CODE OF CONDUCT AND BUSINESS ETHICS

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1 CODE OF CONDUCT AND BUSINESS ETHICS

2 TABLE OF CONTENTS STATEMENT FROM THE CHAIRMAN OF LINQ 4 LINQ S CULTURE AND GUIDING PRINCIPLES 6 GENERAL PRINCIPLES 6 OUR CORE VALUES AND BUSINESS PRINCIPLES 7 REPORTING AND GOVERNANCE 8 OUR PEOPLE: SAFETY AND INTEGRITY 9 RESPECT FOR HUMAN RIGHTS 9 HEALTH, SAFETY, SECURITY AND ENVIRONMENTAL STANDARDS 10 INTOXICATING AND CONTROLLED SUBSTANCES 10 HARASSMENT 11 EQUAL OPPORTUNITY 12 SUSTAINABLE DEVELOPMENT 12 WORKING STANDARDS 13 FIGHT AGAINST CORRUPTION, INCLUDING FACILITATION PAYMENTS, FRAUD AND ANTICOMPETITIVE PRACTICES 13 LOBBYING 13 INVOLVEMENT IN POLITICAL ACTIVITIES 14 RESPECT OF CONFIDENTIALITY 14 INTELLECTUAL & INDUSTRIAL PROPERTY 14 CLASSIFIED INFORMATION 15 ETHICS STANDARDS IN BUSINESS 16 QUALITY ASSURANCE 16 CONFORMITY WITH THE RULES RELATED TO THE MANAGEMENT FOR QUALITY OF PRIVATE SECURITY COMPANY OPERATIONS 16 CONFLICT OF INTEREST 17 CONSULTANTS AND SUBCONTRACTORS 17 BRIBERY AND CORRUPTION 18 MONEY LAUNDERING 19 2

3 ANTITRUST AND COMPETITION LAW 19 SEXUAL EXPLOITATION AND ABUSE OR GENDER-BASED VIOLENCE 20 ETHICAL BUSINESS WITH GOVERNMENTS AND INTERNATIONAL ORGANISATIONS 20 PROCUREMENT PROCESSES 21 CHOICE OF PARTNERS AND SUBCONTRACTORS 21 PERFORMANCE OBLIGATIONS 22 AUDITS 22 GIFTS AND HOSPITALITY 22 DISTRIBUTION OF LINQ S CODE OF CONDUCT AND BUSINESS ETHICS 23 LINQ REFERENCES 24 ETHICS TRAINING 24 DECLARATION OF COMPLIANCE WITH LINQ S CODE OF CONDUCT AND BUSINESS ETHICS 25 3

4 STATEMENT FROM THE CHAIRMAN OF LINQ As a strategic defence and security services integrator, LINQ CAP SA (hereinafter LINQ ) is a family of companies providing integrated security, operations support, training, and post-conflict stabilisation services to meet the needs of governments, multinational corporations and international organisations in the most complex and challenging environments. An essential part of our strategy is to ensure that all LINQ subsidiaries and affiliate companies ( LINQ companies) comply fully with the highest ethical standards, observe strictly all laws and regulations, and meet or surpass all recognised international standards and codes of conduct. This Code of Conduct and Business Ethics (the Code") explains the expectations of LINQ as majority shareholder of companies within the LINQ portfolio and thus provides framework guidance for everyone who works on our behalf. At LINQ, we strongly believe that a culture of integrity and respect requires the implementation of three priority business principles: > establishing relationships based on trust with clients, suppliers, communities and employees to ensure the highest levels of safety and security in operations as well as protecting health and the environment > compliance with laws, regulation and international standards > personal commitment and responsibility to maintain the highest ethical standards of business conduct and to guarantee respect for internationally recognized human rights standards Each employee and manager of LINQ, as well of its companies, must follow this Code. Where appropriate, LINQ companies should promulgate their own specific ethical codes and instructions, which should fully reflect the LINQ Code. 4

5 Contractors or external consultants acting on behalf of LINQ or LINQ companies should be required to act consistently with the Code. Everyone at LINQ is expected to be familiar with the Code and to sign the appropriate acknowledgment form, or its equivalent in LINQ companies, which is at the end of this document. The LINQ Board of Directors and I are confident that each and every one of us will do business in line with this Code. Working together and striving for excellence, treating everyone with dignity and respect, those are the preconditions to build sustainable growth and create value for all our stakeholders. Stéphane Gérardin 5

6 LINQ S CULTURE AND GUIDING PRINCIPLES LINQ companies, including, but not limited to ERYS Group and LINQ Experts, are committed to conducting business honestly, ethically, and in accordance with applicable laws and regulations of the European Union and other countries and jurisdictions in which we operate. This Code of Conduct and Business Ethics (the Code ) binds all LINQ companies employees and must be reflected in any equivalent instructions promulgated in LINQ affiliate companies, adapted where necessary to their specific activities and domains of expertise. GENERAL PRINCIPLES LINQ s goal is for its companies to be market leaders in their service offering domains, while never compromising our commitment to our core values and our reputation. The requirements and expectations of the Code must apply to all LINQ affiliates, including all officers, employees, and members of boards of directors, and also to LINQ third parties, which include independent contractors, subcontractors, agents, consultants; anyone representing or acting on behalf of LINQ. Company managers and supervisors are responsible for ensuring that the Code, or its equivalent implementing instruction in LINQ companies, is understood and followed by their subordinates. Compliance with the Code, as well as all laws, regulations, company policies, and sound ethical practices should be taken into account when reviewing the performance of all employees. Failure to comply should be grounds for disciplinary action, up to and including termination of employment. 6

7 LINQ may change, add or eliminate any policies or procedures contained in the Code at its sole discretion and at any time, unless prohibited by law. While it is hoped the Code will foster fair and consistent administration and concern for all employees, it does not create an employment contract between any employee and LINQ or its companies. Lastly, this Code is not intended to be a complete discussion of all laws and regulations under which LINQ companies and their employees and third parties operate. OUR CORE VALUES AND BUSINESS PRINCIPLES LINQ companies subscribe to three core values which underpin all our work and are the foundation of the Code: integrity, excellence and teamwork. Our business principles are derived from these values: > Integrity: LINQ and LINQ affiliate personnel ( LINQ personnel") must adhere to the highest ethical principles despite any pressure to do otherwise. They must strive at all times to maintain integrity, demonstrating consistency between thoughts, words and actions o They must make every reasonable effort to fulfil the letter and spirit of their promises and commitments. This is necessary not only on ethical grounds but also to ensure client satisfaction. o They must acknowledge and accept personal accountability for the ethical quality of their decisions. o They must demonstrate respect for the human dignity, autonomy, privacy, rights, and interests of all employees and colleagues, and of all clients and stakeholders. All people must be treated with equal respect and dignity 7

8 > Excellence: LINQ personnel should pursue excellence at all time and in all things, especially in performing their duties and being well informed and prepared. They should constantly endeavour to increase proficiency in all areas of responsibility > Teamwork: Both within and between affiliate companies, LINQ personnel must recognise teamwork as a key enabler and multiplier. They must facilitate and welcome each other s success and hold the performance of the team as more important than individual achievement o LINQ and LINQ companies equity and profit-sharing arrangements must reflect this core value REPORTING AND GOVERNANCE In order to monitor and guarantee the implementation of the Code, LINQ companies must put in place formal reporting arrangements to deal with issues of compliance. LINQ companies must nominate an Ethics Officer to carry out the day-to-day implementation of the Code. LINQ has appointed an Ethics Officer within its leadership team to serve as primary interface for affiliates who may have questions or concerns and to oversee Group-wide compliance. Employees of LINQ affiliates and applicable third parties with knowledge of a violation of this Code or the laws and regulations governing our business practices are expected to promptly report such violations to their line manager or to the relevant company Ethics Officer or the LINQ Ethics Officer. It is important to report such violations or suspected violations as soon as possible. 8

9 As well as being dealt with locally where possible, all known or suspected violations of an applicable law or this Code must be promptly reported to the LINQ Ethics Officer who will take such further action as may be necessary. OUR PEOPLE: SAFETY AND INTEGRITY LINQ companies must pay particular attention to employees working conditions, especially the respect for each individual. LINQ is committed to providing a safe and respectful work environment free from threats, violence, harassment and discrimination. RESPECT FOR HUMAN RIGHTS Respecting human rights is a fundamental requirement for LINQ personnel, working as we do in varied, often complex and hazardous environments. Conducting our activities in a way that respects human rights as set out in the UN Universal Declaration of Human Rights and the core conventions of the International Labour Organisation is a key requirement of our licence to operate. Two main areas are identified that are relevant to our work: > In the workplace: within our sites, respect for human rights must be evident in the employment and working conditions of employees as well as subcontractors and their employees > Local communities: LINQ companies activities can have a significant impact on local communities. For this reason, special attention must be paid to rights and concerns of those communities in countries where we work (environmental protection, property rights, etc) 9

10 Specific guidelines on the integration of the human rights principles into the operations of security companies must be promulgated by all LINQ affiliates delivering security services. 1 HEALTH, SAFETY, SECURITY AND ENVIRONMENTAL STANDARDS LINQ companies must support the health, safety, security and well being of our employees, our families and, ultimately, the communities in which we work. LINQ personnel must be conscious in their daily activities of their personal responsibilities, giving due consideration to the prevention of accidents, harm to health or adverse impacts on local communities. LINQ personnel must aim to earn the confidence of customers, shareholders and society, and to contribute to sustainable development. Special attention should be paid to the implementation of environmentally sound business practices throughout the world. These aims and others are included in the LINQ Corporate and Social Responsibility Guidelines 2. INTOXICATING AND CONTROLLED SUBSTANCES The use, possession, distribution or sale of controlled substances by any person while on LINQ and its affiliates premises or while operating LINQ equipment is prohibited. Use, distribution or sale of alcohol is prohibited unless prior permission has been obtained from appropriate management. 1 Refer to the ERYS Group Code of Conduct and to the Corporate and Social Responsibility Guidelines of LINQ. 2 Refer to the Corporate and Social Responsibility Guidelines of LINQ. 10

11 Any person under the influence of alcohol of controlled substances is prohibited from entering LINQ and its affiliates premises, engaging in Company business or operating Company equipment. Any use of alcohol or any other substance that causes or contributes to unacceptable job performance or unusual job behaviour is prohibited. HARASSMENT LINQ companies will not tolerate harassment of any kind and will not tolerate any action, conduct and behaviour, which is humiliating, intimidating or hostile. LINQ personnel must strive to create and maintain a work environment in which people are treated with dignity, decency, and respect. Mutual trust and the absence of intimidation, oppression, and exploitation should characterise LINQ companies work environment at any site. Harassment can be both verbal (comments regarding a person s national origin, race, religion, age, gender, sexual orientation, disability, appearance, marital status or other protected status) and non-verbal (distribution, display, or discussion of any written or graphic material that ridicules, degrades, insults, or shows hostility or aversion toward an individual or group because of national origin, race, religion, age, gender, sexual orientation, disability, appearance, marital status or other protected status). Harassment where detected will be dealt with through disciplinary action and may lead to dismissal. 11

12 EQUAL OPPORTUNITY Diversity is a decisive factor for our competitiveness, attractiveness and ability to innovate and adapt. LINQ companies must ensure that their employment-related decisions are based on relevant qualifications, merit, performance and other job-related factors. Unlawful discrimination relating to employment must not be tolerated. Each employee and candidate must be considered on individual merit, without discrimination as to origin, gender, age, disability, sexual orientation, gender identity, affiliation with a political, religious, or union organisation or minority group. LINQ companies must ensure the application of the highest standards of nondiscrimination, as enforced by international and European law. SUSTAINABLE DEVELOPMENT Sustainable development for LINQ companies means helping to meet business goals in ways that are economically, environmentally and socially responsible. Our commitment to sustainable development requires us to balance our shortand long-term interests; and to integrate economic, health, safety, security, and environmental and social considerations into business decisions. In conducting their operations, LINQ companies must respect the natural environment and the culture of host countries. More information about LINQ s policies on sustainable development can be found in the document LINQ Corporate and Social Responsibility Guidelines 3. 3 Refer to the Corporate and Social Responsibility Guidelines of LINQ. 12

13 WORKING STANDARDS FIGHT AGAINST CORRUPTION, INCLUDING FACILITATION PAYMENTS, FRAUD AND ANTICOMPETITIVE PRACTICES LINQ companies must have a zero tolerance approach on these topics and adhere to the highest standards of integrity. We must build sound relationships with all stakeholders and prevent, identify and address situations that might cross the line. Paragraph 4.4 of this Code provides recommendations and procedures to comply with applicable rules. LOBBYING Lobbying activity is highly regulated, especially when it is related to institutional and public clients. LINQ companies must comply with all statutory and regulatory requirements, including national and local requirements governing such activities, including registration, reporting and disclosure requirements. Particular care should be taken to ensure that lobbying activities with regards to the European Union, if conducted, are appropriately managed. The European Parliament and the European Commission interact with a wide range of groups and organisations representing specific interests. LINQ companies interactions with those institutions must be transparent and honest. They must therefore strictly follow the rules governing these activities, including the Code of Conduct governing relations of interest with representatives of the EU institutions, and where appropriate join the EU Transparency Register. 13

14 INVOLVEMENT IN POLITICAL ACTIVITIES LINQ companies should fully recognize the right of all employees to take part as individuals in political activities. Employees wishing to engage in political activities should be requested to clearly indicate that they do not represent LINQ or any LINQ affiliate company and to inform their manager if their political activities might create a conflict of interest. In no case should LINQ companies funds and resources be used to contribute to or otherwise support any political campaign, political party, political candidate, or any politically affiliated organisation. RESPECT OF CONFIDENTIALITY LINQ personnel must not improperly disclose confidential business information, whether verbally, in writing or electronically. Confidential business information should never be used for individual benefit, especially to trade in shares or other securities or recommend anyone else to do so. LINQ companies must fully respect all national security laws, regulations and firewalls. INTELLECTUAL & INDUSTRIAL PROPERTY Intellectual, physical and financial assets are valuable and must be preserved, protected and managed properly. LINQ companies resources should only be used for authorized business purposes, unless a specific exception has been approved by management. 14

15 IT and communication facilities include personal computers, mobile and desk phones and personal digital assistants. A limited use of LINQ companies IT and communication facilities for personal use is currently generally acceptable but could be reviewed. Data privacy and protection laws safeguard information about individuals. This information includes name and contact details, financial information, age and nationality. Information on race or ethnic origin, religion or philosophical beliefs, health or sexual orientation or trade union membership is sensitive personal data and subject to strict controls. LINQ companies must respects the basic right of individuals including employees, customers and suppliers to privacy. CLASSIFIED INFORMATION Due to the nature of the security business domain, LINQ companies are routinely trusted with classified national and international security information. All LINQ personnel who are granted access to classified information must take all necessary measures to protect such information, consistent with the requirements of the originating authority, and coordinate all activities related to this information with the relevant security authority s point of contact. Teaming between LINQ companies must never prejudice national security requirements and appropriate firewalls should be put in place to ensure that when LINQ companies work together they do not jeopardise the trust placed in them by security authorities. Each LINQ company should promulgate its own security policies and procedures consistent with this Code. 15

16 ETHICS STANDARDS IN BUSINESS QUALITY ASSURANCE Consistent with LINQ s Quality Management System, the quality assurance ethos must be fundamental to LINQ companies business operations. All LINQ personnel should be encouraged to meet the highest quality management standards, and to participate in the process to continually improve our perceived and actual performance.. LINQ company services must be provided in a manner that meets or exceeds requirements for safety, reliability, quality and performance. CONFORMITY WITH THE RULES RELATED TO THE MANAGEMENT FOR QUALITY OF PRIVATE SECURITY COMPANY OPERATIONS LINQ companies must always provide high-quality services to their clients in a manner that complies with applicable national and international laws, and protects the safety, security, human rights, and fundamental freedoms of all internal and external stakeholders, including LINQ personnel, clients, third parties, suppliers, and the local populations in areas where LINQ operates. To that end LINQ companies must implement policies, procedures, and controls that demonstrate and document their commitment to compliance with all laws and respect for human rights, to ensure they conform to the ANSI/ASIS PSC.1 Management System for Quality of Private Security Company Operations. This system supports the objectives of the Montreux Document on Pertinent International Legal Obligations and Good Practices for States Related to Operations of Private Military and Security Companies During Armed Conflict and the International Code of Conduct for Private Security Service Providers. 16

17 Specific quality rules and guidelines should be developed as necessary by LINQ companies delivering security services. CONFLICT OF INTEREST Conflicts of interest can influence proper decision-making, or be perceived to do so, and thus jeopardise the reputation of LINQ companies. Accordingly, LINQ personnel must promptly disclose any such conflicts of interest. Identifying and reporting existing or potential conflicts of interest allows risk to be managed. Employees can minimise or avoid potential conflicts of interest arising by: > avoiding acquiring any interest in the business of a competitor, supplier or customer without their manager s prior written approval > not exercising any outside professional activity without first obtaining their manager s written approval if employed by a LINQ company on a full-time basis. > declaring to the appropriate line manager or supervisor any matter that could influence or be perceived to influence decision or actions of a LINQ company > withdrawing from decision-making that creates, or could be perceived to create, a conflict of interest > being impartial, professional and competitive in dealings with contractors and suppliers CONSULTANTS AND SUBCONTRACTORS LINQ companies should as far as possible only engage in business with suppliers that have exhibited high standards of ethics and business integrity and have demonstrated compliance with all applicable laws and regulations. The manner in which LINQ companies select suppliers requires the utmost care and due diligence. 17

18 The character of the suppliers that we select is highly reflective of the way that we conduct business. Suppliers and subcontractors must be held responsible for delivering highquality services and materials, meeting contractual requirements, operating with ethical business principles, and complying with applicable laws and regulations. LINQ companies should only work with those consultants, business representatives, and other third parties who share a commitment to upholding the highest standards of ethics and business integrity. The actions of consultants, business representatives, and other third parties reflect on and impact the reputation of LINQ companies. BRIBERY AND CORRUPTION Bribery occurs when an employee offers, pays, seeks or accepts a payment, gift or favour to influence a business outcome improperly. Bribery and corruption whether involving government officials or commercial entities can be direct or indirect through third parties like agents and partners. The general principle to be applied by LINQ companies is that no personal payment, gift or favour shall be offered, paid, sought or accepted in return for favourable treatment to influence a business outcome or to gain any business advantage. The aim is that all LINQ personnel and third parties should fully understand that bribery and corruption are unacceptable. 18

19 MONEY LAUNDERING Money laundering occurs when the criminal origin of money or assets is hidden in legitimate business dealings or when legitimate funds are used to support criminal activities. LINQ companies must fully comply with the money laundering laws worldwide; LINQ personnel should report any suspicious transactions or individuals to their line manager or to the relevant company Ethics Officer or the LINQ Ethics Officer. All such notifications must also be promptly reported to the LINQ Ethics Officer who will take such further action as may be necessary. ANTITRUST AND COMPETITION LAW Antitrust law protects free enterprise and prohibits behaviour that limits trade or restricts fair competition. These laws apply to every level of business. LINQ companies must obey the antitrust and competition laws of every country in which they do business. Examples of violations of antitrust laws include: > agreeing with competitors to fix the price of a service or any elements of its price > agreeing with others not to compete in particular markets or for particular customers or accounts > rigging tenders > agreeing with others to boycott customers or suppliers except in connection with legally imposed sanctions 19

20 Anti-competitive behaviours will damage LINQ companies business and reputation and must therefore be avoided. SEXUAL EXPLOITATION AND ABUSE OR GENDER-BASED VIOLENCE Sexual exploitation, sexual abuse or gender-based violence must not be tolerated by LINQ companies, in any form. LINQ personnel must remain vigilant for all instances of sexual or gender-based exploitation or violence and, where discovered, report such instances to the appropriate authorities. ETHICAL BUSINESS WITH GOVERNMENTS AND INTERNATIONAL ORGANISATIONS Doing business with Governments and International organisations is both an honour and a privilege. LINQ companies must pay particular attention to observing the rules and regulations of international organisations, such as the United Nations, NATO and European Union, which can differ substantially from those they operate under when dealing with national governments or private companies. In their relationships with these institutions, LINQ companies may contract directly with the client or as a member of an ad hoc consortium or as a subcontractor to a prime contractor or leader. Even if a LINQ company does not hold a contract directly with the institution, many of the specific rules may apply to it and must be strictly followed. 20

21 PROCUREMENT PROCESSES National and international organisations normally seek tenders through competitive procurement processes. During these processes, it is crucial that all LINQ personnel strictly follow the rules and the guidelines of each institution or organisation 4. CHOICE OF PARTNERS AND SUBCONTRACTORS This Code applies directly or through equivalent guidelines or instructions in all companies and joint ventures where LINQ has a majority shareholding and whenever it controls a consortium. In other situations, LINQ companies should make continuous efforts to ensure that the partner who controls the joint venture or consortium applies equivalent principles. LINQ companies should favour the selection of their industrial and business partners on the basis of their ability to comply with our business principles in terms of safety, health, environment and quality. The same applies to the choice of subcontractors. 4 The United Nations Financial Regulations and Rules, as promulgated by Secretary-General's Bulletin ST/SGB/2013/4 dated 1 July 2013, govern the procurement functions of the United Nations. The Classic Directive governs the European Union rules on procurement: Contracts for public works, public supply and public service EU directive 2014/18. Contracts and purchase orders made by NATO are subject to a number of provisions: 21

22 PERFORMANCE OBLIGATIONS After contract award, contractors must meet numerous obligations specific to the institutional client, including strict compliance with the terms of the contract, as well as strict adherence to the technical and financial offer, delivery schedules, milestones and other performance commitments. LINQ companies should avoid all deviations from the terms of contracts and implement a firm control system to guarantee the highest level of adherence with the agreed terms. AUDITS LINQ personnel (in particular project managers and financial officers) must cooperate with the officials designated by the Institution and / or Government to facilitate timely and efficient performance of audits and examinations required under a contract. All records and data must be internally approved prior to release. GIFTS AND HOSPITALITY The offering and receiving of gifts and hospitality, including travel-related expenses, for officials of governments and international organisations is particularly restrained. LINQ personnel and third parties must not offer anything of value to any official or employee of any government or international institution in an attempt to improperly influence any act or decision of such official, employee or managers for the purpose of promoting the business interests of LINQ companies. 22

23 Gifts and hospitality must never influence business decisions and must not place any LINQ company or LINQ personnel under any obligation. LINQ personnel must keep a record of any gifts or favours received from business contacts with a value greater than 100 euros. DISTRIBUTION OF LINQ S CODE OF CONDUCT AND BUSINESS ETHICS LINQ companies must distribute this Code or equivalent guidance or instruction to all employees, affiliates and applicable third parties. New employees must receive a copy of the Code prior to the signature of their employment contract and are required to familiarise themselves with it. Any current or new employee of LINQ and of one of its companies is requested to affirm compliance with the Code by signing the Declaration of Compliance, a sample of which Is attached below. Any question or request of clarification should be addressed to managers or the appropriate ethical Ethics Officer. 23

24 LINQ REFERENCES This Code is inspired by the highest international standards. The following websites provide further detail about the standards with which LINQ companies are committed to comply: UN Global Compact: The Voluntary Principles on Security and Human Rights: United Nations Guiding Principles on Business and Human Rights: EN.pdf International Labour Organization: en/index.htm OECD Guidelines for Multinational Enterprises: ICoC International Code of Conduct for Private Security Service Providers: Le Document de Montreux: ETHICS TRAINING LINQ company boards of directors and all LINQ personnel should participate in regular ethics and compliance training. Ethics awareness training should be carried out annually; compliance training should be carried out as assigned. 24

25 DECLARATION OF COMPLIANCE WITH LINQ S CODE OF CONDUCT AND BUSINESS ETHICS As set forth in its Code of Conduct and Business Ethics, LINQ and its affiliate companies are committed to the highest standards of integrity, ethical behaviour, and compliance with all applicable laws and regulations. As an employee (or prospective employee) of LINQ or of one of its companies, I support these objectives and affirm the following: 1. I have read and understand the Code of Conduct and Business Ethics. I understand that the Code sets forth the minimum standards of conduct with which I must comply. 2. I am personally responsible for complying with all sections of the Code of Conduct and Business Ethics and acting ethically and with integrity at all times. 3. I will be held accountable for my actions, and any violations of the Code may result in disciplinary action, up to and including termination of the contract. 4. It is my duty and responsibility to report any known or reasonably suspected violations of the Code or LINQ policies. I may report such violations to my line manager, Ethics Officer, or LINQ Ethics Officer, and I may do so anonymously. 5. It is my responsibility to understand the Code of Conduct and Business Ethics, and I should direct any questions to my line manager or the Ethics Officer. Signature Date Print Name Title and Company Name This attestation must be completed and returned to your line manager or HR manager for retention with your personnel records. 25

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