Activity Simulation, Time Fraud, and Workplace Systems Policy

The Recruitment Org LLC, doing business as Lioncrest People ("Lioncrest People"), requires all employees and independent contractors to report working time, attendance, availability, invoiced hours, and work activity honestly and accurately.

Personnel may not use software, hardware, scripts, devices, services, or other methods to:

• create the false appearance that they are working, active, available, or online;
• prevent an online status from changing to idle or away when they are not working;
• generate artificial mouse, keyboard, clicking, scrolling, or application activity;
• falsify timesheets, invoices, attendance, screenshots, productivity data, or other work records;
• interfere with or circumvent an authorized timekeeping, security, or workplace-management system; or
• obtain compensation for time not worked or services not performed.

Deliberate violation may constitute dishonesty, fraud, time-record falsification, or time theft. It may result in immediate termination of employment or immediate termination of an independent contractor's engagement, subject to applicable law and any governing written agreement.

This policy applies to all Lioncrest People personnel, including:

• full-time and part-time employees;
• temporary, remote, and hybrid employees;
• independent contractors and consultants;
• interns, agency personnel, and subcontractors; and
• any other person granted access to Lioncrest People or client systems.

References to "personnel" include employees and independent contractors unless a provision expressly states otherwise.

This policy applies when personnel use:

• company-owned equipment;
• company systems, networks, accounts, or information;
• client systems, information, or equipment;
• authorized timekeeping or workforce-management systems; or
• personal equipment used to perform company work, subject to applicable law and written bring-your-own-device requirements.

Personnel may not:

1. 1.Use artificial activity to appear present, productive, available, or working when they are not performing authorized work.
2. 2.Use a mouse jiggler, mouse mover, automatic clicker, keyboard simulator, or comparable device or application for a deceptive purpose.
3. 3.Use scripts, macros, scheduled tasks, browser automation, or other automation to generate false activity.
4. 4.Run videos, presentations, applications, or other processes solely to prevent a device or communication status from becoming idle.
5. 5.Record, submit, approve, or invoice time that was not actually worked.
6. 6.Submit an invoice for services that were not performed.
7. 7.Alter, delete, conceal, or falsify attendance, productivity, payroll, invoicing, security, or system records.
8. 8.Disable, uninstall, obstruct, manipulate, or circumvent an authorized company or client system.
9. 9.Ask another person to log in, clock in, remain online, or create activity on their behalf.
10. 10.Use another person's credentials or allow another person to use their credentials.
11. 11.Test whether deceptive activity can avoid company controls without prior written authorization.
12. 12.Help, encourage, or instruct another person to engage in prohibited conduct.
13. 13.Conceal the presence or use of an unauthorized activity-simulation tool.
14. 14.Misrepresent work performed, results achieved, availability, attendance, or time devoted to a client or project.

This policy applies according to a tool's purpose and use, regardless of its name or stated purpose.

Prohibited tools and methods include, but are not limited to:

• LazyWork;
• Still Here and comparable activity or presence simulators;
• applications described as Mouse Jiggler, Mouse Mover, Auto Mouse Mover, or Move Mouse;
• physical, mechanical, wireless, or USB mouse-jiggling devices;
• automatic clicking or keyboard-simulation tools;
• unauthorized AutoHotkey, PowerShell, AppleScript, Python, shell, or similar scripts;
• unauthorized macros or scheduled processes that create artificial input;
• browser extensions intended to maintain a false active status;
• devices physically attached to a mouse, keyboard, or touchpad to generate movement;
• methods intended to manipulate Microsoft Teams, Slack, Zoom, timekeeping software, or another presence indicator; and
• renamed, modified, successor, or substantially similar tools.

This list is illustrative and not exhaustive. A tool does not have to be specifically identified in this policy to be prohibited.

Some automation or device-awake tools may have legitimate uses, including:

• disability or accessibility accommodations;
• authorized software testing;
• approved workflow automation;
• presentations or demonstrations;
• system administration;
• security testing; or
• another documented operational requirement.

Personnel must obtain written authorization from Lioncrest People before installing or using such a tool in connection with company or client work.

The authorization must identify:

• the authorized individual;
• the tool or method;
• the device on which it will be used;
• the legitimate business purpose;
• the permitted use; and
• the approval period.

Authorization for a legitimate use does not permit anyone to falsify time, availability, services, invoices, or work activity.

Employees requesting a reasonable accommodation should contact Byron Van Gisborne or the designated Human Resources representative. Lioncrest People will address accommodation requests in accordance with applicable law.

An idle or away status, standing alone, does not establish wrongdoing.

Legitimate work may include:

• telephone or video calls;
• reviewing printed materials;
• meetings;
• planning, analysis, or research;
• authorized travel;
• training;
• authorized breaks;
• accessibility-related work methods; and
• duties performed away from a computer.

Personnel must nevertheless maintain accurate time and service records and provide truthful information when reasonably asked about a period of inactivity.

Employees

Nonexempt employees must accurately record all compensable time worked. Employees may not:

• work off the clock;
• underreport or overreport their hours;
• change a time record to conceal work or non-work time; or
• falsify another employee's record.

Lioncrest People will pay nonexempt employees for all compensable time it knows or has reason to believe was worked, even when the work was not authorized in advance. Performing unauthorized work or failing to follow timekeeping procedures may result in discipline, but payment for compensable work will not be withheld.

Independent contractors

Independent contractors must submit complete and accurate invoices, time records, deliverables, and service reports as required by their written agreements. Independent contractors may not:

• invoice Lioncrest People or a client for time not worked;
• invoice for services not performed;
• duplicate billable time across clients or engagements;
• falsify a deliverable or service record;
• misrepresent their personal participation in the work; or
• delegate or subcontract work without required authorization.

Payment obligations, invoicing procedures, acceptance requirements, and dispute procedures for independent contractors remain governed by their written agreements and applicable law.

All personnel must promptly report suspected errors in time, pay, or invoices. Lioncrest People prohibits unlawful retaliation against anyone who raises a good-faith concern.

To the extent permitted by federal, state, and local law, Lioncrest People may collect and review information generated through company or client systems, including:

• login and logout records;
• time and attendance information;
• application and website usage;
• task, project, recruitment, and candidate-management records;
• communication metadata;
• device, network, and security events;
• idle and activity information;
• file-access records; and
• authorized screenshots or other records identified in a monitoring notice.

Monitoring may be conducted for legitimate business purposes, including:

• payroll, invoicing, and attendance administration;
• information security;
• protection of company, candidate, and client information;
• investigation of suspected misconduct;
• operational management;
• legal or contractual compliance;
• verification of client billing; and
• confirmation that contracted services have been performed.

Where required, Lioncrest People will provide a separate state-specific electronic-monitoring or privacy notice and obtain any legally required acknowledgement or consent.

Monitoring information will not automatically be treated as conclusive proof. Lioncrest People may consider work output, deliverables, communications, system records, the individual's explanation, and other relevant evidence.

Personnel should not expect privacy when using company-owned equipment or company systems, except where privacy is provided by applicable law.

This policy does not authorize unrestricted monitoring of personal devices, personal accounts, legally protected communications, or activity outside the permitted scope of employment or a contractor's engagement.

Lioncrest People may investigate suspected violations and may:

1. 1.preserve relevant records;
2. 2.restrict or suspend system access;
3. 3.inspect company-owned equipment;
4. 4.direct personnel to stop using or remove an unauthorized tool;
5. 5.place an employee on investigatory suspension where appropriate;
6. 6.suspend an independent contractor's access or assignments while an investigation is pending;
7. 7.interview the individual and other relevant persons;
8. 8.review time, invoice, work, security, and system records; and
9. 9.take other lawful and proportionate investigative steps.

Where practicable, the individual will be informed of the suspected conduct and given an opportunity to provide an explanation before a final decision is made.

Nothing in this section requires Lioncrest People to use progressive discipline or prevents immediate protective action when the company reasonably determines that urgent action is necessary.

An employee's violation of this policy may result in disciplinary action, up to and including immediate termination of employment.

Conduct that may justify immediate termination includes:

• deliberate falsification of time or attendance;
• using artificial activity to obtain compensation for time not worked;
• intentionally deceiving Lioncrest People or a client;
• altering, concealing, or destroying relevant records;
• interfering with security or monitoring controls;
• repeated prohibited conduct;
• refusing a lawful and reasonable direction to stop the conduct; or
• assisting another person to commit time fraud.

Subject to applicable law and any binding written agreement, Lioncrest People may terminate employment immediately without:

• advance notice;
• progressive discipline;
• severance; or
• payment for time after termination becomes effective.

A terminated employee remains entitled to:

• wages for all compensable time actually worked;
• overtime and other earned compensation required by law;
• qualifying business-expense reimbursement where required;
• accrued paid time off when payment is required by applicable state law or company policy; and
• any other vested or legally protected benefit.

Final wages will be paid within the period required by the law of the state in which the employee works.

Lioncrest People will not make an unlawful deduction from wages or treat this policy as authorization to forfeit earned compensation.

An independent contractor's violation of this policy may result in:

• rejection or correction of an inaccurate invoice;
• suspension or revocation of company or client system access;
• removal from an assignment or client account;
• immediate termination of the contractor's engagement, subject to the governing agreement and applicable law;
• recovery of amounts paid because of proven fraud or material misrepresentation, where legally permitted;
• exercise of contractual indemnification or other remedies;
• notification to an affected client; and
• referral to legal counsel, law enforcement, or a regulator where appropriate.

Independent contractors will be paid for undisputed, properly performed, and accepted services according to their written agreements and applicable law.

Lioncrest People will not withhold undisputed earned compensation merely as a disciplinary penalty.

Nothing in this policy changes an individual's legal classification.

This policy does not:

• convert an independent contractor into an employee;
• create an employment relationship with an independent contractor;
• alter the terms of a signed independent contractor agreement;
• give an independent contractor employee benefits or employment rights not otherwise provided by law;
• guarantee an employee employment for any period; or
• guarantee an independent contractor any minimum amount of work.

For employees, termination is governed by applicable law and any binding written agreement.

For independent contractors, termination and payment obligations are governed by the applicable contractor agreement and law.

This section applies only to employees.

Unless a written agreement signed by an authorized officer of The Recruitment Org LLC expressly provides otherwise, employment with Lioncrest People is at will.

Either the employee or Lioncrest People may terminate the employment relationship at any time, with or without advance notice and with or without cause, subject to applicable law.

This policy does not create an employment contract, guarantee employment for any period, or alter an employee's at-will status.

Nothing in this policy prohibits or restricts any person from:

• reporting suspected legal violations;
• filing or participating in a government complaint or investigation;
• discussing wages, hours, or working conditions as protected by law;
• engaging in protected concerted activity;
• requesting a legally protected accommodation;
• taking protected leave;
• reporting discrimination, harassment, retaliation, or wage concerns;
• making a protected whistleblower disclosure; or
• exercising another right protected by applicable law.

This policy will not be applied to interfere with legally protected activity.

No manager may promise that a particular disciplinary sequence will be followed or that a particular violation will automatically produce a predetermined outcome.

Lioncrest People may determine the appropriate response based on:

• the available evidence;
• applicable law;
• the governing employment or contractor agreement;
• consistency;
• the seriousness of the conduct;
• the individual's explanation; and
• other relevant circumstances.