COMPANY, INC. Corporate Policies and Procedures. Policy Number: 3.5 Date Issued/Revised: May 16, 2003 May 25, Person, CEO

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1 COMPANY, INC. Corporate Policies and Procedures Policy Number: 3.5 Date Issued/Revised: May 16, 2003 May 25, 2004 Subject: Corporate Records Retention Approvals: Person, CEO Person, Corporate Controller Person, V.P. Administration & General Counsel PURPOSE: The objective of this Policy is to establish mandatory guidelines for the Company and each of its subsidiaries to manage, maintain and dispose of records in an orderly, reasonable and lawful manner. It is the purpose of a records retention policy to facilitate the following: 1. All records are retained for the period required by applicable state and federal laws and regulations. 2. Adequate records will be developed and maintained to document the company's compliance with all relevant laws and regulations. 3. All records necessary for business reasons are retained for a period of time that will reasonably assure the availability of those records when needed. 4. Vital records will be identified and appropriately safeguarded. 5. All records not necessary for legal and business reasons can be destroyed in order to reduce the high cost of storing, indexing and handling the vast amount of documents and paper which would otherwise accumulate. 6. Destruction of records shall take place only in compliance with this standard policy that has been developed for business reasons in order to avoid the inference that any document was destroyed in anticipation of a specific problem. 7. Documents that are not subject to retention may need to be retained due to otherwise unusual circumstances, such as litigation or government investigation. 8. Records maintained on microfilm and microfiche, magnetic tape or other electronic data processing storage media are legally acceptable media for records retention and are governed by the same guidelines as other records. 9. It is imperative that the Company knows which documents have been retained and which documents have been discarded. Therefore, extra files including correspondence, notes, 1

2 SCOPE: memoranda, computer discs, tapes, etc. which are maintained in individual offices, or any other approved off-site location are subject to these guidelines and shall not be retained in excess of these guidelines. Such records shall not be stored and maintained at home or on personal computers at ay time. This Policy is applicable to all employees and records of Company, Inc. and its subsidiaries. POLICY: Responsible Officers The records retention program shall be annually reviewed and approved by the Corporate Controller and General Counsel. Suggested changes should be submitted to the Corporate Controller Training and Audit of Retention Plan Each Accounting Manager shall be responsible for annually training and auditing the actual implementation of this Policy at the various operating units. In January of each year, the Accounting Manager at each facility will review closed files to determine any that are subject to destruction for that year. He/she shall first review destruction with the Responsible Person listed on the files to be destroyed to confirm that destruction is appropriate and then proceed with destruction Electronic Files Electronic files, whether on floppy discs or hard drives, are considered company records that are subject to this Policy. The Vice President of Information Technology shall maintain a procedure to destroy electronic records according to the Retention Schedule established by this Policy. Destruction shall be complete, using software that prevents such destroyed files from being reconstructed or retrieved Marking of Files and Documents When documents are placed in storage or otherwise removed from active use, such files and documents shall be marked with the destruction date (or Permanent notation) and indexed so as to allow ease of location at the appropriate date for destruction. If files within the same storage box have different destruction dates, all dates will be noted on the outside of the box, and individual files will be marked with their respective destruction dates, all dates will be noted on the outside of the box, and individual files will be marked with their respective destruction date. Physical file boxes shall be labeled as follows: Contents: [Describe] Facility: Department: Responsible Person: Date Placed in Storage: Destruction Date(s): 2

3 1.05. Storage Location The Accounting Manager at each location shall designate the storage location at the respective facility. Once removed from active file location, written records shall be boxed and stored in a central location at each facility. Company records and files may not be stored at home or on personally-owned computers, including duplicate copies Secure Medical Record Storage Due to federal law requirements, all files which contained medical or health information about any current or former employee must be stored in a locked storage area accessible only by approved personnel. The storage boxes shall be marked in red with the words Confidential Medical Records Access Restricted Contact General Counsel Exceptions Requests for exceptions from this Policy should be submitted first to the Corporate Controller and General Counsel and must be supported by evidence that the basic objections above will be met. Exceptions shall not be routinely granted, as it is vital to the proper and efficient use of the Policy to have regular destruction of documents to avoid the inference of improper destruction. If for any reason it is felt that a document should be retained due to an unforeseen circumstance, the General Counsel must be consulted. When litigation or investigations occur, the General Counsel will notify the appropriate departments and direct that relevant categories of documents be labeled for retention until further notice. The Chairman/CEO may exempt from destruction, document he has created or received that he determines constitutes historical or strategic value to the Company Interpretation of Policy The Corporate Controller and General Counsel will be responsible for interpreting any portions of this Policy or the records retention plans as they may apply to specific situations Record Retention Schedule Attached are the Retention periods for various types of documents in both text (Ex. A) and chart (Ex. B) formats. If a type of document is not listed, the Corporate Controller or General Counsel shall be consulted to determine an appropriate retention period and whether this schedule should be amended to include such documents. 3

4 Exhibit A Company, Inc. Corporate Records Retention Schedule All written or electronic corporate documents should normally be retained according to the following schedule. (P) indicates permanent retention. A. Letters to be Destroyed Within One Year. 1. Routine letters and notes that require no acknowledgment or follow-up, such as notes of appreciation, congratulations, letters of transmittal and plans for meetings. 2. Form letters that require no follow-up. 3. Copies of inter-departmental or other company correspondence that have a copy retained in the originating department's file. 4. Letters of general inquiry and replies that complete a cycle of correspondence. 5. Letters or complaints requesting specific action that have no further value after changes have been made or the appropriate action has been taken, such as name or address change. 6. Other letters of inconsequential subject matter or which no further reference will be required. 7. Chronological correspondence files. 8. Electronic (1 year). B. Letters Retained Four Years. The following are examples: 1. Letters explaining but not establishing company policy. 2. Letters establishing credit. 3. Collection letters after the account is paid. 4. Quotation letters where no contract results. C. Letters Retained for the Life of the Principal Document that It Supports or Retained Indefinitely. The following are examples, yet specific retention periods should be defined in the appropriate functional category or department. 1. Letters pertaining to patents, copyrights, bills of sale, permits, etc. 2. Letters which constitute all or a part of a contract or which are important in the clarification of certain points in a contract. 3. Letters denying liability of the company. D. General Corporate Records. The office of General Counsel shall be responsible for establishing adequate record retention programs and policies for all documents normally handled by that office. The office of General Counsel shall keep all legally required documents and documents of business significance and, in addition, shall keep or provide for the retention of such other documents as may have historical value. 1. Records of incorporation, by-laws and amendments thereto for the corporation and subsidiaries (P) 2. Qualification to do business in states and related records (P) 3. Corporate seals (P) 4

5 4. Stock transfer and stockholder records (P) 5. Dividend records (P) 6. Minute books of Corporate and Subsidiary Boards. Board committees and stockholder meetings (P) 7. Annual reports, quarterly reports and proxy material (P) 8. Shareholder proxies (P) 9. Board of Directors Packet (5 years) 10. Acquisition files (P) 11. All financing documents, credit agreements, loan agreements, commitments, etc. (review ten years after satisfaction or termination) 12. Divestiture files (review after twenty years) 13. Cancelled stock certificates (review by Corporate General Counsel after twenty years) E. Legal Files and Papers. 1. Requests for departure from Records Retention Policy (P) 2. Litigation files including correspondence, depositions, discovery, responses and pleadings: a. Major litigation (as determined by General Counsel on a case by case basis) b. Other litigation (one year after expiration of appeals or time for filing of appeals) 3. Written arbitration decision (P) 4. Court orders involving the Company (P) 5. Legal memoranda and opinions subject matter files. (five years after close of matter. Thereafter, review for utility and historic value.) F. Contracts. 1. Contracts and related correspondence and documents - commercial (six after expiration or termination plus written approval of General Counsel) 2. Contracts - government (three after completion) 3. Licensing and distribution agreements including production and royalty data (six after expiration or termination plus written approval of General Counsel) G. Pension Documents and the Supporting Employee Data. Pension documents and supporting employee data shall be kept in such manner and for such periods that the company can establish at all times whether or not any pension is payable to any person and if so, the amount of such pension. Review every 10 years. 1. Pension plans and all amendments thereto (P) 2. Pension plan determination letters (P) 3. Records of employee service and eligibility for pension (including hours worked and any breaks in service) (P) 4. Required personal information on employees and former employees. (Name; address; social security number; period of employment; pay type, either hourly or salary) (P) 5. Records of plan administrator setting forth authority to pay (P) 6. Records of pension paid to employees or their beneficiaries (six years after final payment may be kept by Plan Recordkeeper). 7. Reports of pensions or pension plans filed with the Department of Labor or the Internal Revenue Service (six years after filing) H. Personnel. 5

6 1. Original union agreements (P) 2. Invention assignment forms (P) 3. Records showing employee exposure to potentially hazardous substances (P, except documents may be discarded thirty years after termination of all affected employees) 4. Medical histories or health data (P) must be kept in separate files marked confidential and accessible only to HR Department or with approval of General Counsel 5. Earnings records (general) (P) 6. Employees' personnel records, including individual attendance records, wage and salary history, application forms, performance evaluations, termination papers, exit interview records, withholding information. garnishments, test results (individual), employment contracts, separation agreements, etc. (P) 7. Attendance records (general) (three years) 8. Job descriptions (three after superseded) 9. Safety or injury frequency reports (ten years) 10. Affirmative action programs (five years after superseded) 11. EEO- I and EEO-2 Employer information reports (four years after superseded or filing, whichever is longer) 12. Applications, resumes, results of pre-employment physicals, interview notes, and related correspondence (non-hired applicants) a. Advertised job openings (two years from date of non-hire decision) b. Unsolicited applications and resumes (one year) 13. Correspondence with employment agencies and advertisements for job openings (one year from date of hiring decision) 14. Wage and salary surveys (three years) 15. Census reports and headcount comparisons (three years) 16. Employee handbooks (P) 17. Household moves (three years after move) I. Insurance Records. 1. Policies: a. Workers compensation (P) b. Product liability (P) c. Umbrella (P) d. Property (P) e. Fidelity & crime (P) f. General liability (P) g. Other 3rd party (P) 2. Certificates a. Issued on behalf of Company (three years) b. Issued to Company (P) 3. Group insurance plans: a. Active employees (until plan is amended or terminated) b. Retirees (P or until six years after death of last eligible participant) 4. Audits or adjustments (two years after final adjustment) 5. Claims files (including correspondence, medical records, injury documentation, etc.): a. Workers compensation (ten years after termination of employment) b. Product liability (open if no litigation, five years after last 6

7 correspondence or contact with claimant if litigation) c. 1st party (five years after last correspondence or contact with insurer) d. Other 3rd party (five years after last correspondence or contact with 3rd party) e. Long term disability (ten years after the earlier of: return to work, retirement or death) f. Group life (five years after close) 6. Release/settlements (twenty-five years) 7. Inspections (three years) 8. Loss runs (ten years) 9. Annual loss summaries (ten years) 10. Journal entry support data (seven years) J. Accounting and Finance. 1. Annual audited financial statements (P) 2. General ledgers (ten years*) 3. General journals and other posting & control media subsidiary to the general ledgers (seven years*) 4. Annual audit work-paper package (seven years*) 5. Monthly financial statements (seven years*) 6. Bank statements and cancelled checks (seven years*) 7. Original copies of accounts payable invoices and employee expense reports: Normal trade payables (seven years*) 8. Freight bills (three years*) 9. Accounts receivable invoices (four years*) 10. Accounts receivable cash receipts files (four years *) 11. Annual plans and budgets (two years) 12. Strategic plans (two years after termination of plan period) 13. Census bureau and other government surveys (seven years) 14. Physical inventory records (seven years *) 15. Appropriation requests (renew one year after post completion.) * The Corporate Controller will annually issue a directive outlining the specific years to be destroyed. 16. Letters of Credit or Guaranty (2 years after expiration). K. Tax Records. All corporations required to file a tax return of any kind must keep books of account or records, including inventories, as are sufficient to establish the amount of gross income, deductions, credits or other matters required to be shown in any such return. These documents and records shall be kept for as long as the contents thereof may become material in the administration of federal, state, and local income, franchise, and property tax laws. The corporation shall keep sufficient records to prove its cost basis and to compute its earnings and profits permanently. 1. Tax returns (income, franchise, property) (P) 2. Tax bills, receipts and statements (P) 3. Tax work-paper packages originals (P. Operating division copies to be retained for seven years) 4. Payroll tax records (seven years*) 5. Sales and use tax records (seven years*) 6. Excise tax records (seven years*) 7

8 * Represents the estimated retention period for storage planning purposes. Actual retention will be based on the specific statute of limitations governing each return and the necessity to keep documents for years which remain open pending settlement with the taxing authorities. The Corporate Controller will annually issue a directive outlining the specific years to be destroyed. L. Payroll Documents. Payroll documents and supporting data shall be kept in such a manner that the company can prove that it has fulfilled its responsibilities under the Wage and Hour Rules of the Department of Labor, as well as the Walsh-Heasley Act. Also, payroll records must be such as to enable the company to compute the payment of any pension. (See section G above.) 1. Employee earnings record (P) 2. Labor distribution cost records (seven years) 3. Payroll registers (gross and net) (seven years) 4. Unclaimed wage records (six years) 5. Employee deduction authorizations (four years after termination) 6. Assignments, attachments and garnishments (three years after payment or settlement) 7. Time cards and sheets (two years) M. Plant and Property Records. 1. Original purchase, sale or lease agreement of plant facility (P) 2. Correspondence, property deeds, easements, licenses, rights of way and miscellaneous documents pertaining to sold plant facilities (ten years plus approval of General Counsel) 3. Property and liability insurance policies (P) 4. Fixed asset ledgers (year-end run) (seven years plus written approval of Corporate Controller) 5. Mortgages (ten years after satisfaction) 6. Plant inspection and safety audit reports (three years) N. Research and Development. 1. Original patents, trademarks and copyrights (Life of patent, trademark or copyright plus three years) 2. Minutes of all technical meetings (twenty years plus written approval of General Counsel) 3. Invention notebooks and invention records (twenty years plus written approval of General Counsel) 4. Laboratory notebooks, supporting data and test data (twenty plus written approval of General Counsel) 5. Outside submissions of new product ideas (twenty years plus written approval of General Counsel) O. Safety and Environmental Documents. The company must keep all documents in relation to employee and public health and safety for such periods as will enable it to demonstrate compliance with an applicable regulation or standard. These standards and regulations are in a state of continual expansion and change. Following is a current list of widely applicable rules: 1. Any government issued permit or authority relating to environmental laws or regulation (P) 2. Consent decrees, safety orders or other administrative orders regarding the environment or the safety and health of employees (P) 8

9 3. Mechanical power press: records of periodic regulation inspection (P) 4. Industrial slings: inspection records and repair records (one year) 5. Carcinogen Records: a. Authorized personnel rosters (twenty years) b. Medical records (thirty years) c. Monitoring or inspection reports (P) 6. Ground fault: testing records (P or until superseded) 7. Ethylene oxide testing records (See 29 CFR ) (P) 8. Environmental site files including insurance claims (P) 9. Records relating to disposal of hazardous waste (P) 10. Records relating to disposal of non-hazardous plant waste (three years) 11. Records relating to beneficial re-use of foundry by-products (20 years) P. Manufacturing. 1. Lab test reports (20 years plus written approval of General Counsel) 2. Product tooling, design, specifications and research data (twenty years) 3. Engineering change requests (ten years) 4. Engineering change notices (ten years) 5. Work orders (three years) 6. Bills of material (two years) 7. Safety related tests and inspection reports for existing products (five years) 8. Records showing quantities, sources, costs, shipment dates and related information for products assembled abroad with U.S. components (five years from date of re-entry) Q. Quality Control and Inspection. 1. Quality Manual (P) 2. Work Instructions (P) 3. Management Review Records (three years) 4. Contract Review Records (Life of Product + one year) 5. Approved Suppliers Lists (five years) 6. Customer supplied Product records (Life of Product + 3 years) 7. Identification & Traceability Records (Life of Product + 3 years) 8. Process Control records (Life of Product + 3 years) 9. Inspection and Test records (Life of Product + 3 years) 10. Inspection, Measuring and Test Equipment (Life of Product + 3 years) 11. Non-conforming product records (Life of Product + 3 years) 12. Corrective action records (Life of Product + 3 years) 13. Internal Quality Audit records (three years) 14. Training records (ten years) 15. PPAP Records (Life of Product + 3 years) 16. Tooling Records (Life of Product + 1 year) 17. Purchase Orders and Amendments (Life of Product + 1 year) R. Shipping and Transportation. 1. Freight bills (three years) 2. Bills of lading, waybills (two years after delivery) 3. Freight claims (two years after settlement) 4. Rates and tariffs (one year after superseded) S. Sales and Marketing. 1. Advertising copy and marketing programs (five years) 2. Copies of packaging materials and instructions (including MSDS sheets) (five 9

10 years) 3. Customer order files (four years) 4. Customer correspondence files (four years) 5. Salesman's call reports (ten years) 6. Sales department copies of invoices (one year) 7. Export certificate of origin and information necessary to prepare certificate for exports to or imports from Canada (five years) 8. NAFTA Certificates (four years) 9. Records relating to duty drawbacks on exports (four years) T. Credit Relating to Customers. 1. Application for credit, approval forms. qualification reports (one after account becomes inactive) 2. Collection litigation files (three after legal settlement and satisfaction of judgment) 3. Correspondence regarding collection (two years) 4. Customer financial statements (four years after last order from customer) 5. Guarantees and subordination agreements (three years after termination and settlement of account) 6. Security agreements & financing statements (three years after satisfaction) U. Procurement Material Control. 1. Purchase order register (six years) 2. Vendor files (requisitions, purchase orders, quotations, correspondence) (six years) 3. Inventory control reports (three years) 4. Production schedules (one year) V. Plant Engineering/Capital Improvement Project Files. 1. Proposed Project Files containing all documents, drawings, proposals, etc., electronic or otherwise associates with a proposed, but never implemented improvement project (Review after 4 years to determine obsolescence) 2. Completed Project Files containing all documents, drawings, proposals, etc., electronic or otherwise associated with a complete plant improvement project (10 years or life of the equipment, whichever is greater). 3. Plant Equipment Quotation (4 years) 4. Existing plant/equipment layout or engineering drawings (Review every 2 years for accuracy and discard obsolete drawings. Maintain current drawings at all times.) W. General. 5. Books, professional periodicals, published reports, etc. (review annually for useful and discard obsolete material) 6. Charitable contribution records (seven years) 7. Consultants reports (two years) 8. Departmental budgets and related work sheets (two years) 9. Major corporate and division policy and procedure manuals (Originating department (P) receiving departments retain only current version) 10. Major speeches by corporate officers (four years, thereafter review for historical value) 11. Material of historic value (pictures, publications. etc) (P in custody of communications officer) 12. Project files not otherwise classified (review at close of project) 10

11 13. Trade association materials (review annually for usefulness) 14. Customer RFDs. Specifications, cost sheets, prints, and out quotating and review forms if no contract results (four years) 15. Supply Agreements (six years plus approval of General Counsel) 16. Surcharge or Price Change, notification or agreements (ten years) 17. Monthly Sales Reports/Forecasts (four years) 18. Monthly Sales Meeting Notes (two years) 19. Customer-generated performance reports (Life of Product + 3 years) 20. Sales presentations (four years) 11

12 Number of Years Document To Be Retained Category Permanent < Letters to be Destroyed Within One Year Company, Inc. Corporate Records Retention Schedule Routine letters and notes that require no acknowledgement or follow-up, such as notes of appreciation, congratulations, letters of transmittal and plans for meeting Form letters that require no follow-up Copies of inter-departmental or other company correspondence that have a copy retained in the originating department's file Letters of general inquiry and replies that complete a cycle of correspondence Letters of complaints requesting specific action that have no further value after changes have been made or the appropriate action has been taken, such as name or address change Other letters of inconsequential subject matter or which no further reference will be required Chronological correspondence files Electronic Letters Retained Four Years Letters explaining, but not establishing company policy Letters establishing credit Collection letters after the account is paid Quotation letters where no contract results Letters Retained for the Life of the Principal Document that it Supports or Retained Indefinitely Letters pertaining to patents, copyrights, bills of sale, permits, etc. Letters which constitute all or a part of a contract or which are important in the clarification points in a contract Letters denying liability of the company General Corporate Records Records of incorporation, by-laws and amendments thereto for the corporation and subsidiaries Qualification to do business in states and related records Corporate seals Stock transfer and stockholder records Dividend records Minute books of Corporate and Subsidiary Boards, Board committees and stockholder meetings Annual reports, quarterly reports and proxy material Shareholder proxies Board of Directors Meeting Packet 1

13 Corporate Records Retention Guidelines Number of Years Document To Be Retained Category Permanent < Acquisition files All financing documents, credit agreements, loan agreements, commitments, etc. (review 10 years after satisfaction or termination) Divestiture files (review after 20 years) Cancelled stock certificates (review by General Counsel after 20 years) Legal Files and Papers Requests for departure from Records Retention Policy Litigation files including correspondence, depositions, discovery, responses and pleadings regarding major litigation (as determined by General Counsel on a case by case basis) Litigation files including correspondence, depositions, discovery, responses and pleadings regarding other litigation (one year after expiration of appeals or time for filing of appeals) Written arbitration decision Court Orders involving the Company Legal memoranda and opinions subject matter files (five years after close of matter, thereafter, review for utility and historic value) Contracts Contracts and related correspondence and documents - commercial (six years after expiration or termination plus written approval of General Counsel) Contract - government (three years after completion) Licensing and distribution agreements, including production and royalty data (six years after expiration or termination plus written approval of General Counsel) Pension Documents and Supporting Employee Data Pension documents and support employee data shall be kept in such manner and for such periods that the company can establish at all times whether or not any pension is payable to any person and if so, the amount of such pension. Review every 10 years. Pension plans and all amendments thereto Pension plan determination letters Records of employee service and eligibility for pension (including hours worked and any breaks in service) Required personal information on employees and former employees. (Name, address, social security number, period of employment, pay type, either hourly or salary) 2

14 Corporate Records Retention Guidelines Number of Years Document To Be Retained Category Permanent < Records of plan administrator setting forth authority to pay Records of pension paid to employees or their beneficiaries (may be kept by Plan recordkeeper) Reports of pension or pension plans filed with the Department of Labor or the Internal Revenue Service Personnel Original union agreements Invention assignment forms Records showing employee exposure to potentially hazardous substances (documents may discarded after 30 years after termination of all affected employees) Medical histories of health data (must be kept in separate file marked "confidential" and accessible only to HR Department or with approval of General Counsel HIPAA Privacy Notices, HIPAA Disclosure logs, authorizations, requests to amend PHI and related correspondence (P) HIPAA Privacy Consents and Authorizations HIPAA Privacy Notices Earnings records (general) Employees' personnel records, including individual attendance records, wage and salary history, application forms, performance evaluations, termination papers, exit interview records, withholding information, garnishments, test results (individual), employment contracts, separation agreements, etc. (P) Attendance records (general) Job descriptions (3 years after superseded) Safety or injury frequency reports, including OSHA 200 and 300 Logs Affirmative action programs (5 years after superseded) EEO-1 and EEO-2 Employer information reports (4 years after supseded or filing, whichever is longer) Applications, resumes, results of pre-employment physicals, interview notes, and related correspondence (non-hired applicants) - advertised job openings Applications, resumes, results of pre-employment physicals, and related correspondence (non-hired applicants) - unsolicited applications and resumes Correspondence with employment agencies and advertisements for job openings (1 year from date of hiring decision) Wage and salary surveys Census reports and headcount comparisons 3

15 Corporate Records Retention Guidelines Number of Years Document To Be Retained Category Permanent < Employee handbooks Household moves (3 years after move) Insurance Records Workers Compensation Insurance Policy Product Liability Insurance Policy Umbrella Insurance Policy Property Insurance Policy Fidelity & Crime Insurance Policy General Liability Insurance Policy Other third party insurance policies Certificates issued on behalf of the Company Certificates issued to Company Group insurance plans covering active employees Group insurance plans covering retirees Audits or adjustments (2 years after final adjustment) Workers compensation claims files (including correspondence, medical records, injury documentation, etc.) (10 years after termination of employment) Product liability claims files (open if no litigation, five years after last correspondence or contact with claimant if litigation) First party claims files (five years after last correspondence or contact with insurer) Other third party claims files (five years after last correspondence or contact with third party) Long term disability claims files (ten years after the earlier of: return to work, retirement or death) Group life claims files (five years after close) Release/settlements Inspections Loss runs Annual loss summaries Journal entry support data Accounting & Finance Annual audited financial statements General ledgers General journals and other posting & control media subsidiary to the general ledgers Annual audit work-paper package Monthly financial statements 4

16 Corporate Records Retention Guidelines Number of Years Document To Be Retained Category Permanent < Bank statements and cancelled checks Original copies of accounts payable invoices and employee expense reports; normal trade payables Freight bills Accounts receivable invoices Accounts receivable cash receipts files Annual plans and budgets Strategic plans (2 years after termination of plan period) Census bureau and other government surveys Physical inventory records Appropriation requests Letters of Credit or Guaranty (2 years after expiration) Tax Records Tax returns (income, franchise, property) Tax bills, receipts and statements Tax work - paper packages originals Payroll tax records Sales and use tax records Excise tax records Payroll Documents Employee earnings record Labor distribution cost records Payroll registers (gross and net) Unclaimed wage records Employee deduction authorizations Assignments, attachments and garnishments (3 years after payment or settlement Time cards and sheets Plant and Property Records Original purchase, sale or lease agreement of plant facility Correspondence, property deeds, easements, licenses, rights of way and miscellaneous documents pertaining to sold plant facilities (10 years plus approval of General Counsel) Property and liability insurance policies Fixed asset ledgers (year-end run) (7 years plus written approval of General Counsel) Mortgages (10 years after satisfaction) Plant inspection and safety audit reports 5

17 Corporate Records Retention Guidelines Number of Years Document To Be Retained Category Permanent < Research and Development Original patents, trademarks and copyrights (life of patent, trademark or copyright, plus 3 years) Minutes of all technical meetings (20 years plus written approval of General Counsel) Invention notebooks and invention records (20 years plus written approval of General Counsel) Laboratory notebooks, supporting data and test data (20 years plus written approval of General Counsel) Outside submissions of new product ideas (20 years plus written approval of General Counsel) Safety and Environmental Documents Any government issued permit or authority relating to environmental laws or regulation Consent decrees, safety orders or other administrative orders regarding the environment or the safety and health of employees Mechanical power press (P); records of periodic regulation inspection Industrial slings, inspection records and repair records Carcinogen Records: authorized personnel rosters Carcinogen Records: medical records Carcinogen Records: monitoring or inspection reports Ground fault testing records Ethylene oxide testing records (See 29 CFR ) Environmental site files including insurance claims Records relating to disposal of hazardous waste Records relating to disposal of non-hazardous plant waste Records relating to beneficial re-use of foundry by-products Manufacturing Lab test reports (20 years) Product tooling, design, specifications and research data Engineering change requests Engineering change notices Work orders Bills of material Safety related tests and inspection reports for existing products Records showing quantities, sources, costs, shipment dates and related information for products assembled abroad with U.S. components (5 years from date of re-entry) 6

18 Corporate Records Retention Guidelines Number of Years Document To Be Retained Category Permanent < Quality Control and Inspection Quality Manual (P) Work Insturctions (P) Management Review Records Contract Review Records (life of product & service + 1 year) Approved Suppler List Customer-supplied Product records (life of product & service + 3 years) Identification and traceability records (life of prodcut & service + 3 years) Process Control Records (life of product & service + 3 years) Inspection and Test Records (life of product & service + 3 years) Inspection, Measuring & Test Equipment (life of product & service + 3 years) Non-conforming product records (life of product & service + 3 years) Corrective Action Records (life of product & service + 3 years) Internal Quality Audit Records Training Records PPAP Records (life of product & service + 3 years) Tooling Records (life of product & service + 1 year) Purchase Orders & Amendments (life of product & service + 1 year) Shipping and Transportation Freight bills Bills of lading, waybills (2 years after delivery) Freight claims (2 years after settlement) Rates and tariffs (1 year after superseded) Sales and Marketing Advertising copy and marketing programs Copies of packaging materials and instructions (including MDSD Sheets) Customer order files Customer correspondence files (4 years) Salesman's call reports Sales department copies of invoices Export certificate of origin and information necessary to prepare certificate for exports to or imports from Canada NAFTA Certificates Records relating to duty drawbacks on exports 7

19 Corporate Records Retention Guidelines Number of Years Document To Be Retained Category Permanent < Credit Relating to Customers Application for credit, approval forms, qualification reports (1 year after account becomes inactive) Collection litigation files (3 years after legal settlement and satisfaction of judgment) Correspondence regarding collection Customer financial statements (4 years after last order from customer) Guarantees and subordination agreements (3 years after termination and settlement of account) Security agreements and financing statements Procurement Material Control Purchase order register Vendor files (requisitions, purchase orders, quotations, correspondence) Inventory control reports Production schedules Plant Engineering/Capital Improvement Project Files Proposed project files containing all documents, drawings, proposals, etc., electronic or otherwise, associated with a proposed, but never implemented improvement project (Review after 4 years to determine obsolescence) Completed Project Files containing all documents, drawings, proposals, etc., electronice or otherwise, associated with a complete plant improvement project (10 years or life of the equipment, whichever is greater) Plant Equipment Quotation (4 years) Existing plant/equipment layout or engineering drawings (Review every 2 years for accuracy and discard obsolete drawings. Maintain current drawings at all times.) General Books, professional periodicals, published reports, etc. (review annually for useful material and discard obsolete material) Charitable contribution records Consultants reports Departmental budgets and related work sheets Major corporate and division policy and procedure manuals Major speeches by corporate officers (review for historical value) Material of historical value (pictures, publications, etc.) 8

20 Corporate Records Retention Guidelines Number of Years Document To Be Retained Category Permanent < Project files not otherwise classified (review at close of project) Trade association materials (review for usefulness) Customer RFDs (specifications, cost sheets, prints, and out quotating and review forms - if no contract results) Supply Agreements (6 years plus approval of General Counsel) Surcharge or Price Change notification or agreements Monthly Sales Reports/Forecasts Monthly Sales Meeting Notes Customer-generated performance reports (life of product + 3 years) Sales Presentations 9

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