Policy SummaryThis Policy governs the use of cellphones and other mobile communication devices by employees of The Blevins Company and its operating companies, whether the device is personally owned or issued by the Company. It establishes expectations for device use during working hours, safeguards for Company-issued equipment, mandatory restrictions on device use while operating a vehicle for Company business, and limits on the use of camera, video, and audio recording capabilities on Company premises.
This Policy applies enterprise-wide to all employees, officers, and Governors of The Blevins Company and each of its operating companies. Every person within scope shall comply with all applicable local, state, and federal laws governing cellphone use, shall protect Company-issued equipment from loss, damage, or theft, and shall not read or send text messages while driving in the course of Company business.
Approving Authority Board of Governors
Policy Sponsor Chief Human Resources Officer
Policy Owner Director, HR Compliance
Responsible Committee Policy Administration Committee (PAC)

Review Cycle Every three (3) years, or upon material change in law
Policy ID HR.032, Rev. 1.0
DefinitionsTERM DEFINITIONCellphone: Any handheld or wearable mobile communication device capable of voice, text, or data transmission, including smartphones, tablets with cellular capability, and smartwatches.Company: The Blevins Company and each of its operating companies, subsidiaries, and affiliates.Company-Provided Cellphone A Cellphone owned or leased by the Company and issued to an employee for work-related communications.Hands-Free Operation Use of a Cellphone that does not require the user to hold the device, including a paired vehicle system, wired or wireless headset, or speakerphone mode with the device secured in a mount.Personal Cellphone A Cellphone owned by an employee and not issued or subsidized by the Company.Recording-Capable Device Any device with camera, video, or audio recording functionality, whether or not that functionality is in use.Working Hours Time during which an employee is engaged in or expected to be engaged in the performance of job duties, excluding meal and rest breaks.
Policy TextGeneral UseCellphones shall be turned off or set to silent or vibrate mode during meetings, conferences, and in any circumstance in which an incoming call or notification may be disruptive.Personal CellphonesEmployees shall exercise discretion in the use of Personal Cellphones during Working Hours. Excessive personal calls, messages, or device use during the workday interferes with productivity and may distract others. Employees should place personal calls during nonwork time where practicable and should ensure that friends and family members are aware of this Policy.The Company shall not be liable for the loss, damage, or theft of a Personal Cellphone brought into the workplace.Company-Provided CellphonesWhere job duties or business needs require, the Company may issue a Company-Provided Cellphone to an employee for work-related communications. Personal use of a Company-Provided Cellphone shall be kept to a minimum.An employee in possession of a Company-Provided Cellphone shall protect the device from loss, damage, or theft. Upon resignation or termination of employment, or at any time upon request, the employee shall produce the device for return or inspection.Safety and Cellphone Use While DrivingAll employees shall comply with applicable local, state, and federal laws and regulations governing Cellphone use at all times.An employee whose job responsibilities include regular or occasional driving and who is issued a Company-Provided Cellphone shall refrain from using the device while driving. The Company does not require any employee to use a Cellphone while operating a vehicle, and no employee shall be subject to adverse action for declining to do so. Safety shall take precedence over all other concerns.Regardless of circumstances, including slow or stopped traffic, an employee shall use Hands-Free Operation or shall pull off to the side of the road and safely stop the vehicle before placing or accepting a call. Employees should refrain from discussing complicated or emotionally charged matters while driving and should keep their attention on the road at all times. Particular care should be exercised in heavy traffic, in inclement weather, or when driving in an unfamiliar area.Reading or sending text messages while driving is prohibited.The Company shall provide hands-free equipment with each Company-Provided Cellphone to facilitate compliance with this subsection.An employee who incurs a traffic citation or other penalty arising from the employee's use of a Cellphone while driving shall be responsible for any fine or penalty assessed against the employee personally.Recording-Capable DevicesUse of a Recording-Capable Device on Company premises is prohibited where necessary to secure client or patient privacy, to protect trade secrets and other confidential business information, or to comply with a contractual or regulatory confidentiality obligation. Recording in restrooms, locker rooms, and other areas in which a person has a reasonable expectation of privacy is prohibited at all times.Compliance and ResponsibilitiesBoard of GovernorsThe Board of Governors shall approve this Policy and each Substantive Revision to it, and shall retain ultimate accountability for the Company's governance framework.Chair of the BoardThe Chair shall place proposed adoptions, revisions, and rescissions of this Policy on the Board agenda and shall authorize emergency action where a delay would expose the Company to material legal or safety risk.Policy Administration CommitteeThe Policy Administration Committee (PAC) shall review this Policy for form, consistency, and conflict with other instruments before it is presented to the Board, and shall confirm that the Required Drafting Format has been satisfied.Policy SponsorThe Chief Human Resources Officer, as Policy Sponsor, shall own the substantive content of this Policy, shall present it to the PAC and the Board, and shall approve Technical Revisions.Policy OwnerThe Director, HR Compliance, as Policy Owner, shall maintain the current text, monitor legal developments affecting Cellphone use, initiate the scheduled review, and respond to interpretation questions.Clerk of the BoardThe Clerk of the Board shall record Board approval, assign the version number, publish the approved text to the policy library, and maintain the Revision History.Governors, Officers, and EmployeesEach Governor, officer, and employee shall comply with this Policy, shall complete any training assigned in connection with it, and shall report suspected violations to the Policy Owner or through the Company's reporting channels.Accountability MatrixResponsibility Board PAC Sponsor PO Corp. Sec. CommitteeApprove this Policy A C R C I CApprove Substantive Revision A C R R I CApprove Technical Revision I C A/R R I IDraft and maintain text I C A R I CMonitor legal developments I I A R I CReview for form and consistency I A/R C C I IPublish and record version I I C C A/R IIssue and recover Company devices I I A R I IMonitor compliance and report violations I I A R I CRescind this Policy A C R C I C
A = Accountable · R = Responsible · C = Consulted · I = Informed · A/R = Accountable and Responsible. PAC = Policy Administration Committee; PO = Policy Owner; Corp. Sec. = Clerk of the Board / Corporate Secretary; Committee = Responsible Board Committee.ProceduresPolicy ReviewThe Policy Owner shall initiate a review of this Policy no less than every three (3) years, and promptly upon any material change in applicable distracted-driving, wiretap, or workplace-privacy law. The Policy Owner shall report the outcome of each review to the Policy Sponsor and the PAC.Substantive RevisionA revision that changes an obligation, prohibition, scope, or allocation of accountability under this Policy is a Substantive Revision and shall be approved by the Board of Governors on the recommendation of the PAC.Technical RevisionA revision limited to correction of typographical errors, updated titles or contact information, cross-reference renumbering, or formatting is a Technical Revision and may be approved by the Policy Sponsor without Board action. The Clerk of the Board shall record each Technical Revision in the Revision History.Compliance-with-Law RevisionWhere a change in law renders any provision of this Policy unlawful or unenforceable, the Policy Owner shall prepare a conforming revision and the Policy Sponsor may place it into immediate effect pending ratification by the Board at its next regular meeting.Emergency AuthorizationWhere a delay in revising this Policy would expose the Company to material legal or safety risk, the Chair may authorize interim measures in writing. Interim measures shall expire upon Board action or ninety (90) days from issuance, whichever occurs first.RescissionThis Policy may be rescinded only by action of the Board of Governors. The Clerk of the Board shall retain the rescinded text and the record of rescission in the policy library.Device Issuance and ReturnThe Policy Sponsor shall maintain administrative procedures under GOV.02 governing the request, approval, issuance, inventory, and recovery of Company-Provided Cellphones, including the hands-free equipment required under Section III.D.Reporting and EnforcementAn employee who violates this Policy shall be subject to discipline, up to and including termination of employment. The Policy Owner shall record reported violations and shall report aggregate compliance trends to the Policy Sponsor annually.Related InformationParent AuthoritiesGOV.01 — Policy on Policies (Board Policy governing the creation, format, and administration of all Tier 1 instruments). GOV.02 — Administrative Procedures (governing Tier 3 operational procedures referenced in Section V).Related PoliciesAcceptable Use of Information Technology Resources; Confidentiality and Trade Secrets Policy; Employee Handbook (Workplace Conduct); Fleet and Vehicle Safety Policy; Records Retention Policy.FormsCompany Device Issuance and Acknowledgement Form; Device Return Certification; Employee Acknowledgement (Section VIII).External ReferencesNational Labor Relations Act, 29 U.S.C. §§ 157 and 158(a)(1); applicable state distracted-driving statutes; applicable state and federal wiretap and two-party consent recording statutes.Reservation of Employee RightsNothing in this Policy is intended to, nor shall be construed to, limit or interfere with employee rights under any applicable provision of the National Labor Relations Act, including Section 7 and Section 8(a)(1) rights to organize and to engage in protected, concerted activity regarding the terms and conditions of employment.Frequently Asked QuestionsQ: May I keep my personal phone at my desk during working hours?A: Yes. Personal Cellphones are permitted in the workplace. Employees shall exercise discretion in using them during Working Hours and shall set devices to silent or vibrate in meetings and other settings where notifications may be disruptive.Q: The Company gave me a phone. Am I required to answer it while I am driving?A: No. The Company does not require any employee to use a Cellphone while driving, and no employee shall be subject to adverse action for declining to place or accept a call while operating a vehicle. Use Hands-Free Operation or stop the vehicle safely before responding.Q: Is hands-free calling always permitted while driving?A: No. Hands-Free Operation is permitted only where applicable law allows it. Where state or local law prohibits any Cellphone use while driving, that law controls and the employee shall not use the device.Q: If I am ticketed for phone use while driving on Company business, who pays the fine?A: The employee is responsible for any fine or penalty assessed against the employee personally.Q: May I take a photograph of my team on Company premises?A: Use of a Recording-Capable Device is prohibited where necessary to protect client or patient privacy, trade secrets, or confidentiality obligations, and is prohibited at all times in restrooms, locker rooms, and comparable areas. Where none of those conditions apply, an incidental photograph is permitted. Consult the Policy Owner if you are uncertain.