Recordkeeping

The Environmental Health & Safety (EHS) department at Dow Aero (“Company”) is responsible for retaining and destroying confidential personnel records in accordance with corporate policies and procedures, along with statutory and regulatory requirements. The following is a general outline of the Company’s Environmental Health & Safety (EHS) department’s operating policies and procedures for personnel record retention and destruction; at its discretion, the Company may expand the record retention period beyond what is identified below.

If the Company’s retention timeline is not of sufficient duration for statutory or regulatory requirement, then law or regulation shall govern.

Minimum Retention of Records

Compliance

• OSHA 300 / 300A — Posting date + 5 Years

Inspections

• Daily — Inspection date + 2 Years

  • Daily Forklift Operator Inspection

• Weekly — Inspection date + 2 Years

  • First Aid Kit Inspection

  • Plumbed Eye Wash Station Inspection

  • Weekly Scissorlift Operator Inspection

• Monthly — Inspection date + 2 Years

  • AED Inspection

  • Indoor Chemical Spill Container Inspection

  • Monthly Forklift Inspection

  • Outdoor Chemical Spill Container Inspection

  • Portable Fire Extinguisher Inspection - Monthly

• Quarterly — Inspection date + 2 Years

  • Personal Eye Wash Stations Inspection

• Annually — Inspection date + 2 Years

Destruction of Employee and Applicant Information

All confidential personnel records maintained by the Environmental Health & Safety (EHS) department shall be destroyed as retention dates pass. Any employment materials submitted by applicants, and who were never employed by the Company, are also to be destroyed as appropriate. This pertains to all employee and applicant information, not just specific info governed by the Fair and Accurate Credit Transactions Act (FACTA).

When confidential records or materials must be discarded or destroyed, the information shall either be:

• Deleted from an appropriate Environmental Health & Safety (EHS) system if electronic data.

• Shredded by the Company’s Environmental Health & Safety (EHS) department personnel if a paper document.

Litigation Hold

When the Company is involved in or anticipates that it may be involved in litigation, a litigation hold may be issued. This means that all records relating to the litigation matter shall be kept in order to preserve any potential evidence. In failing to do so, the Company may be sanctioned by the court for destroying evidence. A court has broad authority to impose these sanctions, which may include anything from unfavorable procedural rulings during a trial to payment of monetary damages.

In the event that the Company announces a litigation hold on any or all Company records as a result of pending or anticipated litigation, all records covered by such a litigation hold SHALL NOT be discarded, deleted, or destroyed. Further, the Company’s Information Technology (IT) department shall be notified to suspend any automatic deletion of communication records and data, as appropriate, for all individuals covered by the litigation hold. Any questions regarding employment litigation should be directed to the Company’s Human Resources (HR) department.