.

The reason for this is simple. Outside programs may contain viruses which can disrupt or destroy our computer system. Even if you are sure that they program you bring does not contain a virus and that it would not damage our computer system, you are not to use any outside program without advance written approval. If software programs are not properly registered, there may be criminal and civil penalties for their use.

No employee is authorized to transfer or remove any information from S.A.M.C.’s computer system without the expressed advance permission of their supervisor.

Some computer programs contain games or programs which are not related to the work of S.A.M.C. These programs are not to be played by any employee at any time during the work day. Only computer programs that are directly related to the work of S.A.M.C. are to be used on company computers. Employees should have no reasonable expectation of privacy concerning any data in the computer system. Furthermore, the system and software is solely the property of S.A.M.C.

Failure to abide by the above request will result in disciplinary action.

INTERNET USE POLICY

INTRODUCTION

This policy governs all employees’ use of S.A.M.C.’s Internet access system.

OTHER POLICIES INCORPORATED

Although the Internet is new technology, it is strictly governed by all S.A.M.C. policies and practices, including the Anti-Harassment Policy. Under no circumstances are sexually oriented, pornographic, or harassing materials to be sent, viewed, or received using S.A.M.C. equipment or facilities at any time. Please see the Human Resources Department if you have questions regarding any policies or practices.

SECURITY AND CONFIDENTIALITY

Internet users will not intentionally seek information on, obtain copies of, or modify files, other data, or passwords belonging to other users, or misrepresent other users on the network. Downloading of software over the network is prohibited. The Management Information System (MIS) Department will provide a safe method for downloading software that will also honor licensing agreements and fees.

Employees are not permitted to install any software on any device connected to S.A.M.C. computers or networks without the express written permission of the director of the MIS Department. All software (or files) must be scanned for computer viruses by an authorized method before being used at work or being installed on S.A.M.C.’s computers or networks. The intentional introduction of a computer virus, Trojan horse, or other malicious codes is strictly prohibited.

Internet users must maintain the security and confidentiality of S.A.M.C. information and personal addresses or phone numbers of S.A.M.C. employees. Unauthorized access to the company’s confidential, financial, strategic information is prohibited.

LIMITATIONS ON PERSONAL USE

Employees may use their Internet facilities for non-business research or browsing during meal time or other breaks, or outside of work hours, provided that they adhere to all S.A.M.C. policies.

LEGAL ISSUES

Internet users are prohibited from transmitting any material or using the Internet in violation of any federal or state law. This includes but is not limited to copyright infringement, discrimination, negative statements regarding other companies or clients, or the communication of unlawful materials. Employees should assume that all communications and information accessible via the network are copyrighted. Plagiarism is prohibited.

S.A.M.C. Internet facilities and computing resources must not be used knowingly to violate the laws and regulations of the United States or any other nation, or the laws and regulations of any state, city, province or other local jurisdiction in any material way. Use of any S.A.M.C. resources for illegal activity is grounds for immediate dismissal, and the company will cooperate with any legitimate law enforcement activity.

PRIVACY

S.A.M.C. has software and systems in place that can monitor and record all Internet usage. Employees should be aware that our security systems are capable of recording (for each and every user) each World Wide Website, each chat, news group or e-mail message, and each file transfer into and out of our Internet networks, and S.A.M.C. reserves the right to do so at any time. No employee has a reasonable expectation of privacy in his or her Internet usage.

S.A.M.C. will periodically access, screen, and disclose use of the Internet system in order to determine whether employees are violating any applicable policies. The MIS Department will review Internet activity and analyze usage patterns, and may choose to publicize this data to assure that S.A.M.C. Internet resources are devoted to maintaining the highest level of productivity. In addition, S.A.M.C. reserves the right to inspect any an all files stored in private areas of our network in order to assure compliance with this policy. Such inspections include material sent over and received from the Internet. Employees have no ownership or privacy expectations regarding such data.

APPROPRIATE COMMUNICATION

Only those employees who are duly authorized to speak to the media, analysts or in public gatherings on behalf of S.A.M.C. may speak/write in the name of S.A.M.C. to any news group or chat room. Other employees may participate in the news groups or chatrooms in the course of business when relevant to their duties, but they do so as individuals speaking only for themselves. Where an individual participant is identified as an employee or agent of S.A.M.C., the employee must refrain from any unauthorized endorsement or appearance of endorsement by S.A.M.C. of any commercial product or service. Only those employees who are authorized to speak to the media, to analysts or in public gatherings on behalf of S.A.M.C. may grant such authority to news group or chat room participants.

VIOLATIONS

Any violation of this policy may be grounds for discipline, up to and including termination. Employees are expected to report any misuse of the Internet, or attempted infiltration by outsiders into the system, to the MIS Department.

The use of S.A.M.C.’s Internet system to commit infractions such as misuse of S.A.M.C. assets or resources, sexual or other harassment, unauthorized public speaking and misappropriation or theft of intellectual property or proprietary information is prohibited.

INSPECTIONS

Employees do not have a reasonable expectation of privacy with respect to personal belongings while on S.A.M.C. premises. Employees may be asked to sign an acknowledgment form, which will be kept in their personnel files, acknowledging that they are subject to searches of their personal property and that they have no reasonable expectation of privacy with respect to personal belongings while on S.A.M.C. property. For security reasons, S.A.M.C. Officers may inspect personal belongings of employees within S.A.M.C. premises.

Each employee agrees, as a condition of continued employment, to allow management to inspect employee personal property on our premises. Any package brought into or taken out of our premises may be inspected. Our premises and equipment, including S.A.M.C. vehicles and desks, are subject to inspection at any time. Refusal to cooperate in an inspection or search will be considered violation of your terms of employment.

PROPERTY OF EMPLOYER

Upon termination of your employment, the employee must surrender to S.A.M.C. any and all material including, but not limited to, drawings, manuals, reports, documents, Rolodex, calendar, original and/or copies of computer software, lists of S.A.M.C.’s vendors and customers, and the like (including all copies thereof), that you have in your possession relating to the business of S.A.M.C. or its affiliates. Your recognize that all such materials are the exclusive property of S.A.M.C. and that you have no right, title, or other interests in or to such materials.

DISCLOSURE OF EMPLOYEE INFORMATION

It is very common practice for prospective employers to attempt to verify prior employment information on candidates for a job. All requests for information about job applicants and current employed, retired or terminated employees must be referred to the Human Resources Department.

SUGGESTIONS

All employees should be constantly alert for more efficient procedures and ways to develop new business and to improve service to our clients by contributing constructive suggestions. Any suggestions should be prepared in written form and submitted to the Human Resources Department.

ANTI-HARASSMENT / ANTI-DISCRIMINATORY POLICY

S.A.M.C. believes that each of us should be able to work in an environment free of discrimination and harassment. To this end, S.A.M.C. prohibits and will not tolerate discrimination or harassment based on any legally protected status, including, but not limited to sex, raced, national origin, or age. Although this policy is primarily directed to sexual harassment, it applies equally to any form of discrimination or harassment based on any legally protected status, including but not limited to sex, race, national origin, or age.

Definition of Sexual Harassment: Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature are considered to be sexual harassment when:

1. Submission to such conduct is made either explicitly or implicitly a term or condition of your employment.

2. submission or rejection to such conduct by you is used as the basis for employment decisions which affect you, or

3. Such conduct has that purpose or the effect of unreasonably interfering with your work performance or creating an intimidating, hostile, or offensive working environment.

Examples: Some of the more common examples of sexual harassment include:

1. repeated, unwelcome, and offensive sexual flirtations, advances, or propositions;

2. continued or repeated verbal abuse of a sexual nature;

3. continued or repeated graphic verbal commentaries about a person’s body;

4. Continued or repeated sexually degrading words about a person or the person’s body.

Sexual harassment is not limited to harassment of women by men. It includes the harassment of men by women and of gender-based harassment of individuals of the same sex as the harasser.

Sexual harassment does not refer to behavior or welcome occasional compliments of a socially acceptable nature. It refers to behavior that is not welcome, that is offensive both objectively and subjectively, that fails to respect the rights of others, that lowers morale, and that interferes with work effectiveness.

S.A.M.C. personnel, including, but not limited to officers, directors, supervisors and managers, do not have the authority to engage in any activity which would constitute harassment, sexual or otherwise. S.A.M.C. will not condone such behavior.

Procedure for Reporting Harassment:

If you believe (or have direct knowledge of such incidents) that you are being harassed by a supervisor, co-worker, outside tradesman, or customer, you should promptly report the incident or incidents to the Human Resources Department. If you do not feel comfortable reporting this matter to the Human Resources Department, you may report directly to the Personnel Committee. If you believe you are being harassed by the department supervisor or other S.A.M.C. executive, officer, or director, you should report the incident or incidents to a senior S.A.M.C. officer you consider appropriate. If you report the incident or incidents in writing, please place the report in a sealed envelope marked “Personal and Confidential.” The following information should be included in the written statement: the date(s) of the incident(s), identity of the alleged harasser, identity of any witnesses, and details about the incident(s).

The S.A.M.C. Investigation:

1. S.A.M.C. will investigate all sexual harassment claims promptly and thoroughly irrespective of the identity of the alleged harasser.

2. S.A.M.C.’s investigation will include, for example, inquiry to the alleged harasser’s identity, the specific conduct complained of, the identity of witnesses, and the number of times the conduct has occurred.

3. S.A.M.C. will conduct confidential interviews of the alleged harasser, the alleged victim, and all witnesses.

4. In determining whether the alleged conduct constitutes sexual harassment, S.A.M.C. will consider the totality of the circumstances, the nature of the harassment, and the context in which the alleged incident or incidents occurred.

5. S.A.M.C. will keep all information concerning the incident or incidents strictly confidential. S.A.M.C. will provide access to and disclose information to only those individuals involved in conducting the investigation and resolving the matter.

6. S.A.M.C. will inform the alleged victim and harasser about the results of the investigations and the steps that S.A.M.C. will be taking in response to the complaint.

7. S.A.M.C. will not use the information against the person who makes a truthful, good faith allegation of harassment. However, because false accusations can seriously affect the lives of innocent people, S.A.M.C. will take disciplinary action if the investigation leads S.A.M.C. to believe that the complaint was false and made in bad faith. This policy is not meant to discourage the reporting of incidents, but to protect those who are innocent of allegations of harassment.

Sanctions:

If the investigation reveals evidence supporting the occurrence of an incident of sexual harassment, S.A.M.C. will take prompt remedial action. S.A.M.C.’s disciplinary action will depend upon the specifics of the case and may range from a warning to termination of employment.

If the investigation fails to disclose sexual harassment conclusively, S.A.M.C. reserves the right to nonetheless take action. Such action may include counseling, a reminder of S.A.M.C. sexual harassment policy, or a written warning to be included in the personnel file. S.A.M.C. will not transfer the alleged victim unless he or she consents to the transfer.

Follow-Up

Once the matter has been resolved, S.A.M.C. will continue to monitor the employees involved to ensure that no future incidents of harassment occur.

S.A.M.C. is dedicated to maintaining a working environment free of discrimination and based on professionalism. We expect that all employees will continue to act responsibly to fulfill S.A.M.C.’s commitment to working in an environment totally free of discrimination. Employee should not hesitate to ask the Human Resources personnel any questions regarding harassment.

GRIEVANCE PROCEDURE

S.A.M.C. has established procedure designed to encourage communication and mitigate dissatisfaction that may arise when an employee does not know or understand the policies or reasoning governing certain decisions.

Employees who feel they have a job related problem, question or complaint must discuss it with their immediate supervisor. Usually, a solution can be found.

If discussion with the supervisor does not resolve the matter, the employee may request the supervisor to relate the information to the next higher level of management. Employees who feel they have not received proper consideration following these channels are encouraged to present their problem to the Human Resources Department.

As to matter of personal or embarrassing nature, such that employees do not want to discuss with their supervisor, they may contact the Human Resources Department.

Whatever the circumstances, employees are discouraged from discussing complaints or problems with other employees who are not in a position to remedy the problem.

DISCIPLINARY ACTION

A. GENERAL POLICY

Disciplinary policies are necessary to provide a basis for the fair treatment of each employee, and as the basis of an equitable relationship between the employee and S.A.M.C.. It is necessary that these policies be applied consistently to each employee without preference or prejudice. S.A.M.C. may change the disciplinary process at any time

B. DISCIPLINARY ACTIONS

Violations of any of the established policies and procedures may result in disciplinary action including dismissal. The nature of the disciplinary action is contingent upon the facts and circumstances of the individual situation. S.A.M.C. and each employee recognize that the employee relationship is for an indefinite period and may be terminated by either party at will.

The following employee actions are, by way of illustration only, some of the events which would result in discipline including dismissal:

1. Refusal or inability to comply with reasonable instructions of supervisors.

2. Refusal to comply with S.A.M.C. rules.

3. Failure to report for duty without a bona fide excuse.

4. Failure to comply with established safety and health rules and sage work procedures.

5. Disorderly conduct on S.A.M.C. premises.

6. Destruction, misuse, or removal of S.A.M.C. property or another employee’s property.

7. Falsification of any S.A.M.C. records, reports, or documents.

8. Reading books, magazines, or newspapers while on duty, except where required in the line of duty.

9. Sleeping on duty.

10. Neglect of duty.

11. Smoking in prohibited areas.

12. Reporting for duty under the influence of alcohol or illegal drugs.

13. Bringing, consuming, possessing, providing, selling or otherwise using alcohol or illegal drugs on S.A.M.C. premises.

14. Dishonesty.

15. Illegal gambling within S.A.M.C. premises.

16. Bringing, discharging, and/or possessing unauthorized firearms or other weapons within S.A.M.C. premises.

17. Giving or taking a bribe of any nature.

18. Being convicted of any crime which S.A.M.C. believes is detrimental to S.A.M.C. and/or its employees.

19. Theft of S.A.M.C.’s property or property of other employees or customers.

20. Excessive tardiness.

21. Insubordination.

22. Excessive unauthorized absenteeism.

23. Leaving work station or work without authorization.

24. Defrauding customers of S.A.M.C.

25. Embezzlement.

26. Disloyalty to S.A.M.C.

If an employee is on authorized Family and Medical Leave Act (“FMLA”) leave, S.A.M.C. will not consider it to be an excessive absence.

When a supervisor determines that an employee’s performance is unsatisfactory, the following disciplinary steps may be taken and S.A.M.C. reserves the right to omit any or all steps in this disciplinary process:

1. The supervisory will first talk to the employee to try to resolve the problem(s).

2. If the problem continues, the supervisor will present the employee a memorandum which states the concerns, date of the first verbal communication, noting that this is the second occurrence, and what corrective action will be taken. This document must be signed by the employee and supervisor. A copy of this document should be sent to the manager of the department and the Human Resources Department.

3. If a third meeting is necessary, documentation is again required, stating the concern, the dates of previous meetings, and the action to be taken. This documentation requires the signatures of the employee and the supervisor, and copies should be distributed to the manager of the department and the Human Resources Department.

4. If the employee is placed on probation, the supervisor and employee should again meet at the end of the probationary period to document the progress, if any. The employee should be advised that reoccurrence of events which initially resulted in probation will be grounds for dismissal.

IV. LOAN FRAUD POLICY DISCLOSURE (L.F.P.D) and CODE OF ETHICS

All Loan Originators, Agents, Contractors, Employees and Third Party Vendors must be aware that S.A.M.C. bears the responsibility for all actions of its Employees, Agents, Contractors, and Vendors. S.A.M.C. is responsible for the content and quality of each loan application that is processed and submitted. Loan Originator, Agent, Contractor, Employee or Vendor personally warrants and represents the truth and accuracy of each and every loan. Loan Originator, Agent, Contractor, Employee or Vendor agrees to reimburse S.A.M.C. for any damages sustained by S.A.M.C. as the result of fraudulent activity. As a Loan Originator, Agents, Contractors, Employees or Vendor of S.A.M.C., you agree to the following Loan Fraud Policy Contract:

1. S.A.M.C. has ZERO TOLERANCE for fraud.

2. Each loan document, is complete and accurate as to all information therein, contains no misleading information, has been prepared and executed and copies delivered by applicable laws or regulations, and all signatures and executed initials therein are authorized and genuine.

3. That for every loan, after following standard practices and procedures prevalent in the mortgage banking/brokering industry, if followed, would have lead to discovery or disclosure, you have no knowledge of any adverse information concerning any Borrower that has not been accurately communicated to the lender, nor has any material fact been omitted or disguised.

4. That neither you, nor the borrower, or any person or entity engaged by S.A.M.C. involved in the loan, including without limitation, any appraiser or credit reporting agency has, to the best of your knowledge, made any false representations or provided information which is not true, complete and accurate.

5. That at the time of loan submission and at the time of closing that to the best of your knowledge, there is no adverse condition that exists relative to the property that would affect its appraised value.

6. That you understand the submission of a loan application containing false information is a crime with severe consequences for you, and for S.A.M.C.

TYPES OF LOAN FRAUD

1. Submission of inaccurate information, including false statements on loan applications, and falsification of documents purporting to substantiate credit, employment, deposit, asset information, personal identity, ownership/non-ownership of real property, etc.

2. Forgery of partially or predominately accurate information.

3. Incorrect statements regarding current occupancy or intent to maintain minimum continuing occupancy as stated in the application or the security instrument.

4. Lack of due diligence by the Loan Officer, Interviewer, Processor, Agent, Contractor, Employee or Vendor including failure to obtain all information required for the application and failure to request further information as dictated by any borrower response to other questions.

5. Non-Disclosure of relevant information, which would materially and adversely affect the value of marketability of the loan on the borrower’s ability to repay the loan.

6. Unquestioned acceptance of information or documentation that is known, should have been known, or should be suspected to be inaccurate.

7. Simultaneous or consecutive processing of multiple owner occupied loans from one applicant supplying different information on each application,.

8. Allowing an applicant or interested third party (Realtor, Builder, Seller, Borrower, etc.) to “assist” with the processing of the loan.

POTENTIAL CONSEQUENCES TO EMPLOYEE

The effects of Loan Fraud are costly to all partied involved S.A.M.C. stands behind the quality of its loan production. Fraudulent loans cannot be sold into the secondary market, and, if sold, will require repurchase by S.A.M.C. Fraudulent loans damage our reputation with our investors and may even cause an investor to terminate an agreement with us. The price is paid by those who participate in Loan Fraud is even more costly. The following is a list a few of the potential consequences, for you personally:

1. Criminal Prosecution

2. Loss of License

3. Loss of access to lenders, mortgage insurance companies, FHA, VA, surety bonding, etc. Industry participants routinely share information about fraudulent activities with each other, Federal Agencies, State authorities, Federal/State law enforcement and private information repositories.

4. Civil action by S.A.M.C., applicant/borrower or other parties to the transaction.

5. Loss of employment.

6. Adverse effect on credit history for outstanding balances on any outstanding fees due to circumstances stated in Number 7 of Potential Consequences to Employees of the L.F.P.D in the Employment Manual.

7. Personally liable for any other fee included in the repurchase, refinance, indemnification, discount, rehabilitation of property, etc., which also includes yield spread premiums paid by S.A.M.C. for the servicing rights of the loans, plus any accrued interest, legal expenses, attorneys’ fees, and other expenses S.A.M.C. may have incurred as a result of the misrepresentation or the breach of the warranty or covenant.

8. S.A.M.C. reserves the right to deduct from your pay commissions on salaries that may be required to pay under this agreement for Fraudulent Loan Accounts.

POTENTIAL CONSEQUENCES TO BORROWER

1. Criminal Prosecution

2. Civil action by S.A.M.C. and/or the lender.

3. Civil action by other parties to the transaction such as the seller or Real Estate Agent.

4. Adverse effects on credit history.

CODE OF ETHICS

This Code of Ethics applies to everyone employed by S.A.M.C. and its subsidiaries. The Code summarizes general policies of S.A.M.C. and provides guidelines for minimal acceptable standards.

WHAT EMPLOYEES CAN EXPECT FROM THE COMPANY

S.A.M.C. strives to treat all employees fairly and maintain its ongoing affirmative action programs. All employees and supervisors are expected to comply fully with these programs.

WHAT THE COMPANY EXPECTS OF THE EMPLOYEES

S.A.M.C. expects conscientious and professional work., as well as high ethical standards from employees. The nature of our business requires special obligations by employees to safeguard integrity. Employees are expected to:

1. Adhere to the spirit and provisions of this Code of Ethics.

2. Avoid illegal conduct in both business and personal matters.

3. Know the contents of the Code of Ethics and observe its letter and spirit at all times. Employees who violate the Code of Ethics may be subject to disciplinary action, including dismissal.

4. Perform work duties in good faith, in the best interests of S.A.M.C. and in a prudent manner. An employee:

a. Should not knowingly delay or neglect any company matter entrusted to him or her, or handle any company matter the employee knows or should know, that he or she is not qualified or authorized to handle.

b. Should not execute any note, contract or other agreement on behalf of S.A.M.C. except as appropriate to the duties of the employee and as authorized by the Charter or Bylaws of S.A.M.C., or by a resolution adopted by The Board of Directors or Committee of the Board.

5. Carefully follow expense account policies and guidelines. Falsification of an expense account constitutes grounds for dismissal.

6. Comply with S.A.M.C.’s stated policies on illegal drug use and alcohol abuse.

RESPONSIBILITY OF EMPLOYEES TO AVOID POSSIBLE CONFLICTS OF INTEREST

Employees must not use their association with S.A.M.C. for personal gain outside authorized compensation. If there should be any question that an activity might violate or appear to violate this Code of Ethics, the employee must seek guidance from appropriate management authority and receive written approval for such action(s). To avoid possible conflicts of interest, employees either directly or indirectly:

1. Shall not purchase or lease assets or property to S.A.M.C. except where no undue advantage arises from association with the company.

2. Shall not take personal advantage of a business opportunity that might be of interest to S.A.M.C. unless details of the opportunity are disclosed and the company elects not to pursue the opportunity.

3. Shall not buy or sell securities, investments or any other property or interest if such action involves the use of information obtained through association with S.A.M.C. and which is not generally available to the public.

4. Shall not participate in or influence the making or approval of any S.A.M.C. credit or business decision if the employee has or may appear to have a material interest in the matter involved.

5. Shall not accept directorships with other profit making corporations without the approval of management. Outside employment or position with other businesses may be accepted only through prior approval.

6. Shall not give legal, tax, or accounting advice to any customer of S.A.M.C. In general, customers should be cautioned to seek legal, tax, and accounting advice from their own advisors.

OUTSIDE FINANCIAL INTERESTS

Employees must exercise extreme caution in representing S.A.M.C. with any person or firm with whom they have a family or financial connection. Transactions with such persons or firms must be handled by a disinterested employee.

GIFTS

Employees may not accept gifts or services values at $250 or more in any calendar year from customers or suppliers of the company. Gifts in any calendar year with a value greater than $250 must be reported to your supervisor.

LOANS

S.A.M.C. endeavors to make loan decisions responsibly and constructively. It will:

1. Seek sound loans which support economic growth.

2. In periods of tight credit, give preference to customers whose relations with S.A.M.C. have been the most satisfactory, also taking into account the purpose of the loans and the needs they serve.

3. Extend personal credit based on an individual’s own credit qualifications. Balances and credit worthiness of an individual’s employer or the individual’s affiliation shall no be substituted for individual credit analysis.

PRIVACY RIGHTS

Financial and personal information about customers commands the same respect and care as funds and property. S.A.M.C. strives to protect its customer’s privacy rights by:

1. Securely maintaining all files and records which contain customer information.

2. Divulging no personal or credit information to others, except a) with proper customer authorization, b) through proper legal process or regulation or, c) for accepted credit reporting purposes.

RESPONSIBILITY IN THE MARKETPLACE

S.A.M.C. strives to conduct all relations with customers, competitors and suppliers in full compliance with the letter and spirit of applicable laws in an exemplary manner with regard to honesty, good faith, and fairness. The following general rules will be observed:

1. Employees and members of their immediate families shall not accept money, gifts of other than nominal value, unusual hospitality or loans from any customer, competitor or supplier who is not making such a gift or loan solely as a personal family friend or family member.

2. Employees shall not give money, gifts of other than nominal value or unusual hospitality to any customer, competitor or supplier of S.A.M.C. where the intent is to influence the recipient to favor S.A.M.C.

3. Employees shall not directly or indirectly make any statement related to S.A.M.C. business that is knowingly false or misleading in any material respect to any director or employee of the company, to any attorney, accountant or agent retained by S.A.M.C. or to any government agent or regulator.

4. Employees shall not engage in discussions or enter into agreements or arrangements with competitors about prices for services or other non-competitive practices.

5. Employees shall strive to provide information that is clear, factual, relevant and honest to enable customers to select services best suited to their needs. All services will be equally available to all customers who meet S.A.M.C. criteria and standards.

6. Confidential or proprietary information, whether or not designated as such relating to S.A.M.C., its shareholders, existing or prospective customers or suppliers, acquired through association with S.A.M.C., shall be used by employees solely for company purposes. Such information shall not be provided to any other person or firm, used for personal, private, business, charitable or any other purpose.

CIVIC RESPONSIBILITY

S.A.M.C. intends to be a good corporate citizen in the community in which it operates, supporting worthy civic, cultural, educational, social and other programs contributing to the quality of life. Employees are encouraged to exercise their rights and duties as private citizens.

Employees must obtain management approval before seeking or accepting any private office and before serving as the chairperson or treasurer of a political campaign committee for any candidate or political policy.

POLITICAL CONTRIBUTIONS

Federal law prohibits all corporations from making federal political contributions to candidates for election. In addition, various state laws further limit the ability of corporations to make political contributions. Where lawful, S.A.M.C. or its subsidiaries may make the contributions concerning civic or governmental issues in which S.A.M.C. or subsidiary has a particular interest only after receiving both an opinion of corporate counsel that the contribution is lawful and the prior approval of the Chief Executive Officer of S.A.M.C. Any contributions to candidates for elective public office shall require both an opinion of corporate counsel that the contribution is lawful and the prior approval of the Chairman of the Board or President of S.A.M.C.

IMPLEMENTATION

All employees are responsible for knowing the contents of the Code and must observe its letter and spirit at all times. The policies and rules of the Code will be vigorously enforced through audit, examination and personnel procedures. Employees should address questions concerning whether specific activities are prohibited or restricted by this Code to the Human Resources Department of S.A.M.C. for clarification.

RESPONSIBILITY OF EMPLOYEES TO REPORT VIOLATIONS OF THE CODE OF ETHICS

It is the responsibility of each employee to report promptly to the Human Resources Department of S.A.M.C. directly any instances the employee reasonably believes to be violations of the Code of Ethics or violations of the law. Upon receipt of such report of violation, the Human Resources Department shall conduct an investigation and determine appropriate disposition. The Human Resources Department shall further ensure that such reports and disposition result in unbiased treatment of all parties concerned.

V. SUPPLEMENTAL CODE OF ETHICS FOR OFFICERS

INTRODUCTION

The Supplemental Code of Ethics sets forth in greater detail standards of conduct for all officers of S.A.M.C. In order to monitor compliance with the code, the President of S.A.M.C. may designate certain officers as Reporting Officers for purposes of completing an annual disclosure, whenever necessary certifying compliance with the Code of Ethics and this Supplement. Those designated as Reporting Officers for this purpose shall include, but not limited to, those holding positions as Senior Vice President and above. Others may also be designated as Reporting Officers provided that to serve as Reporting Officer would not place them in a position where their personal interests could conflict with those of S.A.M.C.

A. FIRST STANDARD

An officer shall promote integrity within the business community by demonstrating professional and ethical conduct in both personal matters and in the discharge of S.A.M.C. responsibilities.

1. An Officer shall perform his or her duties without discriminating on the basis of race, religion, national origin, sex, age, marital status, veteran status, disability, sexual orientation, citizenship, or any other legally recognized status entitled to protection under state or federal law.

2. An Officer shall maintain a high level of integrity and shall encourage other directors, officers, and employees do likewise. An officer shall refrain from illegal conduct in personal and business affairs and avoid all conduct that could reasonably be expected to reflect adversely on his or her integrity or that of S.A.M.C.

3. An Officer shall support an obey both the language and spirit of the law in general, the S.A.M.C. Code of Ethics and this Supplemental Code of Ethics, avoiding efforts to circumvent the law or Code provisions by devious means or questionable interpretations.

4. An Officer shall be entitled to rely upon the opinions of lawyers and the reports and information prepared by S.A.M.C. employees, directors, accountants, or other outside advisors he or she deems competent and authorized, but such reliance shall not relieve the Officer of the final responsibility for making the business decisions based in whole or part upon that reliance.

5. An Officer shall disclose to the Human Resources Department of S.A.M.C. any illegal or unethical activities by any officer that are likely to have an adverse effect upon the business integrity, reputation or affairs of S.A.M.C. Such disclosure does not eliminate the obligation under federal law to file criminal referral forms.

6. An Officer shall perform his or her duties without discriminating on the basis of race, religion, national origin, sex, age, marital status, veteran status, disability, sexual orientation, citizenship, or any other legally recognized status entitled to protection under State or Federal Law.

7. An Officer shall act within the authority that has been legally delegated to him or her by S.A.M.C. In this regard, an Officer shall be responsible for understanding the scope of his or her delegated authority and for ensuring that his or her subordinates are informed concerning their authority.

8. An Officer has no authority to, and shall not, either take any action that he or she knows or should know is in violation of any statute, rule or regulation, or execute any note, contract or any other agreement on behalf of S.A.M.C. except as is specifically provided by the articles of incorporation, or by the bylaws of S.A.M.C. or action of the Board of Directors or its executive committee. An Officer who is uncertain whether he or she has been duly authorized should seek prior guidance from a superior officer, S.A.M.C. internal corporate counsel, or, where appropriate, from outside counsel.

B. SECOND STANDARD

An Officer shall preserve the confidential and proprietary information nature of business and customer information.

1. An Officer shall ensure that all confidential and proprietary information of any nature acquired in the course of employment is used solely for S.A.M.C. purposes and is not provided to unauthorized persons or used in any way:

a. Either directly or indirectly for investment, business, charitable, religious, civic, or other purposes unrelated to the business life of S.A.M.C.; or

b. As a basis for buying, selling, trading, or recommending the purchase, sale or trading of any securities of any entity until the information has been publicly disseminated.

2. The obligation of an Officer to preserve the confidential and proprietary nature of information acquired in the course of employment continues after termination of employment with S.A.M.C.

C. THIRD STANDARD

An Officer shall place the interests of S.A.M.C. ahead of any private interests and shall disclose the facts of any situation where an actual or potential conflict of interests may exist.

1. An Officer shall ensure that no outside personal, business, charitable, religious, civic, or investment activities directly or indirectly conflict with the interest of S.A.M.C. In all situations where an actual or potential conflict of interest exists, or might appear to others to exist, an Officer shall disclose all details of the activity and the actual or potential conflict to the President of S.A.M.C.

An Officer or his or her affiliates or immediate family may sell, purchase, or lease property or services to or from S.A.M.C. only if the company is not acting in a fiduciary capacity and:

a. The transaction is in the ordinary course of the business on terms and conditions generally available to the public, less any standard S.A.M.C. approved employee discounts; or

b. The details of the transaction are disclosed and prior approval is obtained from the President and the transaction is fair and reasonable to S.A.M.C. at the time it is approved.

The primary business obligation of an Officer shall be to S.A.M.C. Business activities and investments that detract from, or conflict with, this obligation shall be avoided. In addition, unless prior written approval is obtained from the President or V.P., an officer or any person or entity affiliated with the Officer shall not directly or indirectly:

a. Engage in any business activity or make any investment that competes with the business interests or activities of S.A.M.C.

2. An Officer shall not directly or indirectly solicit or accept any fee, commission, entertainment, gift, gratuity, property, discount or loan for himself or herself or any person or entity affiliated with the Officer as compensation for performing duties with S.A.M.C. or for making or encouraging S.A.M.C. to make any business decision.

No Officer will accept any compensation for services performed by the Officer on behalf of S.A.M.C. that are part of the Officer’s job duties.

3. An Officer or members of his or her immediate family shall not accept money, gifts of other than normal value, bequests or unusual hospitality from any customer, competitor or supplier who is not acting solely as a personal friend or family member. No bribe, kickback or other payment regardless of the amount, for illegal or corrupt purposes shall be given, accepted or authorized. An Officer shall disclose to the President any offer of anything of value made with the intent to influence or reward him or her in connection with S.A.M.C. business. Any gifts or other items about which an Officer is uncertain should not be made or accepted without disclosure of the details and the receipt of prior approval from the President or V.P.

4. An Officer and any person or entity affiliated with the Officer may not directly or indirectly obtain credit from any customer, competitor, third parties, vendors or supplier of S.A.M.C. except where:

a. The entity or person granting the credit does so solely as a family member or personal friend independent of any business relationship with S.A.M.C.; or

b. I) The entity or person granting the credit engages in extending credit in the ordinary course of business; and II) The loan is granted on terms (including interest rates and collateral) no more than those available through the applicable creditor to comparable persons in similar transactions.

5. An Officer shall not serve under a power-of-attorney or as executor, personal representative, trustee or guardian of an estate, trust or guardianship by anyone other than a family member without having first obtained written permission of the President or V.P.

6. An Officer shall not accept any directorship or position with any for-profit corporation or enter into outside employment with an entity or individual other than S.A.M.C. without obtaining prior approval from the President or V.P.

7. When an Officer is publicly stating a personal opinion which might be construed as the opinion of S.A.M.C., the Officer is under an obligation to make it clear that such opinion may not represent the position of S.A.M.C.

8. Copyright ownership and title to, and all income royalties resulting from, S.A.M.C. work products prepared primarily at the direction of S.A.M.C. or for company purposes shall belong to S.A.M.C.

9. An Officer may retain honoraria received for services as a lecturer, speaker, or other similar capacity if the amount is disclosed to the Officer’s superior and his or her approval is obtained. Any expenses incurred by the Officer in connection with any such activity shall be paid by the Officer.

10. An Officer shall not make, approve, participate or influence the making or approval of any S.A.M.C. credit or other business decision if the Officer or any person or entity affiliated with the Officer has, or might reasonably appear to others to have, any direct or indirect interest in the decision involved or in any entity that may benefit from the decision.

D. FOURTH STANDARD

Officers shall avoid impropriety in fact and appearance in business and personal matters.

1. An Officer shall be governed by both the language and spirit of S.A.M.C. Code of Ethics and this Supplemental Code of Ethics and shall construe their provisions in a manner that will protect the integrity and reputation of S.A.M.C. and the individual officer. In the event the Code of Ethics and the Supplemental Code of Ethics appears to be ambiguous, the Officer shall either:

a. Request advice for clarification by filing a written request for an opinion with the Human Resources Department of S.A.M.C. or

b. Assume that the particular activity is restricted under code of provision.

2. An Officer shall not convert property or assets of S.A.M.C. to personal use or use S.A.M.C. funds to purchase property for personal use.

3. An Officer shall exercise prudence and restraint in personal financial affairs in order to avoid debts and other financial obligations that are out of proportion to the employee’s personal or family financial condition. An Officer shall disclose to the President or V.P. any personal financial problem that affects, or might reasonably be expected to affect, the employee’s judgment or decision in any S.A.M.C. matter or decision entrusted to him or her.

4. An Officer shall neither posses nor uses illegal drugs on or off S.A.M.C. premises.

5. Although Officers are encouraged to participate freely and actively in the political process, an Officer shall ensure that such activities are consistent with the provisions of S.A.M.C.’s Code of Ethics and this Supplemental Code of Ethics and all applicable laws, rules and regulations (including those relating to conflicts of interest and ethical improprieties by government officials) and that the activities do not interfere with the employee’s ability to perform his or her employment duties.

6. An Officer may become a candidate for election to or serve in a federal, state, or local office or serve as the chairperson or treasurer to a campaign committee for such a candidate or any political party only if prior approval to accept the position or assignment is obtained from the Human Resources Department.

7. Federal and State laws prohibit or severely restrict S.A.M.C.’s ability to make political contributions. An Officer may make no contribution, expenditure or payment directly or indirectly on the behalf of S.A.M.C. concerning any political, legislative, government or civic issue unless:

a. S.A.M.C.’s General Counsel has rendered an opinion that the disbursement is lawful; and

b. The details of the disbursement are disclosed and prior written approval of the disbursement is obtained from the President or V.P.; and

c. The disbursement is accurately described and recorded in the appropriate books of S.A.M.C.

Any contributions on behalf of S.A.M.C. to political parties or to candidates for elective public office shall require, in addition to the foregoing, the prior approval of the President of V.P.

8. No bribe or other compensation to influence a decision or action shall be paid to any political or governmental official.

E. FIFTH STANDARD

An Officer shall be truthful in dealing with the public.

1. An Officer shall not knowingly make any statement to any representative or to any lawyer or accountant retained by S.A.M.C., or to any government agency or regulator, which is misleading in any material respect or fails to state any material fact necessary to make the statement, in light of the circumstances under which it was made, not misleadingly.

2. An Officer shall strive to ensure the information, advertising and other statements released to the public by S.A.M.C. are truthful and not misleading.

3. An Officer shall strive to ensure that the books, records, and accounts of S.A.M.C. accurately reflect S.A.M.C.’s transactions and operations. An Officer shall not directly or indirectly falsify any of the books, records, accounts, or other document of S.A.M.C.

VI. LOAN FRAUD POLICY DISCLOSURE CONTRACTUAL AGGREEEMENT

CONDENSED CODE OF ETHICS/LOAN FRAUD POLICY DISCLOSURE (L.F.P.D.)

I, the undersigned, declare that I have on this date carefully reviewed the CODE OF ETHICS/L.F.P.D of S.A.M.C. and have thoroughly understood how it applies to my job at S.A.M.C. and to me. I shall follow very closely all the guidelines contained in this CODE OF ETHICS/L.F.P.D. so that in conducting all the functions of my job and all my relations with S.A.M.C and its customers I will act:

To reflect what is right as well as what is legal in every country which S.A.M.C. does business.

To avoid conflict of interest.

To ensure the confidentiality of communications and transactions between the company and its clients.

To prevent misuse of information (either for personal gain or for any purpose other than that which the company intends), which I garner through S.A.M.C.’s operations.

To guarantee proper treatment of customers, suppliers, employees, and others who rely upon or are associated with the company.

To conduct business transactions with integrity and maintain the accuracy of the relevant accounting records.

To adhere to the strict requirements of personal integrity and conduct of S.A.M.C.

To personally warrant and represent the truth and accuracy of each and every loan.

This is an acknowledgement that you have read and understand the terms herein. This agreement legally binds you to potential consequences that S.A.M.C. reserves the right to pursue under this agreement.

_____________________________ _____________________________

DATE NAME

_____________________________

SIGNATURE

(The CODE OF ETHICS/LOAN FRAUD POLICY DISCLOSURE is to be reviewed once a year by every employee of S.A.M.C., including officers and senior executives, signed immediately afterwards and delivered to the Human Resources Department.)

EMPLOYEE MANUAL ACKNOWLEDGMENT FORM

I understand that S.A.M.C.’s Employee Policies Manual (“Manual”) describes important information about this organization. S.A.M.C. retains the sole discretion to alter the Manual from time to time. Because provisions of the Manual are subject to change, I further understand that revisions to the Manual may supersede or eliminate one or more existing policies and that all such changes will be communicated to me.

My employment relationship with this organization is voluntarily entered into and is subject to termination by me or the company at will, with or without cause, at any time.

I acknowledge that this Manual is neither a contract of employment nor a legal document. I have received, read, understood, and will comply with both the policies contained in this Manual and any revisions made to it. I specifically acknowledge that I have read, understood, and will comply with the company’s Anti-Harassment / Anti-Discrimination Policy.

_____________________________ _____________________________

DATE NAME

_____________________________

SIGNATURE

LOAN FRAUD POLICY DISCLOSURE (L.F.P.D.) AND

CODE OF ETHICS …………………………………...........................................

CODE OF ETHICS...............................................................................................

STATMENT OF PERSONNEL POLICIES

ORIENTATION

PROBATIONARY PERIOD OF EMPLOYMENT

WORK HOURS

EXEMPT AND NON-EXEMPT EMPLOYEES

ATTENDANCE AND PUNCTUALITY

MEAL PERIODS

PAY DAY AND METHOD

PERFORMANCE APPRAISALS

VACATIONS

HOLIDAYS

LEAVE OF ABSENCE POLICY

LEAVES WITHOUT PAY

INTRODUCTION

DEFINITIONS

WHO IS ELIGIBLE FOR FMLA LEAVE?

WHEN IS FMLA LEAVE PERMITTED?

WHAT NOTICE DOES S.A.M.C. REQUIRE?

PHYSICIAN’S CERTIFICATE

B. Additional Medical Opinions

INTERMITTENT OR REDUCED SCHEDULE LEAVE

REPORTING TO S.A.M.C. WHILE ON LEAVE

WHAT RELATIONSHIP DOES FMLA LEAVE HAVE TO PAID LEAVE?

INSURANCE BENEFITS WHILE ON FMLA LEAVE

A. Fitness to Return to Duty Certification

B. Can Leave be Designated as FMLA Leave After the Employee Returns to Work?

A. KEY EMPLOYEE EXCEPTION

ADMINISTRATION OF THIS POLICY

B. NON-MEDICAL LEAVE OF ABSENCE

C. MILITARY LEAVE

TERMINATION AND RESIGNATION

A. RESIGNATION NOTICE

B. EXIT INTERVIEW

III. GROUP BENEFITS

INSURANCE PROGRAMS

A. MEDICAL INSURANCE

CONTINUING HEALTH CARE COVERAGE (COBRA)

MORTGAGE SERVICES

A. LOANS

EDUCATION

A. EDUCATION

LETTERS OF RECOMMENDATION / REFERENCE LETTERS

PERSONAL APPEARANCE

CONFIDENTIALITY

SAFETY AT WORK PREMISES

WORKPLACE VIOLENCE POLICY

Purpose

Reporting Workplace Violence

Reporting Procedure

PERSONAL MAIL

INTERNET USE POLICY

INTRODUCTION

OTHER POLICIES INCORPORATED

SECURITY AND CONFIDENTIALITY

PRIVACY