SONESTA SAN JUAN LLC

EMPLOYEE HANDBOOK
FOR HOTEL EMPLOYEES

December 2020
 TABLE OF CONTENTS

Section Page

A. INTRODUCTION ..................................................................................................................... 1
1.0 Purpose of Handbook and Disclaimer ............................................ 1
2.0 Collective Bargaining Agreement ................................................... 2
3.0 Equal Employment Opportunity, Non Discrimination And Anti-
Harassment Policy ........................................................................ 2

3.1 Equal Employment Opportunity and Non Discrimination....... 2

3.2 Anti-Harassment Policy ........................................................ 3
3.3 Complaints of Discrimination, Harassment or Domestic
Violence .............................................................................. 7
3.4 Protection Against Retaliation .............................................. 7
3.5 Discrimination, Harassment or Domestic Violence
Investigation ....................................................................... 7
3.6 Disciplinary Action .............................................................. 7

B. ATTENDANCE AND HOURS OF WORK ....................................................................... 8

4.0 Employment Classifications .......................................................... 8

4.1 Exempt/Nonexempt Classifications ..................................... 8

4.2 Full-time and Part-time Hotel Employees .............................. 8
4.3 Temporary Employees ......................................................... 8
4.4 Fixed-Term Employees ........................................................ 8
4.5 On-Call Employees .............................................................. 8
4.6 Probationary Employees ...................................................... 8

5.0 Attendance and Hours of Work ..................................................... 8

5.1 Regular Working Hours ........................................................ 9

5.2 Attendance ......................................................................... 9
5.3 Tardiness .......................................................................... 10
5.4 Overtime for Nonexempt Employees .................................. 10
5.5 Meal and Rest Periods ....................................................... 10
5.6 Lactation Accommodation Policy ....................................... 11

C. COMPENSATION ................................................................................................................. 12
6.0 Pay and Time Records ................................................................. 12

6.1 Pay.................................................................................... 12
6.2 Call-Back Pay ..................................................................... 12
6.3 Cancellation Pay ................................................................ 12
6.4 Pay for Attending Mandatory Meetings/Trainings ............... 12

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 6.5 Tips .................................................................................. 12
6.6 Time Records .................................................................... 14
6.7 Payroll Deductions and Safe Harbor Policy ......................... 14
6.8 Garnishments and Attachments ......................................... 16

D. BENEFITS................................................................................................................................. 16
7.0 Benefits ...................................................................................... 16
8.0 Worker’s Compensation .............................................................. 17
9.0 Paid Vacation, Holidays and Paid Sick Time ................................. 17

9.1 Vacation............................................................................ 17
9.2 Holidays ............................................................................ 18
9.3 Paid Sick Time ................................................................... 18

10.0 Short and Long Term Disability ................................................... 19

11.0 Employee Referral Bonus............................................................. 20
12.0 Tuition Assistance ...................................................................... 20
13.0 Employee and Friends and Family Programs ................................ 22

E. LEAVES OF ABSENCE ........................................................................................................ 22

14.0 Leaves of Absence ...................................................................... 22

14.1 Military Leave .................................................................... 22

14.2 Jury Duty and Witness in Criminal Cases ............................ 23
14.3 Bereavement Leave ............................................................ 23
14.4 Family and Medical Leave .................................................. 24
14.5 Medical Leave Policy for Non-FMLA Leave and Certain
Other Circumstances ......................................................... 30
14.6 Work During Leave ............................................................ 30
14.7 Newborn/Adoption Leave .................................................. 31
14.8 Special Leave for Domestic Violence .................................. 31
14.9 Other Leaves ..................................................................... 32

F. WORKPLACE RULES AND CONDUCT ....................................................................... 32

15.0 Rules of Conduct and Discipline .................................................. 32

15.1 Employee Duties ............................................................... 32

15.2 General ............................................................................. 32

16.0 Discipline ................................................................................... 34

17.0 Performance Appraisal and Wage/Salary Review .......................... 34
18.0 Personnel Files ........................................................................... 34
19.0 Relationships In The Workplace ................................................... 34
20.0 Anti-Violence Policy .................................................................... 35
21.0 Professional Appearance/Dress Code .......................................... 36

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 22.0 Alcohol ....................................................................................... 37
23.0 Drugs ......................................................................................... 37

23.1 Use of Prescription Medications ......................................... 37

24.0 Visitors in the Workplace ............................................................ 37

25.0 Solicitations and Distribution of Literature .................................. 38
26.0 Office Appearance ...................................................................... 38
27.0 Company Property/Searches ....................................................... 38

27.1 Company Property ............................................................. 38

27.2 Company Searches ............................................................ 39

28.0 Smoking ..................................................................................... 39

29.0 Guest Privacy and Confidentiality ................................................ 40
30.0 Designated Staff Entrance/Exit .................................................... 40
31.0 Nametags and Employee Identification Cards .............................. 40
32.0 Lockers ...................................................................................... 40
33.0 Hotel Keys .................................................................................. 41
34.0 Lost and Found ........................................................................... 41
35.0 Packages .................................................................................... 41

G. COMMUNICATION ............................................................................................................. 41
36.0 Communication .......................................................................... 41

36.1 Bulletin Boards .................................................................. 41

36.2 Personal Mail..................................................................... 42
36.3 Confidential and Proprietary Information and Media
Requests ........................................................................... 42

37.0 Electronic Communications Policy ............................................... 42

37.1 Email ................................................................................ 43

37.2 Internet Use ...................................................................... 44
37.3 Personal Communications Devices ..................................... 44
37.4 Illegal Activities Using Any Sonesta Systems or
Equipment ........................................................................ 45
37.5 Social Media ...................................................................... 46
37.6 Respect for Others ............................................................ 46
37.7 Transparency and General Guidance .................................. 47
37.8 Violations.......................................................................... 47

38.0 LEAVING SONESTA ...................................................................... 48

38.1 Notice, Exit Interviews and Return of Sonesta Property ....... 48

38.2 References ........................................................................ 48

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A. INTRODUCTION

Welcome to Sonesta San Juan LLC (“Sonesta”; “we” or “us”). This Employee
Handbook applies to all employees who work on site at Sonesta managed hotels
in Puerto Rico (“Hotel Employees”).

We are delighted you have chosen to be part of the Sonesta team. At

Sonesta, we value our team members as individuals who enhance our business
and our guests’ experiences with their unique skills and contributions. We
actively support professional growth and personal happiness in each of our
employees. Please review this Employee Handbook so you are well informed
regarding our policies and the benefits we offer. We hope that our generous
benefit package and a strong understanding of our policies and procedures will
enhance your experience as a member of the Sonesta team.

1.0 Purpose of Handbook and Disclaimer

This Employee Handbook contains information regarding the policies and

benefits offered by Sonesta to its Hotel Employees in Puerto Rico. If, after
reviewing this Handbook, you have questions, please request clarification from
any member of our Human Resources Department or your Supervisor.

A current version of this Employee Handbook may be accessed on

Sonesta’s intranet portal. Please contact Human Resources for instructions.

You will also periodically receive copies of Sonesta’s Code of Business

Conduct and Ethics and Insider Trading Policies and Procedures. These policies
are not contained in this Handbook, but are applicable to all employees and
available from our Human Resources Department.

THIS HANDBOOK IS INTENDED ONLY AS A SUMMARY OF OUR

PERSONNEL POLICIES, PRACTICES, RULES AND BENEFITS FOR YOUR
INFORMATION. THIS HANDBOOK IS NOT, AND SHOULD NOT BE CONSIDERED
AN AGREEMENT OR CONTRACT OF CONTINUED EMPLOYMENT, EXPRESS OR
IMPLIED. THE POLICIES, PRACTICES, RULES AND BENEFITS SET FORTH
HEREIN ARE SUBJECT TO CHANGE AT ANY TIME.

YOUR EMPLOYMENT WITH SONESTA IS VOLUNTARY AND MAY BE

TERMINATED AT ANY TIME, WITH OR WITHOUT PRIOR NOTICE OR CAUSE, BY
YOU OR SONESTA. NO ORAL STATEMENTS OR REPRESENTATIONS CAN
CHANGE THE PROVISIONS OF THIS EMPLOYEE HANDBOOK.

TO THE EXTENT THAT THIS HANDBOOK CONTAINS GUIDELINES AND

SUMMARIES OF SOME OF OUR BENEFIT PROGRAMS, WE AND OUR PLAN
ADMINISTRATORS RESERVE THE MAXIMUM DISCRETION PERMITTED BY LAW
TO INTERPRET, ADMINISTER, CHANGE, MODIFY OR ELIMINATE ANY RULES,
GUIDELINES, POLICIES, AND/OR BENEFITS DESCRIBED IN THIS HANDBOOK,
AT ANY TIME. THE ELIGIBILITY STANDARDS AND OTHER DETAILS
REGARDING OUR BENEFITS ARE CONTAINED ONLY IN THE ACTUAL PLAN
DOCUMENTS THEMSELVES. YOU SHOULD CONSULT THOSE DOCUMENTS FOR
FURTHER INFORMATION REGARDING OUR BENEFIT PLANS; COPIES ARE
AVAILABLE UPON REQUEST FROM OUR HUMAN RESOURCES DEPARTMENT.

THIS HANDBOOK SUPERSEDES ALL PRIOR HANDBOOKS, MANUALS,

POLICIES AND PROCEDURES, WRITTEN OR VERBAL. THE INFORMATION IN
THIS HANDBOOK IS INTENDED AS A GUIDE TO OUR POLICIES. WE RESERVE
THE RIGHT TO INTERPRET, ADMINISTER, CHANGE, MODIFY OR ELIMINATE
ANYTHING STATED IN THIS HANDBOOK IN OUR SOLE DISCRETION, WITH OR
WITHOUT NOTICE. WE RESERVE THE RIGHT TO DETERMINE THE
APPLICABILITY OF ANY POLICY OR PROCEDURE TO ANY PARTICULAR
SITUATION.

THIS HANDBOOK DOES NOT PROHIBIT PROTECTED CONDUCT OR

COMMUNICATIONS RELATING TO YOUR WAGES, HOURS OR WORKING
CONDITIONS, OR ANY OTHER CONDUCT PROTECTED BY SECTION 7 OF THE
NATIONAL LABOR RELATIONS ACT.

2.0 Collective Bargaining Agreement

This Employee Handbook applies to Hotel Employees who are covered by

a collective bargaining agreement (“CBA”) with a union, as well as those who are
not covered by a CBA. Wages, benefits, working conditions and other terms and
conditions of Hotel Employees covered by a CBA shall be governed by the
applicable CBA. If your employment is governed by a CBA and the CBA provides
greater or different benefits than those set forth herein, or if any policy herein
conflicts with the terms of the governing CBA, that CBA will apply. However, to
the extent the applicable CBA does not cover any specific term or condition of
employment, this Employee Handbook shall govern. Nothing in this Employee
Handbook is intended to violate any local, state or federal law or regulation,
including but not limited to the National Labor Relations Act.

Any Hotel Employee subject to a CBA should consult the terms of that CBA
for any applicable amendments to the policies in this Handbook.

3.0 Equal Employment Opportunity, Non Discrimination And Anti-

Harassment Policy

3.1 Equal Employment Opportunity and Non Discrimination

Sonesta’s policy is to provide equal employment opportunities by

prohibiting discrimination against any applicant, contractor, vendor or employee
on the basis of the following legally protected characteristics: race, color,
religion, national or ethnic origin, age, ancestry, sex, pregnancy (including
childbirth, lactation and related medical conditions), gender, gender identity,

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sexual orientation, social origin or condition, political beliefs, mental or physical
disability, genetic information (including characteristics and testing), being a
victim or being perceived as a victim of domestic violence, sexual aggression or
stalking, military service, veteran or disable veteran status, or membership in any
other category protected by applicable law.

In accordance with applicable law, we will extend all legal rights and
responsibilities to same sex spouses on the same basis as we extend those rights
and responsibilities to opposite sex spouses.

Our equal employment opportunity and nondiscrimination policy reflects

our attitude and intention to do the following:

1. Recruit, hire, train and promote for all positions without regard to
the legally protected characteristics listed above.

2. Ensure that promotion decisions are made consistent with principles

of equal employment opportunity.

3. Ensure that all personnel actions including, for example,

compensation, benefits, transfers, Sonesta sponsored training,
educational tuition assistance and social and recreation programs,
will be administered in accordance with the principles of equal
employment opportunity.

3.2 Anti-Harassment Policy

Our policy is to promote a workplace that is free from harassment based

on the following legally protected characteristics: race, color, religion, national
or ethnic origin, age, ancestry, sex, pregnancy (including childbirth, lactation and
related medical conditions), gender, gender identity, sexual orientation, social
origin or condition, political beliefs, mental or physical disability, genetic
information (including characteristics and testing), being a victim or being
perceived as a victim of domestic violence, sexual aggression or stalking, military
service, veteran or disable veteran status, or membership in any other category
protected by applicable local, state or federal law. We will not tolerate
harassment of employees in the workplace, or in other settings in which
employees may find themselves in connection with their employment. Further,
any retaliation against an individual who has complained about discrimination,
harassment or retaliation against individuals for cooperating with an
investigation of a harassment or discrimination complaint is unlawful and will not
be tolerated.

We will respond promptly to complaints of harassment and, where it is

determined that our policy has been violated, disciplinary action, up to and
including termination of employment may be taken.

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 3.2.1 Definition of Harassment and Sexual Harassment

3.2.1.1 Sexual Harassment Defined

Sexual harassment includes unwanted sexual advances, requests for

sexual favors or visual, verbal or physical conduct of a sexual nature when:

• Submission to such conduct is made a term or condition of

employment; or

• Submission to or rejection of such conduct is used as a basis for

employment decisions affecting the individual; or

• Such conduct has the purpose or effect of unreasonably interfering

with an employee's work performance or creating an intimidating, hostile or
offensive working environment.

Sexual harassment includes various forms of offensive behavior. The

following is a partial list:

• Unwanted sexual advances.

• Offering employment benefits in exchange for sexual favors.

• Making or threatening reprisals after a negative response to sexual

advances.

• Visual conduct: leering, making sexual gestures, displaying of

sexually suggestive objects or pictures, cartoons, posters, websites, emails or
text messages.

• Verbal conduct: making or using derogatory comments, epithets,

slurs, sexually explicit jokes, comments about an employee's body or dress.

• Verbal sexual advances or propositions.

• Verbal abuse of a sexual nature, graphic verbal commentary about

an individual's body, sexually degrading words to describe an individual,
suggestive or obscene letters, notes or invitations.

• Physical conduct: touching, assault, impeding or blocking

movements.

• Retaliation for making harassment reports or threatening to report

harassment.

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 This policy also protects employees from harassment by vendors or clients.
If harassment occurs on the job by someone who is not employed by Sonesta,
Hotel Employees should follow the procedures in this policy. This policy applies
to males who sexually harass females or other males, and for females who
sexually harass males or other females.

3.2.1.2 Other Types of Discriminatory Harassment

Harassment on the basis of any of the following legally protected

characteristics is prohibited: race, color, religion, national or ethnic origin, age,
ancestry, sex, pregnancy (including childbirth, lactation and related medical
conditions), gender, gender identity, sexual orientation, social origin or
condition, political beliefs, mental or physical disability, genetic information
(including characteristics and testing), being a victim or being perceived as a
victim of domestic violence, sexual aggression or stalking, military service,
veteran or disable veteran status, or membership in any other category protected
by applicable local, state or federal law.

Prohibited harassment includes but is not limited to, (a) verbal conduct
including threats, epithets, derogatory comments or slurs, (b) visual conduct
including derogatory posters, photography, cartoons, drawings or gestures, (c)
physical conduct including assault, unwanted touching or blocking normal
movement or (d) retaliation for making harassment reports or threatening to
report harassment.

3.2.1.3 Workplace Harassment (Mobbing)

This policy also prohibits workplace harassment (mobbing). Workplace

harassment is defined as ill-intended, unwelcomed, malicious, unwanted,
repetitive and abusive conduct which is arbitrary, unreasonable and/or
capricious; verbal, written and/or physical; performed repeatedly by the
employer, his agents, supervisors or employees; oblivious to the legitimate
interests of the employer's company, which violates the employee’s protected
constitutional rights and creates an intimidating, humiliating, hostile or offensive
work environment, not suitable for a reasonable person to perform his/her duties
or tasks in a normal manner.

Examples of conduct that constitute workplace harassment include the

following:

• slanderous and harmful expressions about a person, using foul

language;

• hostile and humiliating comments of professional incompetence in

the presence of co-workers;

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 • unjustified threats of termination stated in the presence of co-
workers;

• frivolous disciplinary actions;

• humiliating rejection of work proposals or opinions;

• public comments or jokes directed to the employee about physical

appearance or the manner of dress;

• public references to private, personal or family matters related to the

affected employee;

• assigning work functions clearly unrelated to employment

obligations; and

• an unjustified refusal to provide information or materials pertinent

and indispensable to fulfill the employment obligations.

The following actions will not be deemed workplace harassment:

• executing disciplinary authority;

• conduct geared towards protecting confidentiality;

• creation and promotion of regulations or memorandums to direct

the operation, maximize efficiency and employment evaluations related to
Sonesta’s general objectives;

• requests to comply with additional functions when it is necessary for

the continuity of services or to resolve difficult situations in Sonesta’s operations
or services; and

• Sonesta’s affirmative actions to comply with the obligations, duties

and prohibitions required by or imposed by law, among others.

3.2.1.4 Domestic Violence

We have a policy of zero tolerance regarding domestic violence. We will not

discriminate against persons who are victims of domestic violence, abuse or
stalking or are perceived to be victims as defined by law. Furthermore, we might
seek a court order if necessary to protect our employees or property. A full
description of our Domestic Violence Policy is contained in a document
distributed separately.

Our Human Resources Director is entrusted with the compliance of this

policy. Any information provided in connection with an allegation of domestic

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violence shall be kept confidential to the extent possible while complying with
Sonesta’s legal obligations.

3.3 Complaints of Discrimination, Harassment or Domestic

Violence

If you believe that you have been subjected to discrimination, harassment

or domestic violence, you should advise a member of our Human Resources
Department.

3.4 Protection Against Retaliation

Retaliation by another employee or by us for using the complaint procedure

described above, reporting harassment, discrimination, or domestic violence,
objecting to such conduct or for filing, testifying, assisting or participating in any
manner in any investigation, proceeding or hearing conducted by a governmental
enforcement agency is prohibited. Prohibited retaliation includes, but is not
limited to, termination of employment, demotion, suspension, failure to hire or
consider for hire, failure to give equal consideration in making employment
decisions, failure to make employment recommendations impartially, adversely
affecting working conditions or otherwise denying any employment benefit.

Please report any retaliation to a member of our Human Resources

Department. We will investigate any report of retaliatory conduct in a thorough
and objective manner. If a report of retaliation is substantiated, appropriate
disciplinary action, up to and including termination of employment, may be
taken.

3.5 Discrimination, Harassment or Domestic Violence

Investigation

Should we receive a complaint, we will undertake a thorough and timely

investigation.

3.6 Disciplinary Action

We will take such disciplinary action as is necessary under the

circumstances. Such action may range from counseling to termination of
employment and may include such other forms of disciplinary action we deem
appropriate under the circumstances.

The Equal Employment Opportunity Commission ("EEOC") and the Anti-

Discrimination Unit (“ADU”) of the Puerto Rico Department of Labor and Human
Resources will accept and investigate charges of unlawful discrimination at no
charge to the complaining party. You can find the nearest office of the EEOC and
ADU in your local telephone directory or by visiting www.eeoc.gov.

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B. ATTENDANCE AND HOURS OF WORK

4.0 Employment Classifications

4.1 Exempt/Nonexempt Classifications

Each Sonesta Hotel Employee is classified as exempt or nonexempt,

consistent with applicable laws. Nonexempt Hotel Employees receive overtime
compensation in accordance with applicable law. Exempt Hotel Employees are
not eligible for overtime pay.

4.2 Full-time and Part-time Hotel Employees

A full-time Hotel Employee is one who, in general, normally works 30

hours or more per week. A part-time Hotel Employee is an employee who, in
general, normally works fewer than 30 hours per week.

4.3 Temporary Employees

A temporary Hotel Employee is an employee who is assigned to a position

created for a designated period of time, generally not to exceed 3 months.
Temporary Hotel Employees are not eligible for Sonesta benefits, unless
otherwise required by applicable law.

4.4 Fixed-Term Employees

A fixed-term Hotel Employee is an employee hired pursuant to a fixed term

employment contract which, in the case of non-exempt Hotel Employees, will not
exceed 3 years or be renewed for a duration in excess of 3 years.

4.5 On-Call Employees

An on-call Hotel Employee is an employee who works only on an as-needed

basis at the request of the employee’s supervisor. On-call Hotel Employees are
not eligible for Sonesta benefits unless otherwise required by applicable law.

4.6 Probationary Employees

Non-exempt Hotel Employees are subject to an initial probationary period

of 9 months duration, and exempt Hotel Employees are subject to a probationary
period of 12 months. The employment of probationary employees might be
terminated at any time with or without just cause, and will not be subject to any
indemnity payment upon termination.

5.0 Attendance and Hours of Work

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 Sonesta’s policies regarding attendance and hours of work are set forth
below. These policies are subject to applicable law.

5.1 Regular Working Hours

Your Supervisor and/or our Human Resources Department will explain your
working hour expectations when you begin work with Sonesta.

For Hotel Employees who work varying shifts, schedules are posted each
week in a designated area of the hotel. Schedules are subject to change and it is
your responsibility to check the posted schedule. Misreading or failing to check
the schedule is not an excuse for absence or tardiness. Days off may vary
depending on hotel business needs. You may request changes to schedules from
your Supervisor, but you will be required to work the posted schedule unless
approval to work a different shift is expressly granted by your Supervisor. You
may not exchange shifts without prior authorization of both your Supervisor and
the Supervisor of the other employee.

5.2 Attendance

Employee attendance is important and regular attendance is expected of

every Hotel Employee. We take attendance into consideration during our annual
performance review and other performance assessments. Attendance other than
in accordance with Sonesta policy may result in disciplinary action, up to and
including termination of employment, consistent with applicable law. However,
Hotel Employees will never be disciplined for legally protected absences. By way
of example only, legally protected absences or tardiness include, but are not
necessarily limited to, the following: vacation, sick leave under a mandatory paid
sick leave law, time off under the Family and Medical Leave Act and state
maternity leave, time off under the Americans with Disabilities Act, the
Amendments to that Act and similar state law, time off for any legally protected
disability, including but not limited to, disabilities related to pregnancy,
childbirth or lactation (and related medical conditions), and time off under any
other state or federal leave law. We will evaluate incidences of absenteeism and
tardiness on a case by case basis. However, we will never subject a Hotel
Employee to disciplinary action or retaliation for an absence or tardiness that is
legally protected.

If you will be absent from work for any reason, notify your Supervisor no
less than two (2) hours prior to your scheduled starting work time, by telephone,
rather than by text message or email, unless there is an emergency that prevents
you from doing so. Such notification should include information as to your
planned return date. You should provide your Supervisor with as much advance
notice as possible of a planned absence. Failure to properly notify your
Supervisor may result in forfeiture of pay (if pay were warranted and consistent
with applicable law) for such absence. Any unexplained and unexcused absence

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may be deemed a voluntary resignation, except when the absence is legally
protected.

5.3 Tardiness

You are expected to be at work at your specified starting time. You should
notify your Supervisor as far in advance as possible if you will be late for any
reason. Tardiness is taken into consideration during the annual performance
review and during other performance assessments and may result in disciplinary
action, up to and including termination of employment, except when the
tardiness is legally protected.

5.4 Overtime for Nonexempt Employees

There are occasions when regular work hours may not be sufficient for an
employee to complete his/her work load. On such occasions, Hotel Employees
may be required to work additional hours.

For nonexempt Hotel Employees who do not receive tips, overtime is

compensated at the rate of time and one half for all hours worked in excess of 8
hours in a day, 40 hours per week, 6 consecutive days of work, and as otherwise
provided for by applicable law. A nonexempt Hotel Employee must obtain his/her
Supervisor’s advance approval to work overtime.

No nonexempt Hotel Employee should work any hours that are not
authorized in advance by his or her Supervisor. Nonexempt Hotel Employees are
not to start work early, work late, work during a meal break or perform any other
extra or overtime work (including, but not limited to, sending or responding to
work related emails outside of the employee’s regularly scheduled work hours)
unless authorized by a Supervisor to do so. Likewise, nonexempt Hotel
Employees are prohibited from performing any "off-the-clock" work. "Off-the-
clock" work means work an employee performs but does not report on an
electronic time record or paper timesheet. Any non-exempt Hotel Employee who
works “off the clock,” fails to report or inaccurately reports any hours worked
may be subject to disciplinary action, which may include termination of
employment.

A Supervisor’s overtime approval should be obtained in advance on the

Overtime Approval Form (which form is available from Human Resources). A
signed Overtime Approval Form by your Supervisor must accompany the
timesheet for the week in which you work overtime. Nonexempt Hotel Employees
who work overtime without proper approval may be subject to disciplinary action,
which may include termination of employment.

5.5 Meal and Rest Periods

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 Non-exempt Hotel Employees are provided with one meal period of 60
minutes in length each workday for every 5 consecutive hours of work. Said meal
period will be waived for any Hotel Employee working 6 hours or less during the
day, and for any employee who enjoys a first meal period and subsequently works
more than 5 consecutive hours but less than 12 hours that day. Supervisors will
schedule meal periods to accommodate operating requirements, beginning any
time after the second hour of work, and ending before the sixth consecutive hour
of work. Hotel Employees will be relieved of all active responsibilities and
restrictions during meal periods and will not be compensated for that time. Any
work performed during a statutorily-mandated meal period is subject to payment
at the rate of time and one half, and must be approved in advance by a Supervisor.

The meal period(s) can be reduced to 30 minutes, by mutual written

agreement. Please contact our Human Resources Department for additional
information. Full-time and part-time Hotel Employees at full service hotels that
have the necessary facilities are eligible to receive one (1) complimentary meal
per shift, which must be consumed in the area designated. Uniformed Hotel
Employees must remain in uniform to receive the complimentary meal. However,
you will be permitted to leave the premises during meal periods to the extent
desired and in accordance with applicable law.

5.6 Lactation Accommodation Policy

We will provide a reasonable amount of break time to accommodate a Hotel

Employee desiring to express breast milk for her child for a period of 12 months
commencing upon the employee’s reinstatement to work after maternity leave.
Non-exempt employees will receive up to 1 hour of pay each day in which they
work at least 7½ hours for this purpose, and 30 minutes of pay for each day that
they work 4 hours or more but less than 7½ hours. Any additional time required
by the employee will be unpaid. Hotel Employees should work with their
supervisors or our Human Resources Department to schedule and report any
extra break time that falls outside of the paid leave periods or rest and meal
periods. We will otherwise treat lactation as a pregnancy related medical
condition and address lactation related needs like we address other non-
incapacitating medical conditions, including requested time off for medical
appointments, requested changes in schedules and other requested
accommodations.

We will provide Hotel Employees with the use of an adequate room or a

private area, other than a bathroom, for any break time taken pursuant to this
policy.

A pregnant Hotel Employee should contact our Human Resources

Department during her pregnancy or before returning to work to identify her
need for a lactation area or to make any other arrangements necessary under this
policy.

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C. COMPENSATION

6.0 Pay and Time Records

6.1 Pay

Hotel Employees are paid on a biweekly basis, unless otherwise required

by applicable law. Paychecks are direct deposited or mailed no later than every
other Friday, and include pay for hours worked during the pay period ending on
the preceding Saturday. Our work week is from Sunday through Saturday.

6.2 Call-Back Pay

When a non-exempt Hotel Employee is notified by an authorized Sonesta

Supervisor that an issue exists requiring the employee to return to the workplace
when he/she was not scheduled to work (defined as a “call-back”), the employee
will be compensated for actual time worked but not less than 4 hours. Hotel
Employees who are exempt from overtime are not eligible for call-back pay.

6.3 Cancellation Pay

Non-exempt Hotel Employees who report to work at a scheduled reporting

time, but whose shift is cancelled before work begins are not entitled to receive
any “reporting” or “show-up” pay, unless it is otherwise required by applicable
law. In addition, if you begin working a scheduled shift and the total work time
for that shift is reduced, you are only entitled to receive wages based on time
actually worked, unless otherwise required by applicable law. If you have
questions, please contact your Supervisor or our Human Resources Department
for more information.

6.4 Pay for Attending Mandatory Meetings/Trainings

A non-exempt Hotel Employee who is required to attend a prescheduled

mandatory meeting or training outside his/her scheduled work hours will be
compensated for the number of hours for which the meeting or training is
scheduled to last, or the actual hours the meeting or training lasted, whichever
is greater.

6.5 Tips

6.5.1 Tip Disclosure

All Hotel Employees who receive tips (“Tipped Employees”) are expected to
report their tips to Sonesta in accordance with our procedures and policies.
These procedures and policies are available from your Supervisor or our Human

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Resources Department. Any failure to report tips may result in corrective and
disciplinary actions, up to and including termination. In addition, you are
responsible for reporting tips as taxable income on your annual tax return. You
are responsible for maintaining records of your tips for purposes of reporting
your income to state and federal authorities.

6.5.2 Tip Credit

We may be permitted to take a “tip credit” toward the total minimum hourly
wages we pay to certain Tipped Employees. This “tip credit” is determined by the
difference between the hourly wage rate paid directly by Sonesta and the
minimum hourly wage rate applicable in the states where Tipped Employees
work. As a result, the hourly rate paid directly by Sonesta to such employees
may be less than the standard statutory minimum hourly wage rate. However, in
no case will a Tipped Employee’s total compensation, including hourly wages and
tips, be less than the statutory minimum hourly wage rate applicable in the state
where that employee works. In addition, the tip credit cannot exceed the amount
of tips that the Tipped Employee actually receives.

All tips received by you must be retained by you, except for tips contributed
to a valid tip pooling or sharing arrangement. Any tip pooling or sharing
arrangement must be limited to Hotel Employees who customarily and regularly
receive tips.

At the time of hire, all Tipped Employees must first sign a form
acknowledging that they were informed of the following information: the amount
of cash/direct wage Sonesta is paying the employee; the additional amount
claimed by us as a tip credit; that the tip credit cannot exceed the amount of tips
that the employee actually receives; that all tips received by Tipped Employees
are to be retained by those employees except under a valid tip pooling or sharing
arrangement limited to employees who customarily and regularly receive tips;
and that the tip credit will not apply to any Tipped Employee unless the employee
has been informed of these provisions.

During new employee training, any new Hotel Employees will be paid the
applicable state and/or federal minimum wage. If, during training, a new Hotel
Employee is assigned to shadow an employee that customarily and regularly
receive tips, the new employee will not be entitled to share in the tips earned by
the employee he or she is shadowing.

6.5.3 Overtime for Tipped Employees

A Tipped Employee receives the same tip credit for overtime hours as for
regular hours. However, the amount of earned overtime is calculated based on
the applicable minimum wage in the state where the Tipped Employee works,
unless otherwise required by applicable law.

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 6.6 Time Records

All Hotel Employees are provided with either an electronic time recorder or
paper timesheet. Electronic or paper timesheets are to be recorded daily and
completed accurately. Non-exempt Hotel Employees must record all time worked,
including actual starting and stopping times for each day, all time worked (if any)
during permitted meal periods and all extra or overtime work (if any) performed
outside of the employee’s regularly scheduled work hours. All Hotel Employees
must record days they are out for sick or vacation/personal reasons.

It is a violation of our policy for any Hotel Employee to falsify a time record
or timesheet, or to alter another employee's time record or timesheet. It is also
a violation of our policy for any Hotel Employee or Supervisor to instruct another
employee to incorrectly or falsely report hours worked or alter another
employee's time record or timesheet to under- or over- report hours worked.
Intentional and inaccurate reporting of hours worked or tampering with
electronic or paper timesheets will be deemed to be falsification of time records
and may result in disciplinary action, up to and including termination of
employment. Any request to (1) incorrectly or falsely under- or over- report hours
worked, or (2) alter another employee's time records to inaccurately or falsely
report that employee's hours worked, should be reported immediately to our
Human Resources Department. Any violation of this policy may lead to
disciplinary action, up to and including termination of employment.

6.7 Payroll Deductions and Safe Harbor Policy

We make every effort to ensure Hotel Employees are paid correctly.

Occasionally, however, mistakes may occur. To ensure that you are paid properly
for all time worked and that no improper deductions are made, you must record
correctly all time worked and review paychecks promptly to identify and to report
any errors.

Paycheck stubs or statements show the amount of earnings for the pay
period, accumulated earnings for the year, deductions made and other important
information. For income tax purposes, we will provide you and the Internal
Revenue Service with a "W2 Withholding Statement" showing yearly earnings and
taxes withheld. This statement will be issued to you in the month of January.

If you believe there is a mistake or if you have any questions, the reporting
procedure outlined below should be utilized.

6.7.1 Mandatory Deductions

Your net wages reflect deductions that meet government requirements

and/or deductions that you have authorized, consistent with applicable law.

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 Your pay may be reduced for state, federal and local taxes and social
security withholding. Such deductions are also made from overtime and other
additional payments. Under provisions of the Federal Insurance Contributions
Act (FICA), you and Sonesta are required to contribute on an equal basis. Your
share of this contribution is handled by payroll deductions.

6.7.2 Voluntary Deductions

Your paycheck may have certain additional deductions such as

contributions to health, dental, vision and/or long-term disability insurance,
optional group term life insurance, voluntary contributions to a savings plan,
pension plan or flexible spending plan.

6.7.3 Exempt Employees - Additional Information Regarding

Payroll Deductions

For exempt Hotel Employees, your salary includes compensation for all
hours you work. Your salary will be established at the time of hire or upon
classification as an exempt employee. While your salary may be subject to review
and modification from time to time, it will be a predetermined amount that will
not be subject to deductions for variations in the quantity or quality of the work
performed, other than the deductions listed below.

As permitted by applicable law, exempt Hotel Employee salaries may be

reduced for the following reasons:

• Full day absences for personal reasons.

• Full day absences for sickness or disability.

• Full day disciplinary suspensions for infractions of Sonesta’s written

policies and procedures.

• Family and Medical Leave absences (either full or partial day

absences).

• To offset amounts received as payment for jury and witness fees or

military pay.

• The first or last week of employment in the event the employee

works less than a full week.

• Any full work week in which an employee does not perform any work.

In any work week in which an exempt Hotel Employee performed any work,
his or her salary will not be reduced for any of the following reasons:

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 • Partial day absences for personal reasons, sickness or disability.

• Absence on a day because we have decided to close a facility on a

scheduled work day.

• Absences for jury duty, attendance as a witness, or military leave.

• Any other deductions prohibited by state or federal law.

Please note that it is not an improper deduction to reduce an employee’s

accrued vacation, sick days or other forms of paid time off for full or partial day
absences for personal reasons, sickness or disability.

6.7.4 To Report Concerns or Obtain More Information

If you believe that you have been subject to any improper deductions or
that your pay does not accurately reflect hours worked, you should immediately
report the matter to your Supervisor, Payroll or our Human Resources
Department. You may also call our anonymous Employee Hotline at 855-251-
0649 (DNIS: 617-796-8301).

Every report of improper deductions will be fully investigated and

corrective action will be taken where appropriate. We will not allow any form of
retaliation against individuals who report alleged violations or who cooperate in
our investigation of such reports. Retaliation is unacceptable, and any form of
retaliation in violation of this policy will result in disciplinary action, up to and
including termination of employment. All errors will be corrected in compliance
with applicable law.

6.8 Garnishments and Attachments

As required by applicable law, we may attach part of a Hotel Employee’s

wages for repayment of debt owed to others.

D. BENEFITS

7.0 Benefits

Sonesta offers Hotel Employees, depending on their classification, a

comprehensive benefits program, including health and dental insurance, vision,
life insurance, short and long term disability, business, travel and accident
insurance, retirement savings plan, and tuition reimbursement. Information
regarding these benefits is available from our Human Resources Department. We
and our plan administrators reserve the maximum discretion permitted by law to
interpret, administer, change, modify or delete any rules, guidelines, policies,
and/or benefits offered at any time. The eligibility standards and other details
regarding all benefits are contained in the actual plan documents themselves to

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the extent such documents exist. You should consult those documents for
further information regarding Sonesta’s benefit plans. Those documents are
available upon request from our Human Resources Department.

8.0 Worker’s Compensation

Hotel Employees are covered by worker’s compensation benefits if they are

injured at work, consistent with applicable law. Any Hotel Employee injured at
work should report the injury to his/her Supervisor or department head
immediately. Our Human Resources Department should also be informed of any
injury as soon as possible. A failure to report an injury promptly may result in a
delay or denial of benefits, in accordance with applicable law.

9.0 Paid Vacation, Holidays and Paid Sick Time

9.1 Vacation

Non-exempt Hotel Employees who work at least 130 hours per month will
accrue 1.25 days of paid vacation leave per month, or up to 15 days of vacation
leave per year. Vacation is calculated on the basis of a non-exempt Hotel
Employee’s anniversary year, which is the 12 month period that begins on the
first day of employment. Vacation benefits for non-exempt Hotel Employees
begin to accrue after the employee has been employed for six months,
retroactively to the first month of employment. Vacation days for non-exempt
Hotel Employees generally are not available for use until time is accrued.
Moreover, non-exempt Hotel Employees may not use any accrued vacation during
the first year of employment.

Full-time exempt Hotel Employees will receive 15 paid vacation days per
year in a lump sum on January 1. Exempt Hotel Employees must use vacation in
the year in which it is granted or the time will be lost. Exempt Hotel Employees
will not be paid for any unused vacation time remaining at the end of the calendar
year.

Vacations must be arranged around providing adequate staffing and you

must obtain advance approval from your Supervisor. Not all vacations can be
granted as requested. In the event of scheduling conflicts, vacations will be
approved on a seniority basis or as consistent with business needs, in Sonesta’s
sole discretion.

Upon termination of employment for any reason, Hotel Employees will be

paid for their accrued but unused vacation time at their regular rate of pay.

The use of vacation days runs concurrently with leave taken pursuant to
our Family and Medical Leave or other applicable policies, unless otherwise
required by applicable law.

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 9.1.1 Vacation Benefits for Part-Time Hotel Employees

Subject to any exceptions required by applicable law, part-time Hotel

Employees who regularly work 21 or more hours per week but less than 130
hours per month are eligible to earn pro-rated paid vacation time based upon
years of service subject to the same policies on use applicable to full-time Hotel
Employees, as set forth in Section 9.1 of this Employee Handbook.

9.2 Holidays

Sonesta designates certain days as paid holidays when observed on a week

day (Monday through Friday). Part-time Hotel Employees who regularly work a
minimum of 21 or more hours per week will qualify for holiday pay on a prorated
basis. We will distribute a list of paid holidays each year.

To be eligible for holiday pay, a nonexempt Hotel Employee must:

• work your regularly scheduled shifts during the period before and
after a holiday; or

• work the day of the holiday; or

• have scheduled vacation during the week of the holiday.

If you are eligible for holiday pay, you will receive eight (8) hours of pay at
your regular rate, unless otherwise provided by applicable law, in addition to your
regular pay for the hours worked on the holiday.

Exempt Hotel Employees who are required to work on a holiday are

permitted to take a different day off, within thirty (30) days of the holiday and
with their Supervisor’s prior approval.

9.3 Paid Sick Time

Sonesta offers paid sick time for a Hotel Employee’s illness which is
accrued as set forth below. Hotel employees who have accrued more than 5 sick
days can use any excess up to a maximum of 5 days of accrued paid sick time
per calendar year for the purpose of caring for a sick family member. Accrued,
paid sick time is not payable on termination of employment. In addition, no
exempt Hotel Employee may use accrued paid sick time after giving notice of
resignation from Sonesta.

For purposes of paid sick time specified above, and the special leave
mentioned in Section 14.8 of this Handbook, family member is limited to a child,
spouse, parent; or any minors, persons at least 60 years old, or persons with
disabilities under the legal custody or guardianship of the employee.

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 Hotel Employees who work at least 130 hours per month will accrue paid
sick time at the rate of 1 day per month (12 days per calendar year), beginning
with the date of hire. Unused paid sick time accrual for non-exempt employees
is transferred from one year to the next up to a maximum of 15 days, which
means that if a non-exempt employee has accrued more than 15 days of paid
sick time, only 15 days of accrued sick leave will be transferred from one year to
the next. Unused paid sick time accrual for exempt employees is capped at 15
days, which means that if the exempt employee has accrued 15 days of paid sick
time, he or she will not accrue additional paid sick time unless and until accrued
paid sick time is used.

When a state of emergency is decreed by the Governor or Health Secretary

of Puerto Rico, non-exempt employees suffering from or suspected of suffering
from the illness or epidemic provoking the state of emergency will be entitled to
use all accrued leave once paid sick time is exhausted. Thereafter, any such
employee remaining ill after exhausting all accrued leave will be entitled to paid
emergency leave for up to 5 days.

Hotel employees who suffer a catastrophic illness, as defined by applicable

law, and who have completed 12 months of employment with Sonesta in Puerto
Rico, will be entitled to an additional 6 days of paid sick leave once they have
exhausted any other accrued sick leave. This leave will be available during the
calendar year of eligibility and cannot be transferred to subsequent years.

Paid sick time may be used in 15-minute increments.

The use of paid sick time runs concurrently with leave taken pursuant to
our Family and Medical Leave or other applicable policies, unless otherwise
required by applicable law.

10.0 Short and Long Term Disability

Hotel employees are covered by a short term disability policy (SINOT or

Chauffeur’s Social Security) as required by local law. In addition, full-time Hotel
Employees and part-time Hotel Employees who work 21 or more hours per week
may be eligible for some continuation of pay pursuant to Sonesta’s insured short
term disability (STD) policy in the case of extended absence due to illness or
injury. An eligible employee may receive salary continuation, at a rate of 60% of
pay, to a weekly maximum of $1,500 gross, for up to 11 weeks.

For eligible Hotel Employees who continue to be disabled beyond the STD
benefit period, long term disability (LTD) benefits may also be available, pursuant
to our LTD plan. This is also a fully Sonesta paid insurance policy, and, when
approved, provides 60% of pay to a monthly maximum of $7,500, consistent with
our LTD Plan documents. Instead of accepting our paid LTD coverage, Hotel

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Employees may pay their LTD premiums via post-tax payroll deduction. If you
choose this option, any LTD benefits paid will not be subject to income taxes.

Benefits under our STD and LTD policies are solely monetary benefits and
receipt of benefits does not confer substantive leave rights. Further, receipt of
STD or LTD benefits under our policy runs concurrently with receipt of any
statutorily-mandated benefits, consistent with applicable law. Receipt of STD or
LTD benefits pursuant to our policy or pursuant to statute does not extend any
leave available pursuant to any applicable Sonesta policy (e.g., family and medical
leave, newborn/adoption leave).

You should contact our Human Resources Department to obtain forms to

apply for STD or LTD benefits. You will be required to provide medical
documentation, consistent with applicable law. A failure to provide requested
information in a timely or complete manner may result in the delay or denial of
benefits. Eligibility for STD and LTD benefits, amount of benefits and any issues
concerning benefits are governed by the applicable plan documents, which are
available from our Human Resources Department and, in the event of
inconsistency, the applicable plan documents will govern.

11.0 Employee Referral Bonus

Eligible Hotel Employees will receive a $100 (gross) bonus for referring a
candidate whom we hire for a part-time hotel position or a $500 (gross) bonus
for referring a candidate whom we hire for a full-time hotel position. To receive
the bonus, the referring Hotel Employee and the referred employee both must be
employed for six (6) months following the start date of the new hire. The
referring Hotel Employee will receive the first half of the bonus after the three (3)
month anniversary of the referred employee’s start date, provided that both
employees are employed as of that date. The second half will be paid after the
referred employee has been employed with Sonesta for six (6) months, provided
that both employees are employed as of that date. There is no bonus for referring
a contractor, consultant, or on-call employee. A Hotel Employee is not eligible to
receive the bonus if the referred employee directly reports to the referring
employee or is in his/her “line of reporting.” Senior Executives are also not
eligible for this bonus.

12.0 Tuition Assistance

Tuition assistance is available to Hotel Employees who: (a) have at least 6

months of continuous employment prior to enrolling in the course and (b) are in
good standing for the duration of the course.

Eligible full-time Hotel Employees may receive up to $3,000 in tuition

assistance and book costs during a calendar year, payable after the course is
completed and proof of the employee’s final grade is provided to Sonesta (see

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below for grade requirements). Regular part-time Hotel Employees scheduled to
work 21 hours or more per week may also be eligible to receive 50% assistance
on a pro-rated basis. All approved tuition assistance requests will be reimbursed
in a two-step process:

• We will reimburse you 50% of the total approved cost after the course
is completed and all required supporting documents (defined below)
are submitted to, and approved by, us.

• Six months after paying the first 50% is paid, we will reimburse you
the remaining 50% of the total approved tuition assistance, provided
you are still actively employed.

Tuition assistance requests must be approved in advance of course

enrollment by your Supervisor, the Department Head, and our Human Resources
Department.

We may require repayment of tuition assistance if you voluntarily terminate

your employment, or you are terminated for cause, within 6 months of receiving
your second payment.

Tuition assistance limits are on a calendar year basis and do not

accumulate from year to year. The applicable calendar year is the year in which
the first 50% of the approved tuition assistance payment is made.

To qualify for tuition assistance, you must select a course that meets all
the following criteria:

1. Is offered at an accredited school, college, university or at a city or

town adult education program.

2. Is scheduled during off-duty hours.

3. Is a graded course.

4. Meets for at least a total of twenty (20) classroom hours (either on-
site or on-line) in a semester as defined by the educational
institution.

In addition, the course must be directly job related, which means a course
that:

1. Maintains or improves skills relevant to the Hotel Employee's current

job.

2. Meets express requirements imposed by Sonesta under applicable

law as a condition of continuing employment.

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 3. Is beneficial to the Hotel Employee and/or the performance of the
employee's job responsibilities in the judgment of the employee’s
Supervisor and Head of Human Resources.

4. Meets minimum educational requirements for qualification in

present job.

5. Leads to qualification for career advancement within Sonesta.

Course(s) must be completed with a grade of B- or better, or if pass/fail,

with a pass grade, to be eligible for reimbursement.

Within forty-five (45) days after course completion, you are required to
submit the following to your Supervisor or our Human Resources Department:

1. Duplicate copy of request for tuition assistance.

2. Copy of transcript of grades or certificates of completion.

3. Proof of payment of tuition and receipts for text book(s) for which
reimbursement is being sought.

Payments will be made directly to you and will be excludable from your
gross income to the fullest extent allowed by applicable law.

13.0 Employee and Friends and Family Programs

Sonesta may offer discounts on rates for food, beverage, and room stays
at Sonesta hotels to Hotel Employees and their friends and family. Information
on Sonesta’s current Employee and Friends and Family Programs is available from
our Human Resources Department.

E. LEAVES OF ABSENCE

14.0 Leaves of Absence

A Hotel Employee seeking a leave of absence must submit a written

"Request for Leave" form to his/her Supervisor, or to our Human Resources
Department. Requests should be submitted at least 30 days in advance of the
proposed effective date of the leave, unless otherwise provided by a specific,
applicable policy below or by applicable law. In case of emergency, the Request
for Leave form must be submitted as soon as practicable. Failure to provide the
requested notice may result in denial of the leave, unless otherwise provided by
applicable law.

14.1 Military Leave

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 Sonesta provides military leaves of absence to Hotel Employees who serve
in the uniformed services as required by the Uniformed Services Employment and
Reemployment Rights Act (USERRA) and applicable state laws. If you receive
military orders requiring you to report to active duty or if you must fulfill any
military training requirement, notify your Supervisor or our Human Resources
Department as soon as possible to make arrangements for a leave of absence.
Subject to applicable law, upon return from military leave, you will be restored to
the same salary, seniority, and benefits you would have received if you had
remained actively employed by Sonesta during your military service.

Please contact our Human Resources Department for additional

information, including information concerning eligibility, notice requirements,
benefits and reinstatement rights.

14.2 Jury Duty and Witness in Criminal Cases

If you are called for jury duty or as a witness for the prosecution in a
criminal case, you must submit the jury duty notice or subpoena with a Request
for Leave form to your Supervisor for approval and submit the approved form to
our Human Resources Department. You must also notify your Supervisor and our
Human Resources Department as soon as dates of your jury or witness duty are
known. If your jury duty falls at a time when your department is particularly busy,
you should request that the court allow the jury duty to be rescheduled to a more
convenient time.

While on leave for jury duty, a Hotel Employee is entitled to receive his/her
regular pay, less the amount received from jury duty, for up to 15 days of service.
In the case of witness duty as specified above, a Hotel Employee is entitled to
receive his/her regular pay, less the amount received for witness fees. You must
submit the record of jury or witness fees payment or a copy of the check to our
Human Resources Department before receiving your regular pay.

You are expected to report to work during your regular work hours that
your presence is not required as a juror or witness, unless otherwise prohibited
by applicable law. Jury or witness duty as specified above will not affect your
attendance record.

14.3 Bereavement Leave

Full-time Hotel Employees who have worked at Sonesta for more than 90
days are entitled to up to 3 days paid bereavement leave for the loss of a family
member (including spouse, domestic partner, child, parent, sibling, parent-in-
law, brother- or sister-in-law, grandparent, grandparent-in-law, any family
member living in the same household, aunt, uncle, cousin or any other relation
required by applicable law). Hotel Employees working 21 or more hours per week
but fewer than 30 hours per week should confirm with our Human Resources

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Department the amount of bereavement leave to which they are entitled.
Bereavement leave will not apply if leave is sought for a period you are not
normally scheduled to work or if you are on an approved leave of absence.
Unused bereavement leave pay will not be paid at the time of termination of
employment and does not carry over from calendar year to year.

14.4 Family and Medical Leave

Sonesta grants family and medical leave in accordance with the

requirements of applicable state and federal law. Although the federal and state
laws sometimes have different names, we refer to these types of leaves
collectively as “FMLA Leave.” In any case, Hotel Employees will be eligible for the
most generous benefits available under applicable law.

14.4.1 Employee Eligibility

To be eligible for FMLA Leave benefits, you must: (1) have worked for
Sonesta for a total of at least 12 months; (2) have worked at least 1,250 hours
over the previous 12 months as of the start of the leave; and (3) work at a location
where at least 50 employees are employed by Sonesta within 75 miles, as of the
date the leave is requested.

14.4.2 Reasons for Leave

State and federal laws allow FMLA Leave for various reasons. Because your
rights and obligations may vary depending upon the reason for the FMLA Leave,
it is important to identify the purpose or reason for the leave. FMLA Leave may
be used for one of the following reasons, in addition to any reason covered by an
applicable state family/medical leave law:

• the birth, adoption, or foster care of a child within 12 months

following birth or placement of the child (“Bonding Leave”);

• to care for an immediate family member (spouse, child, or parent)

with a serious health condition (“Family Care Leave”);

• inability to work because of a serious health condition (“Serious

Health Condition Leave”);

• a “qualifying exigency,” as defined under the FMLA, arising from a

spouse’s, child’s, or parent’s “covered active duty” (as defined below) as a
member of the military reserves, National Guard or Armed Forces (“Military
Emergency Leave”); or

• to care for a spouse, child, parent or next of kin (nearest blood

relative) who is a “Covered Servicemember,” as defined below (“Military Caregiver
Leave”).

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 Definitions:

“Child,” for purposes of Bonding Leave and Family Care Leave, means a
biological, adopted, or foster child, a stepchild, a legal ward, or a child of a
person standing in loco parentis, who is either under age 18, or age 18 or older
and incapable of self-care because of a mental or physical disability at the time
that Family and Medical Leave is to commence.

“Child,” for purposes of Military Emergency Leave and Military Caregiver

Leave, means a biological, adopted, or foster child, stepchild, legal ward, or a
child for whom the person stood in loco parentis, and who is of any age.

“Parent,” for purposes of this policy, means a biological, adoptive, step or

foster father or mother, or any other individual who stood in loco parentis to the
person. This term does not include parents “in law.” For Military Emergency
Leave taken to provide care to a parent of a military member, the parent must be
incapable of self-care, as defined by the FMLA.

“Covered Active Duty” means (1) in the case of a member of a regular

component of the Armed Forces, duty during the deployment of the member with
the Armed Forces to a foreign country; and (2) in the case of a member of a
reserve component of the Armed Forces, duty during the deployment of the
member with the Armed Forces to a foreign country under a call or order to active
duty (or notification of an impending call or order to active duty) in support of a
contingency operation as defined by applicable law.

“Covered Servicemember” means (1) a member of the Armed Forces,

including a member of a reserve component of the Armed Forces, who is
undergoing medical treatment, recuperation, or therapy, is otherwise in
outpatient status, or is otherwise on the temporary disability retired list, for a
serious injury or illness incurred or aggravated in the line of duty while on active
duty that may render the individual medically unfit to perform his or her military
duties, or (2) a person who, during the five (5) years prior to the treatment
necessitating the leave, served in the active military, Naval, or Air Service, and
who was terminated or released therefrom under conditions other than
dishonorable (a “veteran” as defined by the Department of Veteran Affairs), and
who has a qualifying injury or illness incurred or aggravated in the line of duty
while on active duty that manifested itself before or after the member became a
veteran. For purposes of determining the five-year period for covered veteran
status, the period between October 28, 2009 and March 8, 2013 is excluded.

“Spouse” means the other person with whom an individual entered into
marriage as defined or recognized under State law for purposes of marriage in
the State in which the marriage was entered into, or, in the case of a marriage
entered into outside of any State, if the marriage is valid in the place where
entered into and could have been entered into in at least one State, including

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common law marriage or same sex marriage in places where these marriages are
recognized.

14.4.3 Length of Leave

The maximum amount of FMLA Leave is twelve (12) workweeks in any 12

month period when the leave is taken for: (1) Bonding Leave; (2) Family Care
Leave; (3) Serious Health Condition Leave; and/or (4) Military Emergency Leave.
However, if both spouses work for Sonesta and are eligible for leave under this
policy, the spouses will be limited to a total of 12 workweeks off in combination
if the leave is for Bonding Leave or to care for a parent using Family Care Leave.
A 12 month period begins on the date of your first use of FMLA Leave. Successive
12 month periods commence on the date of your first use of such leave after the
preceding 12 month period has ended.

The maximum amount of FMLA Leave for a Hotel Employee wishing to take
Military Caregiver Leave will be a combined leave total of twenty-six (26)
workweeks in a single 12 month period. A "single 12 month period" begins on
the date of your first use of such leave and ends 12 months after that date.

If you and your spouse work for Sonesta and are both eligible for leave
under this policy, you and your spouse will be limited to a total of 26 workweeks
off in combination if the leave is for Military Caregiver Leave only or is for a
combination of Military Caregiver Leave, Military Emergency Leave, Bonding Leave
and/or Family Care Leave taken to care for a parent.

Under some circumstances, you may take FMLA Leave intermittently—

which means taking leave in blocks of time, or by reducing your normal weekly
or daily work schedule. Leave taken intermittently may be taken in increments of
no less than one hour. If you take leave intermittently or on a reduced work
schedule basis for planned medical treatment, you must make a reasonable effort
to schedule the leave so as not to unduly disrupt our operations. Please contact
our Human Resources Department prior to scheduling planned medical
treatment. If Family and Medical Leave is taken intermittently or on a reduced
schedule basis due to foreseeable planned medical treatment, we may require
you to transfer temporarily to an available alternative position with an equivalent
pay rate and benefits, including a part-time position, to better accommodate
recurring periods of leave.

If you have been approved for intermittent leave and seek leave time that
is unforeseeable, you must specifically reference either the qualifying reason for
leave or the need for FMLA leave at the time you call to report your request for
time off.

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 To the extent required by law, some extensions of leave beyond your FMLA
entitlement may be granted when the leave is necessitated by a work related
injury/illness or a “disability” as defined under the Americans with Disabilities Act
and/or applicable state or local law. Certain restrictions on these benefits may
apply.

14.4.4 Notice and Certification

14.4.4.1 Bonding, Family Care, Serious Health Condition,

and Military Caregiver Leave Requirements

You are required to provide:

1. when the need for the leave is foreseeable, 30 days advance notice
or such notice as is reasonable if the leave must begin in less than 30 days
(normally this would be the same day the employee becomes aware of the need
for leave or the next business day);

2. when the need for leave is not foreseeable, notice within the time
prescribed by Sonesta’s normal absence reporting policy, unless unusual
circumstances prevent compliance, in which case notice is required as soon as is
otherwise possible and practical;

3. when the leave relates to medical issues, a completed Certification

of Healthcare Provider form within 15 calendar days (for Military Caregiver Leave,
an invitational travel order or invitational travel authorization may be submitted
in lieu of a Certification of Health-Care Provider form);

4. periodic recertification (upon request); and

5. periodic reports during the leave.

Certification forms are available from our Human Resources Department.

At Sonesta’s expense, we may also require a second or third medical opinion
regarding your or your family member’s health condition. In some cases, we may
require a second or third opinion regarding the injury or illness of a “Covered
Servicemember.” You are expected to cooperate with us in obtaining additional
medical opinions that we may require.

When leave is for planned medical treatment, please try to schedule

treatment so as not to unduly disrupt our operation. Please contact our Human
Resources Department prior to scheduling planned medical treatment.

14.4.4.2 Recertification After Grant of Leave

In addition to the requirements listed above, Sonesta may require medical

recertification in connection with an absence that you report as qualifying for

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Family and Medical Leave if permissible under applicable law. For example, we
may request recertification if (1) you request an extension of leave; (2) the
circumstances of your condition as described by the previous certification change
significantly (e.g., your absences deviate from the duration or frequency set forth
in the previous certification; your condition becomes more severe than indicated
in the original certification; you encounter complications); or (3) we receive
information that casts doubt upon your stated reason for the absence. In
addition, we may request recertification in connection with an absence after six
months have passed since your original certification, regardless of the estimated
duration of the serious health condition necessitating the need for leave. Any
recertification we request will be at your expense.

14.4.4.3 Military Emergency Leave Requirements

You are required to provide:

• as much advance notice as is reasonable under the circumstances;

• a copy of the covered military member's active duty orders when the
employee requests leave and/or documentation (such as Rest and Recuperation
leave orders) issued by the military setting forth the dates of the military
member’s leave; and

• a completed Certification of Qualifying Exigency form within 15

calendar days, unless unusual circumstances exist to justify providing the form
at a later date.

Certification forms are available from our Human Resources Department.

14.4.4.4 Failure to Provide Certification and to Return

from Leave

Absent unusual circumstances, failure to comply with our notice and

certification requirements may result in a delay or denial of leave. If you fail to
return to work at your leave’s expiration and have not obtained an extension of
the leave, we may presume that you do not plan to return to work and have
voluntarily terminated your employment.

14.4.5 Compensation During Leave

Generally, FMLA Leave is unpaid. However, you may be eligible to receive

benefits through State sponsored or Sonesta sponsored wage replacement
benefit programs. You may also choose, in conjunction with leave, to use accrued
vacation and sick time, to the extent permitted by law and Sonesta policy. Any
available payments will be integrated so that you will receive no more than your
regular compensation during this period. The use of paid benefits will not extend
the length of a FMLA Leave.

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 14.4.6 Benefits During Leave

Pursuant to the terms of our applicable benefit plans and as required by

law, we will pay the employer portion of the total cost of your employee benefits
during an approved leave. You are still responsible for payment of your portion
of any costs. Hotel Employees taking Bonding Leave, Family Care Leave, Serious
Health Condition Leave, and Military Emergency Leave will generally be provided
with group health benefits for a 12 workweek period. Hotel Employees taking
Military Caregiver Leave may be eligible to receive group health benefits coverage
for up to a maximum of 26 workweeks. In some instances, we may recover
premiums paid to maintain health coverage if you fail to return to work following
a FMLA Leave.

If you are on a FMLA Leave but are not entitled to continued paid group
health insurance coverage, in some circumstances you may continue your
coverage through Sonesta in conjunction with federal and/or state COBRA
guidelines by making monthly payments to Sonesta for the amount of the
relevant premium.

No benefits will accrue during an FMLA Leave (e.g., vacation and sick leave)
unless required by applicable law where mandatory leave is being used
concurrently with FMLA Leave.

Please contact our Human Resources Department for more information

about your payment responsibilities or with any other questions.

14.4.7 Job Reinstatement

Under most circumstances, you will be reinstated to the same position held
at the time of the leave or to an equivalent position with equivalent pay, benefits,
and other employment terms and conditions. However, you have no greater right
to reinstatement than if you had been continuously employed rather than on
leave. For example, if you would have been laid off had you not gone on leave,
or if your position has been eliminated during the leave, then you will not be
entitled to reinstatement.

If you are returning from a Serious Health Condition Leave, you must
submit an acceptable release from a health care provider.

“Key employees,” as defined by law, may be subject to reinstatement

limitations in some circumstances. If you are a “key employee,” you will be
notified of the possible limitations on reinstatement at the time you request a
leave.

14.4.8 Fraudulent Use of FMLA Prohibited

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 A Hotel Employee who fraudulently obtains Family and Medical Leave is not
protected by FMLA’s job restoration or maintenance of health benefits provisions.
In addition, we will take all available appropriate disciplinary action against an
employee for fraud.

14.4.9 Additional Information Regarding FMLA

A Notice to Employees Of Rights Under FMLA (WHD Publication 1420) is

attached to this policy.

14.4.10 Questions and/or Complaints About FMLA Leave

Any questions regarding our FMLA policy should be directed to our Human
Resources Department.

The FMLA makes it unlawful for Sonesta to:

• Interfere with, restrain, or deny the exercise of any right provided

under FMLA; or

• Terminate or discriminate against any person for instituting or

participating in any proceeding under or related to the FMLA or complaining
about any unlawful practice under the FMLA.

If you believe your FMLA rights have been violated you should contact our
Human Resources Department immediately. You may also call our Employee
Hotline at 855-251-0649 (DNIS: 617-796-8301). We will investigate any FMLA
complaints and take prompt and appropriate action to address and/or remedy
any FMLA violation.

14.5 Medical Leave Policy for Non-FMLA Leave and Certain

Other Circumstances

If you believe you need a medical leave of absence and are not eligible for
FMLA or have exhausted FMLA, you should contact our Human Resources
Department. We will comply with applicable law in providing unpaid time off as
a reasonable accommodation. Determinations regarding the length of such a
leave, continuation of benefits while on leave and reinstatement following leave
will be made in accordance with applicable law.

Written documentation from your health care provider supporting the need
for leave may be required.

14.6 Work During Leave

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 Unless otherwise provided by applicable law, you should not engage in any
type of work that conflicts with the reason for your leave of absence.

14.7 Newborn/Adoption Leave

Maternity leave is granted to every expecting or adopting mother as

provided by law or regulation. The expecting mother will have 4 weeks of leave
prior to giving birth (which can be delayed until after giving birth if approved by
her doctor) and 4 additional weeks of leave after giving birth. A medical
certificate is required with an expected date of giving birth in order for the
maternity leave to be paid.

Mothers who adopt a child will be entitled to 8 weeks of paid maternity

leave beginning on the day the child arrives at the employee’s home if the child
is 5 years old or younger, and 8 weeks if the child is 6 years old or older. The
employee will be required to present evidence of the adoption proceedings, the
age of the child, the expected effective date of adoption and return to work, at
least 30 days in advance of the beginning of said leave, in order to receive the
benefit provided by law. In case of abortion, the employee must present a
medical certificate from her attending physician, indicating that the abortion
produced the same physiological effects as childbirth, and the recommended
length of rest. Maternity leave runs concurrently with Family and Medical Leave.

Hotel Employees not eligible for mandatory maternity leave as specified

above, and who work 21 or more hours per week, are eligible to take two (2)
weeks of leave, with full pay, to care for a newborn child and/or a newly adopted
child. This leave must be taken within the first twelve (12) weeks of the child’s
birth or adoption and may be taken intermittently, consistent with applicable law.
This leave will run concurrently with other applicable leave Sonesta provides and
with the receipt of any applicable monetary benefits (e.g., Family and Medical
Leave; Medical Leave Policy for Non-FMLA Leave and Certain Other
Circumstances; Short-Term Disability; state-mandated leave and/or disability
benefits). In no event will a Hotel Employee taking Newborn/Adoption Leave
receive more than 100% of his or her pay during this time. If you want to take
this leave, you should contact our Human Resources Department for further
information.

14.8 Special Leave for Domestic Violence

A Hotel Employee who is a victim, or has a family member (as defined in

Section 9.3 of this Handbook) who is a victim (not caused by the employee) of
domestic violence, gender violence, child abuse, sexual harassment, sexual
aggression, lascivious acts or felony stalking, will be entitled to a special leave
without pay of up to 15 days per natural year to deal with such situations. This
leave might be taken intermittently—which means taking leave in blocks of time,
or by reducing your normal weekly or daily work schedule. Leave taken

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intermittently may be taken in increments of no less than 1 hour. The employee
should request this leave at least 2 working days prior to its effective date, except
in situations outside of the employee’s control, and provide reasonable evidence
of the need for the leave not later than 2 days after the last use of the leave. Any
employee requiring a reasonable accommodation in connection with any of these
situations should contact our Human Resources Department for additional
information.

14.9 Other Leaves

Sonesta will comply with any applicable state or local leave laws that
provide greater benefits than those set forth in this Employee Handbook. Please
contact our Human Resources Department for additional information.

F. WORKPLACE RULES AND CONDUCT

15.0 Rules of Conduct and Discipline

15.1 Employee Duties

Hotel Employees are expected to perform the following general duties:

1. Perform the duties and responsibilities of your position in

accordance with Sonesta’s rules, diligently and in good faith.

2. Comply with all of Sonesta’s occupational safety and health

directives.

3. Abstain from incurring in improper, disorderly, unlawful or immoral

conduct that could reasonably impact Sonesta’s best interests.

4. Obey a supervisor’s orders and instructions.

5. Refrain from competition with Sonesta’s activities.

6. Contribute to improve Sonesta’s productivity and competitiveness.

7. Any other duties arising from the employment contract, job

description and rules, including this Employee Handbook, as long as
they are not contrary to law, morals or public order.

15.2 General

The following is a non-exhaustive list of examples of infractions which may

result in disciplinary action, up to and including termination of employment.

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 1. Deliberate or careless damage to Sonesta property or equipment.

2. Careless performance of duties, including failure to maintain proper

standards of workmanship or productivity.

3. Possessing, ingesting, or being under the influence of alcohol or

drugs on Sonesta property and/or otherwise violating Sonesta’s
substance abuse prevention policies.

4. Falsifying employment applications, personnel security

questionnaires, work records, or other Sonesta records.

5. Failure to observe safety rules and regulations.

6. Violation of Sonesta’s solicitation policy.

7. Failure to return to work upon expiration of an authorized leave or

vacation without approval, unless the reason for not returning is
legally protected.

8. Misrepresentation of the reasons for a leave of absence or for other

time off from work.

9. Excessive personal use of Sonesta telephone and/or other electronic

systems during working time.

10. Theft.

11. Falsification or altering of time records.

12. Failure to observe department work schedules, including lunch and

break periods.

13. Leaving department or job during working hours without

permission.

14. Engaging in any illegal activity.

15. Possession of firearms or any dangerous weapon at work on Sonesta

premises.

16. Gambling or playing the lottery or other game of chance at work or

on Sonesta premises at any time.

17. Violation of any employee duty or rule enumerated in this Employee

Handbook.

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 18. Violation of our equal employment opportunity, anti-discrimination
or anti-harassment policies.

16.0 Discipline

Depending on the circumstances, Sonesta may impose one or more of the

following for infractions: verbal warning, written warning, final written warning
and/or suspension (with or without pay), demotion, or termination of
employment. However, we will address each case individually, and nothing in
these examples or this Employee Handbook should be construed as a promise of
specific treatment in a given situation or as a limitation on our recourse.

17.0 Performance Appraisal and Wage/Salary Review

Performance appraisals will generally be completed on an annual basis.

From time to time, and generally annually, we may also review salaries.

Performance appraisals will be retained in employee personnel files.

A review or performance discussions may be initiated by Sonesta at any

time.

18.0 Personnel Files

We maintain personnel records for each Hotel Employee. You may review
your personnel file after making a written request to our Human Resources
Department.

It is your responsibility to promptly notify our Human Resources

Department of any of the following:

1. Change of address or telephone number;

2. Legal change of name;

3. Change of status regarding legal right to work;

4. Beneficiary change or changes resulting in benefit changes or

enrollment (if required for tax or benefit purposes);

5. Change of emergency contact; and

6. Change in withholding.

19.0 Relationships In The Workplace

While a family member of a Hotel Employee may be considered for

employment by Sonesta, a family member of a Supervisor may not be permitted

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to work in the same department as the Supervisor or in a role in which one family
member has decision-making authority over the other. For purposes of this
policy, family member includes spouse, domestic partner, child, parent, sibling,
parent-in-law, brother- or sister-in-law, grandparent, grandparent-in-law, any
family member living in the same household, aunt, uncle, cousin, or any other
relation required by applicable law.

Sonesta strongly discourages romantic or sexual relationships and any

conduct that may lead to the formation of such a romantic or sexual relationship
(i.e., dating) between a Supervisor and an employee who the Supervisor directly
manages or over whom the Supervisor has employment decision making
authority.

If a romantic or sexual relationship between Supervisor and an employee

who the Supervisor either directly manages or over whom the Supervisor has
employment decision making authority develops, the employee and the
Supervisor should disclose the relationship to our Human Resources Department
as soon as possible. If we conclude that such a relationship could create an actual
or potential conflict of interest, we may require that one of the employees
transfer or leave employment.

20.0 Anti-Violence Policy

You are expected to exercise reasonable judgment in identifying

potentially dangerous situations and inform Sonesta management accordingly.
Sonesta will not tolerate threats, threatening language, or any other acts of
aggression or violence made toward or by any employee. For purposes of this
policy, a threat includes any verbal or physical harassment or abuse, attempts to
intimidate or to instill fear in others, menacing gestures, bringing weapons
(including, but not limited to, firearms, explosives or knives) whether concealed
or not, to the workplace, stalking, or any other hostile, aggressive, injurious
and/or destructive actions undertaken for the purpose of domination or
intimidation.

You should immediately report all potentially dangerous situations,

including threats by co-workers, to our Human Resources Department or to any
member of senior management. You may also report threats anonymously by
calling the Employee Hotline at 855-251-0649 (DNIS: 617-796-8301). All threats
will be promptly investigated. If an investigation confirms that a threat of a
violent act or violence itself has occurred, we will take appropriate action.
Anyone, regardless of position or title, whom we determine has engaged in
conduct that violates this policy, including retaliation, may be subject to
disciplinary action, up to and including termination of employment. If an
employee is threatened by an outside party, you should follow the steps detailed
in this section. It is important for us to be aware of any potential danger in the
workplace.

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 Sonesta policy prohibits any discrimination or retaliation against an
employee for reporting any threat, pursuing any claim, or cooperating in any way
in the investigation of any claims, unless it is determined that the employee made
the report in bad faith or with knowledge that it was false.

21.0 Professional Appearance/Dress Code

Below are general guidelines for appearance and dress. Different hotels
may have other dress code policies from time to time, which vary from the
guidelines below, based on location, season, or operational needs. In such cases,
the specific hotel policy will apply.

A Uniformed Hotel Employee must wear the hotel issued uniform at all
times while on duty. The uniform should be clean and pressed at all times.
Uniforms must be free of rips, stains, and odors. T-shirts worn under uniforms
must not be visible. Extensive damage or repeated loss of uniforms may result
in disciplinary action and employees may be charged the cost of repair or
replacement, unless otherwise prohibited by applicable law.

Hair must be neat, clean and nicely trimmed. No extreme hairstyles are
permitted. Jewelry should not be functionally restrictive, dangerous to job
performance, or excessive. No visible body piercing, facial jewelry, such as
eyebrow rings, nose rings, lip rings, or tongue studs are permitted.

Fingernails should be clean and neat. You should practice good hygiene.
Perfume, cologne and aftershave lotion should be used moderately. You should
check with your Supervisor regarding the permissible footwear for your job and
adhere to all directives regarding appropriate footwear. Generally, shoes must
provide for safe, secure footing and offer protection against hazards. Correct
color and style must be worn in accordance with department requirements. You
should not wear flip flops or any footwear for the beach or sandals that make a
slapping noise when walking.

Managers must wear matching pants and jacket. Jackets must be worn at
all times in guest areas.

Supervisors and our Human Resources Department are responsible for

monitoring and enforcing this policy. If you violate this policy, you may be asked
to return home and change attire immediately. Repeated violations may result in
disciplinary action, up to and including termination of employment, consistent
with applicable law.

If you believe you need an exception to this policy due to a disability or a

sincerely held religious belief, please contact our Human Resources Department
and request an accommodation. We will comply with all reasonable
accommodation requirements under applicable law.

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 22.0 Alcohol

Sonesta prohibits the abuse, misuse, or possession of alcohol while

working, present on Sonesta’s premises (defined as all buildings, facilities, and
property – including parking areas – owned or leased by Sonesta, and all places
where we conduct business, including hotels), or representing Sonesta at any
time and in any way. We also prohibit the use of alcohol, or the possession of
opened containers of alcohol, by Hotel Employees operating any vehicle, while
on Sonesta business.

Notwithstanding the foregoing, we may occasionally authorize alcoholic

beverages at approved Sonesta functions at designated sites. In those situations,
you may consume a moderate amount of alcohol, provided that your conduct and
demeanor remain professional and appropriate at all times and that you do not
thereafter drive or otherwise engage in any activity which could be hazardous if
the alcohol consumed impaired or affected your ability to perform those
activities.

23.0 Drugs

Sonesta strictly prohibits the possession, use, sale, attempted sale,

purchase, attempted purchase, distribution, transfer, dispensation, cultivation,
and/or manufacture of illicit drugs or other intoxicants at any time, and in any
amount or any manner. “Illicit drugs” includes all drugs, narcotics, and
intoxicants for which possession or misuse is illegal under federal law, and
includes prescription medications for which the individual does not have a valid
prescription. The deliberate use of prescription medications and/or over the
counter drugs in a manner inconsistent with dosing directions, and in a manner
which may result in impairment, is considered illicit drug use. In addition, the
use of chemical intoxicants for other than a legitimate and therapeutic purpose
is considered illicit drug use. The possession of illicit drugs and illicit drug
paraphernalia is also strictly forbidden.

23.1 Use of Prescription Medications

If you use prescription and/or over the counter medications that may
impair your ability to perform your job responsibilities safely, you must notify
your Supervisor and our Human Resources Department so that steps can be taken
to minimize the safety risks posed by such use. You may be required to obtain
a doctor’s certification that you can safely perform your job responsibilities.
Hotel Employees are not required to reveal the nature of the underlying medical
condition or the name of the medication.

24.0 Visitors in the Workplace

Hotel Employees are expected to be courteous and respectful to visitors at

all times.

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 25.0 Solicitations and Distribution of Literature

Sonesta requires strict compliance with the following rules that govern
solicitation, distribution of written material, and access to Sonesta property.

• You may not engage in solicitation during work or during the

working time of any other employees to whom such activity is
directed;

• You may not distribute or circulate any printed material in work areas
at any time, or during your working time or during the working time
of any other employees to whom such activity is directed;

• Non-employees are not permitted to solicit or to distribute written

material for any purpose on Sonesta premises; and

• Off-duty employees are not permitted in work areas.

As used in this policy, "working time" includes all time for which you are
paid and/or scheduled to be performing services; it does not include break
periods, meal periods, or periods in which you are not performing or scheduled
to be performing services or work for Sonesta.

26.0 Office Appearance

You should keep your work area in a neat and orderly manner. At the end
of the work day, you should clean up your work area and the surrounding office
space. If you need additional filing space, please consult with your Supervisor.

You should place personal belongings in areas which have been designated
for such articles. You are expected to exercise reasonable care with respect to
your personal property. Purses, wallets, or other personal valuables should not
be left in plain view. We are not responsible for the loss or theft of any personal
property brought into the workplace.

27.0 Company Property/Searches

27.1 Company Property

You are expected to exercise care in the use of Sonesta property.

Negligence in the care and use of Sonesta property or theft of Sonesta property
may be cause for disciplinary action up to and including termination of
employment. Sonesta property issued to you, including, without limitation,
software, manuals, proprietary information and corporate credit cards must be
returned when employment is terminated. If you do not return Sonesta property
upon termination of employment, you must reimburse us for the value of the

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property not returned. You will be liable for any personal charges on a corporate
credit card.

No Hotel Employee may remove Sonesta property from the premises

without proper authorization. Sonesta property includes, but is not limited to:

1. Materials, equipment, tools and other business supplies.

2. Confidential literature including technical, sales, and quality- control

documents.

3. Computer disks, and other storage media.

4. Information identified as proprietary or designated as a trade secret.

5. Electronic equipment.

Hotel Employees who remove or attempt to remove Sonesta property

without proper authorization may be subject to disciplinary action, up to and
including termination of employment.

27.2 Company Searches

We may request that any Hotel Employee open for inspection any package
or other container brought on or taken from our premises for any business
reason.

In addition, Sonesta may conduct searches of Hotel Employee vehicles

parked on our premises at any time we have reason to believe that Sonesta
property has been taken.

If a Hotel Employee is found in possession of Sonesta property without

authorization, he/she will be subject to disciplinary action, up to and including
termination of employment.

Any contraband items and/or illegal substances found during a search

pursuant to this policy may be turned over to law enforcement authorities, when
appropriate. Hotel Employees found in possession of such items will be subject
to disciplinary action, up to and including termination of employment.

Entry on to Sonesta’s premises or worksites constitutes consent to

searches and inspections.

Any Hotel Employee who refuses to comply with a search or investigation

performed pursuant to this policy will be subject to disciplinary action, up to and
including termination of employment.

28.0 Smoking

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 Smoking, including use of electronic cigarettes, is prohibited at all times
in all areas of Sonesta’s premises and worksites. We will not allow any form of
retaliation against any employee who reports an alleged violation of this policy
in good faith. Smoking may be permitted outside, in specified, designated
smoking areas.

29.0 Guest Privacy and Confidentiality

You are required to comply with all Sonesta rules and policies, and all
applicable laws, pertaining to guest privacy and the confidentiality of guest
information.

Unless you are on a specific work assignment, you may not visit guest
floors, guestroom elevators, lounges, guest restrooms, pool areas, fitness
centers or any other guest areas that are not part of your work assignment. While
on duty, you must obtain your Supervisor’s permission before visiting family or
friends staying at a Sonesta hotel.

You are not allowed to ask any celebrities staying at a Sonesta hotel for any
pictures or autographs.

Fraternization or socialization with guests, either of a sexual or non-sexual

nature, is strictly prohibited while on or off duty and may result in disciplinary
action, up to and including termination of employment.

30.0 Designated Staff Entrance/Exit

While on duty, you must use the service elevators and employee entrance.
While on duty, entering or leaving the hotel other than by the authorized
employee entrance may result in disciplinary action, up to and including
termination of employment.

31.0 Nametags and Employee Identification Cards

If you are issued a nametag, the nametag must be worn at all times while
working, unless otherwise directed by your Supervisor.

If your nametag becomes damaged, you should bring all pieces of the
nametag to our Human Resources Department. You may be charged a
replacement fee for lost badges and nametags, unless otherwise prohibited by
applicable law.

32.0 Lockers

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 You may be provided a locker for storage of personal items while on duty.
It is your responsibility to keep the locker neat and clean at all times. No personal
locks are permitted. Locks and lockers remain the sole property of Sonesta. You
may not share your locker with other employees except as permitted by your
Supervisor. You may not deface or post on lockers. You may not use lockers to
store alcohol, food, flammable materials, illegal drugs, weapons or Sonesta
property.

Sonesta reserves the right to open and inspect lockers and their contents.
Inspections may occur with or without consent or advance notice. Hotel
Employees who fail to cooperate in an inspection may be subject to disciplinary
action, up to and including termination of employment, unless otherwise
prohibited by applicable law.

33.0 Hotel Keys

If you have been assigned or issued a key to any hotel property, including,
but not limited to, a bank or master key, and you lose or fail to return it, you may
be subject to disciplinary action up to and including termination and required to
pay a replacement fee, unless prohibited by applicable law.

34.0 Lost and Found

You are required to submit any item found on any hotel property to the
Lost and Found Department, or, if the Lost and Found Department is not
available, to Security. We retain discretion regarding what to do with any
unclaimed items in the Lost and Found Department.

35.0 Packages

You may not bring any parcels or packages into hotels, or remove hotel
property from hotels without prior authorization from your Supervisor. All
parcels or packages are subject to inspection. You are not be authorized to
remove food, liquor, soft drinks, flowers or other items used by Sonesta in the
ordinary course of business, without prior specific approval from your Supervisor
even if these items are given to you by a guest.

G. COMMUNICATION

36.0 Communication

36.1 Bulletin Boards

We may use bulletin boards located throughout our premises to

communicate information to employees. Use of the bulletin boards by Hotel
Employees is not permitted.

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 36.2 Personal Mail

Sonesta’s mail is stamped by a postage meter. Use of this meter for

personal mail is not permitted.

36.3 Confidential and Proprietary Information and Media

Requests

We have previously provided you with a copy of our Code of Business

Conduct & Ethics, which contains obligations concerning Sonesta confidential
and proprietary information. You must adhere to such obligations. Additional
copies of our Code of Business Conduct & Ethics, and the short form summary
document known as the “STAR Brochure,” may be requested from our Human
Resources Department.

You should not attempt to speak to the press or other news media on
behalf of Sonesta unless specifically authorized to do so by our Vice President of
Marketing and Communications or the Corporate Director of Communications.

37.0 Electronic Communications Policy

Our Electronic Communications Policy applies to any use of our electronic

mail (“email”), voicemail, telephone and Internet access systems. Use of such
systems should be for Sonesta related activities and to facilitate the efficient
exchange of business related information. Users of our electronic systems are
expected to be ethical and honest in their use. This policy applies to every
employee with access to corporate email, including Hotel Employees using
Sonesta hand-held devices and browser based web mail.

While occasional personal use of our telephone, email, voicemail or Internet

systems may be tolerated during working time, routine personal use is not
permitted during working time and should take place during non-working time.
Any personal use during working time may not in any way interfere with your
ability to perform fully your job responsibilities.

You should have no expectation of privacy or confidentiality when using

the telephone, email, voicemail, Internet, or any other electronic communication
systems owned or maintained by Sonesta. We may store electronic
communications for a period of time after the communication is created. From
time to time, communications stored in the system may be deleted, printed or
utilized for any business purpose. We may suspend ordinary course disposal of
emails for business reasons, including, but not limited to, pending or anticipated
litigation, investigations or other official proceedings.

Our Code of Business Conduct & Ethics and policies prohibiting all forms
of harassment and discrimination apply to use of Sonesta’s electronic
communications systems. You may not use electronic communications in a

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manner that may be construed by others as unlawful harassment or
discrimination based on any characteristic protected by federal, state or local law.

All questions regarding our Electronic Communications policy, as well as

specific questions regarding the retention of any electronic communications,
should be addressed to our Human Resources Department.

37.1 Email

The use of personal email accounts (i.e. Yahoo, Google, etc.) to conduct
Sonesta business is strictly prohibited. The following guidelines should be
observed whenever email is used:

1. All business email must pass through Sonesta’s network and server.
You should not send or receive email outside the network and server from a
personal computer or personal server.

2. All email must comply with our Code of Business Conduct & Ethics.

3. Our policies against discrimination and harassment apply to all email

communications.

4. You may not send mass distribution email messages from or to our
network or systems.

5. The sending of a computer virus is not permitted. You should be

careful when opening email from a recipient with whom you are unfamiliar.

6. Email is a permanent form of communication and you should keep

in mind that at all times the contents of email may be scrutinized at a later date
by Sonesta for any business reason.

7. You should have no expectation of privacy in email sent through our

network or using Sonesta equipment or systems. We reserve the right to access,
monitor, copy, and disclose any information processed, stored, or transmitted
using our equipment or systems, with or without notice.

8. Email is discoverable and may be the subject of litigation, document

retention orders and rules, or subpoenas.

9. You should not give out your password to others and should not let
others use your email accounts. You are responsible for all messages sent from
your email accounts.

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 10. Our policies on proprietary information must be strictly observed.

37.2 Internet Use

The Internet may not be used to access sites that contain material that
violates Sonesta policy. In this regard, you may not access any website:

1. That contains pornographic, obscene, sexually explicit, or sexually

oriented language or materials.

2. Whose purpose is, or may be perceived to be, unlawfully harassing

or discriminatory.

3. That indicates possible participation in, or appears to encourage

participation in, any activity that violates Sonesta policies or that may be illegal
or may violate any rule or regulation governing Sonesta.

In addition:

1. Unapproved software and other files distributed via CD, diskette or

other media are subject to the same policy concerning their installation and
usage on our computers. For example, downloading any material which is
pornographic, obscene, sexually explicit, contains sexually oriented language or
materials, or otherwise violates our policy on the use of its computer systems,
including the telephone, Internet, voicemail and e-mail, is prohibited.

2. All file transfers or downloads must comply with state, federal and
international copyright and intellectual property laws.

The above guidelines regarding Email and Internet use also apply to
voicemail, text messages and instant messages.

37.3 Personal Communications Devices

You are not permitted to use personal communications devices (e.g.

smartphone, blackberry, iPhone, iPad) or carry personal pagers or other
communications devices while on duty, unless such devices have been issued to
you by Sonesta. Personal cellular/mobile devices are not permitted in guest areas
and are to be kept in employee lockers during work hours, unless otherwise
authorized by your Supervisor. You may use personal communication devices
during breaks, but only in locations where you will not have contact with guests
and provided that your use of such devices does not involve other employees
who are not on break.

If you use personal communication devices issued by Sonesta and/or

access Sonesta systems via public networks or that transmit/store sensitive
information, you are subject to the following:

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 1. You may not modify the device hardware, or install software or
services on the device which have not been tested/approved by Sonesta.

3. Access to the device must be protected with strong passwords; and

inactivity locks/timeouts.

4. You must comply with the Code of Business Conduct & Ethics and
the Data Privacy Policy and confidential and proprietary data must be protected
by encryption when stored on a personal communication device, and while in
transit on public networks. The encryption requirement applies to internal device
storage and removable media.

5. The device must be maintained in accordance with current Sonesta

security standards.

6. The device must not be used or configured to share its network

connection.

7. Services accessed by the device via Sonesta systems (i.e. email,

internet) are subject to the applicable controls and policies for each service.

8. If the device has direct access to non-Sonesta services or systems,

the device must have compensating controls in place to protect sensitive
information.

9. Loss or theft of the device must be reported immediately to our Chief

Technology Officer.

If the situation warrants, we retain the right to reset any Sonesta device to
factory defaults, including the erasure of all data. We are not responsible for
personal or non-business related information stored on the device or lost as a
result of a reset or data erasure.

37.4 Illegal Activities Using Any Sonesta Systems or Equipment

The following activities are prohibited:

1. Violations of the rights of any person or Sonesta protected by

copyright, trade secret, patent or other intellectual property, or similar laws or
regulations, including, but not limited to, the installation or distribution of
“pirated” or other software products that are not legally licensed for use by us.

2. Unauthorized use or distribution of intellectual property, or other

material that is trademarked or copyrighted. Examples include content from
magazines, books and websites, music, and unlicensed software.

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 3. Exporting software, technical information, encryption software or
technology, in violation of international or regional export control laws. Our
Records Retention Officer (“RRO”) should be consulted prior to export of any
material that is in question.

4. Introduction of malicious programs into the Sonesta network or

computing device (e.g., viruses, worms, Trojan horses, key loggers, rootkits,
etc.), or the alteration of computing systems or assets to conceal the presence of
malicious programs.

5. Use of Sonesta’s systems or resources to obtain or transmit material

that is in violation of harassment or hostile workplace laws.

6. Making fraudulent offers of products, items or services.

7. Disclosure of confidential, proprietary or trade secret information to

unauthorized internal or external parties.

8. Accessing data for which an employee is not the intended or

authorized recipient; gaining access to a system or account that an employee is
not expressly authorized to access; and circumventing authentication or security
of any system, network or account.

9. Intentional disruption of Sonesta computing resources.

10. Monitoring or scanning of Sonesta’s network, computing devices

systems and data without first obtaining permission from our RRO or Chief
Technology Officer.

37.5 Social Media

All use of, and participation in, social media must comply with:

1. Our Code of Business Conduct & Ethics;

2. The guidelines in the Electronic Communications Policy;

3. Any other applicable Sonesta policies; and

4. Applicable law.

37.6 Respect for Others

1. Be respectful of potential readers, business partners, competitors

and clients. We will not tolerate statements about us, our employees or any
organizations associated or doing business with us that are discriminatory on the
basis of any legally protected characteristic, knowingly or recklessly false,
harassing, threatening, obscene, or otherwise prohibited by applicable law.

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 2. You should not use Sonesta’s logo, trademark or proprietary
graphics (collectively, “intellectual property” or “IP”) for any commercial purpose,
such as selling or advertising any product or service, without our prior written
consent. You should not use our IP in any posting unrelated to the terms or
conditions of your employment or that disparages our brand, products or
services. You should not use our IP in a way related to any activity that is unlawful
or that violates Sonesta policy.

37.7 Transparency and General Guidance

1. If from your post in a blog or elsewhere in social media it is clear

that you are a Sonesta employee, or if you mention Sonesta, or it is reasonably
clear that you are referring to Sonesta or a position taken by Sonesta, and the
post also expresses a political opinion or an opinion regarding our positions or
actions, the post must specifically note that the opinion expressed is your
personal opinion and not our position. However, this disclaimer will not relieve
you of any legal consequences that may arise from the commentary. Without
specific authorization from the Corporate Director of Communications, you
should not represent or suggest in any social media activity that you are
authorized to speak for Sonesta, or that we have reviewed or approved your
content. You should specifically state, “The views expressed in this post are my
own. They have not been reviewed or approved by Sonesta.”

2. You should use a personal email address (not a Sonesta email

address) as the primary means of identification when communicating on personal
views. Just as you would not use Sonesta stationery for a letter to the editor with
personal views, you should not use Sonesta email addresses to communicate
personal views on-line.

3. You should not link to Sonesta’s internal web sites from any personal
blogs.

4. You may include clients in your networks of online contacts, however

you should not identify those individuals as Sonesta clients. Outside observers
should not be able to discern whether your contacts are business contacts or
personal contacts.

5. We respect our employees’ rights to express personal opinions and

do not retaliate or discriminate against employees who use the internet for lawful
purposes.

37.8 Violations

Violation of this Policy may result in disciplinary action up to and including

termination of employment and/or other appropriate action, including legal
action.

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 38.0 LEAVING SONESTA

38.1 Notice, Exit Interviews and Return of Sonesta Property

Hotel Employees who leave Sonesta’s employ are asked to provide as much
notice as possible prior to departure. If you leave our employment, you may be
interviewed by our Human Resources Department or your Supervisor regarding
your reasons for leaving and/or employment experience.

Immediately upon request or upon termination of employment, Hotel

Employees must return all Sonesta property, including, but not limited to,
uniforms, nametags, identification badges or cards, keys, access cards,
passwords, books or handbooks, computer or office equipment, and parking
passes. Hotel Employees with uniforms must return uniforms to us and we may
charge replacement costs of unreturned uniforms to the extent permitted by
applicable law.

38.2 References

All requests for information or references for former employees should be

referred to our Human Resources Department.

As a general rule, in response to an appropriate request for a reference

from Sonesta, only facts concerning dates of employment, title, confirmation of
employment, and work locations will be provided. With written authorization
from the impacted employee or former employee, compensation information
will be provided. No additional information will be provided in response to a
request for a reference.

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 ACKNOWLEDGMENT OF RECEIPT OF HANDBOOK

I acknowledge that I have received and read a copy of the Sonesta San Juan
LLC Employee Handbook for Hotel Employees (the “Handbook”). I understand
that the Handbook sets forth the terms and conditions of my employment with
Sonesta as well as the duties, responsibilities and obligations of employment with
Sonesta. I agree to abide by and be bound by the rules, policies and standards
set forth in the Handbook.

I acknowledge that my employment with Sonesta is not for a specified

period of time and that the employment relationship may be terminated at any
time, for any reason, with or without cause or notice, by me or by Sonesta.

I further acknowledge that Sonesta reserves the right to interpret, revise,

delete and add to the provisions of the Handbook, but that any revision, deletion
or addition must be in writing. No oral statements or representations can change
the provisions of the Handbook.

_____________________ __________________________________
Date Employee’s Signature

__________________________________
Print Name