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COVID‐19 Preparedness and Response Plan for Corporate Building Offices (The “Plan”).

Policy Number: RC491

Effective date: 6/1/2020

This Plan complies with the State of Michigan Governor’s Executive Order 2020‐97 and aligns with OSHA Guidance on Preparing Workplaces for COVID‐19 (OSHA 3990‐03 2020), Centers for Disease Control (CDC) Interim Guidance for Businesses and Employers Responding to Coronavirus Disease 2019 (COVID‐ 19), May 2020 and Detroit’s COVID‐19 Small Business PlayBook. The Plan is readily available to employees, and customers, whether via website, internal network, or by hard copy.

PVS Chemicals, Inc. (PVS) is committed to achieving and maintaining a safe and productive work environment for all employees. This includes providing a clean, healthy, safe, and secure work environment. To achieve this, PVS will take the following actions with respect to all employees who are asked to work at the PVS Corporate Building 10900 Harper Ave. Detroit, MI 48213 (the “Facility”):

• Provide employee training on COVID‐19
• Perform employee screening before entry
• Monitor employee health status while at work
• Enable contact tracing of exposed employees
• Follow social distancing guidelines
• Provide for workplace sanitation
• Require proper handwashing
• Require and provide for appropriate Personal Protective Equipment (PPE)

These actions will help to keep the virus out of the Facility, prevent the spread within the Facility, and properly manage suspected or confirmed cases. Each employee is expected and required to report to work ready, willing, and able to perform his or her assigned duties. To help ensure a safe and healthy working environment, employees will be expected to adhere to all company procedures and guidelines.

The on‐site worksite supervisors for the Corporate Building who are responsible for the implementation, monitoring, and reporting on the Plan control strategies are listed below with contact information.

PVS Chemicals, Inc. Security (313) 921‐1200

One or more of these supervisors (or their designee) must remain on‐site at all times when employees are present on‐site.

Training

PVS will provide training on COVID‐19 subjects through the Training Section of PVS’s Human Resources Department / EHS&S Department / Local Site Managers. The training will cover: routes by which the virus causing COVID‐19 is transmitted from person to person, distance that the virus can travel in the air, as well as the time it remains viable in the air and on environmental surfaces, workplace infectioncontrol practices, the proper use of personal protective equipment (PPE), including the proper steps for putting it on and taking it off, steps the employee must take to notify PVS of any symptoms of COVID‐19 or a suspected or confirmed diagnosis of COVID‐19, and how to report unsafe working conditions.

Screening/Monitoring

Employees and contractors must report to the screening area immediately upon entering the Facility; when entering the Facility, employees must use the dedicated employee entrance – Lemay & East Parking Lot Door next to rail road crossing. Use of the dedicated entry point for all employees shall reduce congestion at the main entrance. The screening area is located in main lobby. The on duty security officer or site facility manager will complete entry screening by using the COVID‐19 Screening Form (RC488) for each employee and each contractor or accept a completed self‐screen (RC488). During the screening process employees and contractors are allowed to wear a cloth face covering and should maintain social distancing. Employees who are sick please should not report to work and should instead notify their manager or Human Resources.

Under the federal Americans with Disabilities Act, employees’ medical information must be kept confidential; therefore, any information about temperatures if taken will be treated as confidential medical information and kept separate from the general personnel files.

Human Resources is responsible for the employee health information policy. Human Resources will determine which types of methods are used to collect the information, with consideration given to applicable state laws.

Employees who develop symptoms while at work are expected to come forward. The employees may be asked health‐related questions and have their temperatures taken.

Employees who are found to have COVID‐19 symptoms as defined by the CDC, will be isolated from the rest of the workforce and sent home.

PVS will retain RC488.

Social distancing guidelines

Employees shall maintain social distancing (6’ minimum) while in the Facility to minimize the spread of germs and potential infection. Based on public health requirements, proper social distancing is required throughout the worksite, including, without limitation, such work areas as the following:

• Meeting and conference rooms
• Common areas, kitchenettes, and break rooms
• Supply rooms, mail room, or communal work areas (e.g., shared printer)
• Parking lots and garage (including carpooling)
• Hallways, stairwells, and elevators
• Restrooms

PVS will assist employees to maintain social distancing through the use of ground markings, signs, and physical barriers, as appropriate to the worksite.

PVS management may also determine that an effective way to aid in social distancing is to alter work shifts, limit the number of employees at a worksite, or encourage/require employees who are able to work remotely to do so.

PVS follows proper social distancing standards established by the CDC. Employees will be expected to comply with the standards as adopted by PVS, as well as be prepared to adapt based on safety and health protocols at work. Social distancing adjustments at a worksite may include the following:

• Physical modifications within offices and work areas
• Additional space between cubicles, desks, or chairs
• Visual clues
• Rigid dividers between coworker
• Virtual meeting and conference calls

To reduce the spread of germs, PVS management may set limits and restrictions on nonessential workrelated activities like communal food, company picnics, social gatherings, celebrations, and potlucks. To maintain the highest level of health and safety at work, the company encourages employees to follow all public health guidelines while off work.

PVS will also attempt to increase distancing between employees by spreading out workspaces, staggering workspace usage, restricting non‐essential common space (e.g., eating areas), providing visual cues to guide movement and activity (e.g., restricting elevator capacity with markings, locking conference rooms).

Doors have been propped open throughout the Facility to prevent touching and increase airflow.

All water fountains at the worksite shall remain turned off.

PVS management will monitor employees social distancing at work and will address any concerns or issues.

PVS prohibits social gatherings and meetings that do not allow for social distancing or that create unnecessary movement through the office.

Workplace sanitation

PVS achieves and maintains a clean and safe work environment for all employees at the workplace. Facilities and Janitorial Services perform daily and routine housekeeping on all common areas and high-touch surfaces (e.g., whiteboard markers, restrooms, handles) throughout the facility except for employees work stations (offices and cubicles). There are times when our facility and/or your hands are not perfectly clean. This is another reason why we emphasize frequent handwashing and recommend you to wear a face mask. Employees are required to clean and disinfect their work stations (2) times per day at a minimum with provided materials. Clean the frequently touched surfaces in your work station by only using PVS provided materials. High‐touch surfaces include: Tables, desks, light switches, cubicle walls, office door handles, chairs, phones, keyboards, etc. PVS encourages employees to minimize shared items when possible (e.g., pens, remotes, and whiteboards).

If sharing electronics (such as printers, tablets, touch screens, laptops, and remote controls), employees are required to clean and disinfectant by following the manufacturer’s instructions. Use alcohol‐based wipes or sprays containing at least 70 percent alcohol (if there is no guidance). Dry surface thoroughly.

Contact the IT Help Desk for additional guidance on cleaning and disinfecting electronics.

PVS will adopt any additional infection‐control measures that are reasonable in light of the work performed at the worksite and the rate of infection in the surrounding community.

Personal Hygiene

PVS shall post signs about the importance of personal hygiene.

Handwashing

PVS is committed to achieving and maintaining a safe and productive work environment for all employees. Part of this includes requiring employees to perform proper handwashing. Clean hands can help stop germs from spreading from one person to another, and throughout the community— especially from home and to the workplace.

PVS will provide soap, clean running water, and paper towels to combat the spread of COVID‐19 and other illnesses. PVS shall also provide time for employees to wash hands frequently or to use hand sanitizer. Washing hands with soap and water is the best way to get rid of germs in most situations. Employees are required to wash their hands often while at work, especially:

• After having been in a public place and touched an item or surface that may be frequently touched by other people.
• Before, during, and after preparing food.
• Before eating food.
• Before and after treating a cut or wound.
• After using the bathroom facilities.
• After blowing their nose, coughing, or sneezing.
• After touching garbage or recycling items.

Employees are required to follow five steps to wash their hands:

1. Wet hands with clean, running water (warm or cold), and apply soap.
2. Lather hands by rubbing them together with the soap. Lather the backs of hands, between fingers, and under fingernails.
3. Scrub hands for at least 20 seconds.
4. Rinse hands well under clean, running water.
5. Dry hands using a clean paper towel.

PVS will provide the proper alcohol‐based hand sanitizer when soap and water aren’t readily available. PVS is aware hand sanitizers are not as effective when hands are visibly dirty or greasy, or when there is the presence of harmful chemicals. In this case, employees must wash their hands using the five steps listed above.

Employees are required to follow three steps when using hand sanitizer:

1. Apply the product to the palm of one hand (read the label to learn the correct amount).
2. Rub hands together.
3. Rub the product over all the surfaces of hands and fingers until hands are dry. This should take around 20 seconds.

Personal protective equipment

PVS is committed to achieving and maintaining a safe and productive work environment for all employees. This includes providing a clean, healthy, safe, and secure work environment. Part of this includes requiring employees to use personal protective equipment (PPE) to prevent the spread of COVID‐19.

Face coverings

Cloth face covering shall be worn when social distancing cannot be maintained. Cloth face coverings also required in all shared spaces, including in‐person meetings, restrooms, and hallways. PVS will provide non‐medical grade face coverings to all employees. Cloth face coverings protect other employees working around the employee wearing the face covering.

Employees must make sure cloth face coverings:

• Fit snugly but comfortably against the side of the face.
• Be secured with ties or ear loops.
• Include multiple layers of fabric.
• Allow for breathing without restriction.
• Can be laundered and machine dried without damage or change to shape.

They should be routinely washed depending on the frequency of use. A washing machine can be used to wash a face covering. Employees should be careful not to touch their eyes, nose, and mouth when removing their face covering and wash hands immediately after removing. PVS will provide cloth face coverings or allow employees to bring in their own. Handle face coverings with clean and dry hands. Store clean face coverings in an appropriate container.

Gloves, Protective Clothing, and Face Shields

PVS does not require the use of additional PPE in the workplace for general activities. PVS will provide appropriate additional PPE if needed for specific activities.

COVID 19 Cleaning Protocol

PVS has adopted the following COVID‐19 Cleaning Protocol: The PVS EHS&S + Facilities team members will deep clean and disinfect the facility in the event of a positive COVID‐19 case in the workplace. They will employ the following protocol based on RC document number 486.

Shut down contaminated area(s).

• Open outside doors and windows to increase air circulation in the contaminated area
• Wait up to 24 hours before beginning cleaning and disinfection.
• If surfaces are dirty, they shall be cleaned using a detergent or soap and water prior to disinfection.
• Disinfect cleaned surfaces with diluted bleach and or EPA‐registered disinfectants
• Fog entire contaminated area with disinfectant

COVID 19: Positive Case

Any employee who develops symptoms while at work is to report the condition to their manager or other Human Resources. The employee will be isolated and sent home. If employees report this information to their manager, those managers are to immediately communicate the incident to Human Resources. If a positive COVID‐19 employee case occurs in the workplace, the area(s) where that person worked will be cleaned and disinfected.

When an employee is identified with a confirmed case of COVID‐19, within 24 hours, PVS will notify the local public health department and any co‐workers, contractors, visitors, or suppliers who may have come into contact with the person with a confirmed case of COVID‐19. PVS will also notify employees if PVS learns any individual (including a customer, supplier, or visitor) with a confirmed case of COVID‐19 has visited the office.

Employees who have been exposed will be expected to cooperate with related contact tracing efforts. This may include asking about others with which the employee has been in contact in the recent past.

Employees with a confirmed or suspected case of COVID‐19 shall be allowed to return to the Facility only after they are no longer infectious according to the latest guidelines from the CDC.

Business Travel

PVS restricts business‐related travel for employees to essential travel only; including in‐person conference events.

Public Transportation

PVS Encourage employees to use personal protective equipment and hand sanitizer on public transportation.

Remote Work

PVS promotes remote work to the fullest extent possible. Visitors PVS suspends all nonessential visitors at the Facility.

Return to Workplace

Copies of the return‐to‐work policy and training will be provided to all employees. All employees will read, understand, and abide by the rules of this policy. Employees will be asked to sign and or email an acknowledgment form or indicating that they have received a copy of the return‐to‐work policy. Questions concerning this policy, or its administration should be directed to your manager.

Upon arriving at the facility, employees will report to the lobby through assigned entry points and asked medical status questions. If a line forms at the lobby adhere to social distances marking located on the floor of the main hallway corridor.

If an employee’s responses suggest symptoms related to COVID‐19, the employee will be isolated from the rest of the workforce and sent home. Employees who are sent home will be allowed to return to work only after meeting the CDC or local public health guidelines for ending quarantine or isolation.

Only specific identified individuals will be allowed to ask medical questions. The tests will be performed accurately and consistently. They will adhere to the applicable medical information confidentiality requirements.

PVS will not discharge, discipline, or otherwise retaliate against employees who stay home or who leave work when they are at particular risk of infecting others with COVID‐19.