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III-25

for a specified and limited period of time (e.g., lifeguards or grounds

keepers employed for the summer season).

Procedure

HHHunt seeks to exercise sound business judgment in its hiring and advancement

decisions, including with respect to relatives of employees and anyone involved in

amorous relationships. Managers are expected to avoid hiring individuals who are

close relatives or domestic partners of, or involved in dating or amorous

relationships with, any current employee of the Company who would be in the

same business division as the new employee. In addition, individuals are not to be

promoted into a position that would create a conflict with the CompanyÊs policy.

If employees begin an amorous relationship or become relatives, partners or

members of the same household, each employee is required to inform their direct

supervisor of the relationship, as well as the director or assistant director of

human resources (HR), within sixty (60) days (in writing or via email). If one party

is in a supervisory position over the other or if the employees report to the same

supervisor, the employees will have sixty (60) days to resolve the situation on their

own. After sixty (60) days, if the employees have not yet resolved the situation on

their own by means acceptable to the Company, such as a transfer or employment

outside the company, the employeesÊ supervisor(s) will work with the director of

human resources (HR) to determine the most appropriate action for the specific

situation. This may include transfer or, if necessary, termination of one of the

employees and any such actions will be taken within sixty (60) days of the

Company assuming responsibility to resolve the situation.

If an action of the Company results in an involuntary circumstance in which two

relatives, partners or members of the same household may be reporting to each

other or reporting to the same supervisor, one of the employees will be

reassigned within sixty (60) days. During that period, the supervisory employee

will not have involvement or direct input in the employment decisions of the other

employee.

Exceptions

Exceptions to this policy are expected to be infrequent and any exceptions must

be approved in writing by the Sr. Vice President of Senior Living and the director

of HR. Written justification for the exception must be submitted to the HR

director prior to any employment decisions and a written response will be

provided within ten (10) business days. The Company reserves the right to apply

this policy to situations where there is the potential for conflict, undue distraction,

or perceptions of unfair advantage because of the relationship between employees,

even if no direct reporting relationship or authority is involved.

In situations where both employees continue to be employed with HHHunt, these

employees are reminded that their conduct during working hours and within the

working environment must always be professional and appropriate for a business