Incentive Plan – Error & Compliance Recoupment Policy

Legal & Compliance

HR & Employee Care · Internal Policy · Joyner Transportation & Logistic Services

USA Operations Centers Incentive Plan – Error & Compliance Recoupment Policy May 2017

State/Area Exceptions

None

Overview

The purpose of the Error and Compliance Recoupment Policy is to establish guidance for handling incentive awards in the event an error, fraud or other misconduct impacts results and corresponding awards.

General Information

NOTE: This Policy applies to all incentive plans within Joyner Transportation & Logistic Services Company and its subsidiaries.

Employee Actions

Immediately report any discrepancies with your supervisor or manager.

Managerial Actions

Supervisors and Managers should work with HREC Services in event an error or discrepancy.

Human Resources Role

Human Resources staff should be familiar with the provisions of the policy in order to help leadership administer the Incentive Plan - Error and Compliance Recoupment Policy in an accurate and consistent manner. HREC will work with Financial Services in event an error or discrepancy.

Time Period | Situation

One Year Look Back Applies to overpayments or underpayments of incentive awards caused by errors discovered within one year following the plan year impacted by the error | Errors Repayment of an incentive award (partial or full) by a participant is required when a calculation or result error is discovered that caused an overpayment of the incentive award. Payment of an incentive award (partial or full) to a plan participant will be made when a calculation or result error is discovered that caused an underpayment of the incentive award. Note: The CEO or his designees apply discretion to determine if errors are material for recoupment or payment.

Three Year Look Back Applies to errors discovered within three years following the plan year impacted by the fraud / misconduct | Fraud / Misconduct If an incentive plan participant engages in fraud or other misconduct that impacts underlying results and incentive awards, the individual involved in the fraud / misconduct is required to repay the entire incentive received for the impacted year(s). Note: Other plan participants impacted by the fraud / misconduct but not personally engaged in the fraudulent activity are subject to the one year look back outlined above.

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