Record Retention Policy

Record Retention Policy. The Company shall maintain a comprehensive record retention program that governs the creation, maintenance, protection, retrieval, and destruction of all Company records in compliance with applicable laws and regulations, including the Sarbanes-Oxley Act, SEC regulations, IRS requirements, HIPAA (where applicable), and state record retention statutes. Records shall be classified into categories with specific retention periods as follows: (a) corporate records (articles of incorporation, bylaws, minutes, stock records) — permanent; (b) financial records (general ledger, audited financial statements, tax returns) — minimum seven (7) years; (c) employment records (personnel files, payroll records, I-9 forms) — as required by applicable federal and state law, generally three (3) to seven (7) years after termination; (d) contracts and legal documents — duration of the agreement plus seven (7) years; (e) insurance records — life of the policy plus seven (7) years; and (f) electronic communications — three (3) years unless subject to a litigation hold. No records shall be destroyed if they are subject to a pending or reasonably foreseeable litigation, audit, investigation, or regulatory proceeding. The intentional destruction of records in violation of a litigation hold or regulatory preservation requirement is strictly prohibited and may constitute a criminal offense.