Kennebec Telephone CompanyPersonnel Document Retention Policy

Kennebec Telephone Company is required by law to keep certain recruitment, employment and personnel information for a designated period of time. Accordingly, the Company has adopted the following Personnel Document Retention Policy.

Purpose To establish accountability for records management and retention. To define certain terms relevant to records management and retention. To strengthen safeguards against the unauthorized or accidental disclosure or destruction of

personnel and confidential records. To establish the length of time certain categories of records are required to be maintained and

stored. To establish appropriate records destruction practices.

Policy

It is the policy of Kennebec Telephone Company to comply with applicable laws and best business practices with regard to the records it maintains, and to apply those laws and practices consistently.

Definitions

“Confidential Record” – The following types of Records are considered confidential:

" Individual employment records, including records which concern hiring, appointment, promotion, tenure, salary, performance, termination or other circumstances of employment;

Records that include medical information or "protected health information" as defined by the Health Insurance Portability and Accountability Act of 1996 (HIPAA);

Records the use of which has been restricted by contract; All administrative records of the Company,

“Electronic Record” – Any Record that is created, received, maintained and/or stored on University local workstations or central servers, regardless of the application used to create that Record. Examples of Electronic Records include, but are not limited to, electronic mail, word-processing documents, spreadsheets and databases.

“Paper Record”– Any Record maintained in a hard copy paper format, regardless of whether the Record was originally created on paper or as an Electronic Record.

“Records” – As used in this Policy, “Records” refer to Electronic and Paper Records, unless a particular format is specified.

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“Required Retention Period"– The retention period set forth in the Company’s Records Retention Schedule.

“Responsible Department” – responsible for ensuring that a particular Record is maintained for the Required Retention Period.

Electronic Records

Unless otherwise specifically set forth in this Policy, maintenance and disposition of Electronic Records shall proceed on the same basis as Paper Records.

Safeguards Against Unauthorized or Accidental Disclosure

Until Records are properly disposed, each Department and Employee is accountable for securing and maintaining its Records regardless of format or location. Each Department is accountable for ensuring that employees, and others, are only granted access to Confidential Records essential to the performance of their duties. Further, each Department must ensure that those granted access are trained and employ reasonable safeguards to protect the Confidential Records.

Records Retention Schedule

The Records Retention Schedule sets forth the length of time Records should be retained by the Responsible Department or Personnel.

The General Manager should be notified of any Personnel Records not encompassed within the Records Retention Schedule. The General Manger will determine, in consultation with appropriate personnel and legal counsel, whether to destroy the Records in question or add those Records to the Records Retention Schedule.

Extended Retention Period

Records which are retained beyond the Required Retention Period should be destroyed and disposed of, in accordance with this Policy, as early as practical.

Destruction Authorization

Destruction of Electronic Records will be a coordinated effort between the Responsible Department and the General Manager. When the Required Retention Period for Electronic Records expires, the Responsible Office will initiate the process for the Records’ destruction and disposal. The destruction of those Electronic Records will be authorized jointly by the Human Resources Director and the General Manager.

When the Required Retention Period for a Paper Record expires, the senior officer of the Responsible Department shall initiate the process for the Records’ destruction and disposal. The destruction of those Records shall be authorized by the Human Resources Manager.

Safe and Secure Disposal All Paper Records covered by the Records Retention Schedule shall be destroyed by

shredding. All Electronic Records covered by the Records Retention Schedule shall be destroyed by or under the supervision of the General Manager or his designee.

Destruction Record

A destruction record is an inventory describing and documenting those Records, in all 2

formats, authorized for destruction, as well as the date, agent, and method of destruction. The destruction record itself shall not contain confidential information. If a Paper Record is the subject of destruction, the destruction record shall be retained in the Responsible Department. If an Electronic Record is the subject of destruction, two copies of the destruction record shall be retained: one in the Responsible Department and in the General Manager’s office. The destruction record may be retained in paper, digital, or other format.

Suspension of Records Retention Schedule

When a claim or litigation involving the Company or its employees is filed or threatened, the law imposes a duty upon the Company to preserve all Records that pertain to the issues involved. Once the Company is aware that an administrative claim or litigation exists or is likely to be filed, the General Manager or legal counsel will issue a hold directive. The litigation hold directive overrides the Records Retention Schedule that may have otherwise called for the destruction of the relevant Records, until the hold has been lifted by the General Manager or legal counsel. The suspension applies equally to Paper and Electronic Records, including duplicate copies. No Kennebec Telephone Co. employee who has been notified by the General Manager of a litigation hold may alter or destroy a Record that falls within the scope of that hold. Violation of the hold may subject the individual to disciplinary action, up to and including dismissal, as well as personal liability for civil and/or criminal sanctions.

Any employee who becomes aware of litigation or threatened litigation prior to receiving a litigation hold shall inform the General Manager immediately and shall suspend the Records Retention Schedule until a litigation hold, defining the scope of the suspension, is issued by the General Manager or legal counsel.

Personnel Document Retention Schedule

Type of Record Relevant Law Years to be Kept Records CoveredSelection, Hiring & Employment Records

Age Discrimination in Employment Act

Americans with Disabilities Act

Civil Rights Act of 1964 (Title VII)

1 year after creation of the document or the hire/no hire decision whichever is later.

Job applications, resumes, job ads, screening tools/tests, interview notes and other records related to hire/no hire decisions.

Records related to promotions, demotions, transfers, performance appraisals, terminations, reasonable accommodations and/or requests, training records,

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incentive plans, merit systems, and seniority systems.

Payroll Records, Time Sheets/Cards

Age Discrimination in Employment Act

Fair Labor Standards Act

Equal Pay Act

Lilly Ledbetter

3 years Basic employee data: name, address, Social Security number, gender, date of birth, occupation and job classification. Compensation records:Amounts and dates of actual payment.Time and day of week when employee's workweek begins.Total hours worked each day and workweek.Basis and rate which employee's wages are paid (e.g., "$9 per hour", "$455 a week", "piecework"). Straight time and overtime hours/pay. All additions to or deductions from the employee's wages.Total wages paid each pay period.Date of payment and the pay period covered by the payment.Records explaining any sex-based pay differences.Annuity and pension payments.Fringe benefits paid.

Form I-9 Immigration Reform and Control Act

3 years after date of hire or one year after date of termination, whichever is later

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Employment Benefits Employee Retirement Income Security Act

6 years after plan year Except for specific exemptions, ERISA’s reporting and disclosure requirements apply to all pension and welfare plans, including: Summary plan description (updated with changes and modifications), annual reports, notice or reportable events (such as plan amendments that may decrease benefits, a substantial decrease in the number of plan participants, etc.), plan termination.

Tax Records Federal Insurance Contribution Act

Federal Unemployment Tax Act

Federal Income Tax Withholding

4 years from date tax is due or paid

Amounts of wages subject to withholding.Agreements with employee to withhold additional tax.Actual taxes withheld and dates withheld.Reason for any difference between total tax payments and actual tax payments.Withholding forms (W-4, W4-E).

Safety Data Occupational Health & Safety Act

5 years following the year records pertain to (*Medical exams, material safety data sheets and exposure to toxic substances records retained for the duration of employee’s job tenure plus 30 years)

Log of occupational injuries and illnesses. Records of injuries and illnesses. Summary of injuries and illnesses. Records of exposure to toxic substances for each employee.

Credit Reports Fair and Accurate Credit Transactions

No retention requirement. Law requires shredding of all documents

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containing information derived from a credit report. Don’t discard for at least one year though (see Selection, Hiring & Employment Records)

Drug Test Records Department of Transportation (DOT) covered safety-sensitive transportation positions; aviation, trucking, railroads,mass transit and pipelines.

1 year from testdate (up to 5 years for records relating to drug testing for DOT positions, see § 382.401 for specific DOT retention requirements)

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Kennebec Telephone Co., Inc.CAPITALIZATION POLICY

Effective 1/1/2014

The purpose of the capitalization policy is to set forth guidelines for the proper accounting treatment of equipment purchases and construction of telecommunications plant.

Current year expenditures related to the purchase, construction, or repair should be capitalized based on the criteria identified below. The dollar amount indicated below is applied on a “per item” basis and not to the total invoice cost.

Kennebec Telephone Co., Inc. follows the prescribed guidelines set forth by the Federal Communications Commission under CFR Title 47 Part 32 Subpart C §32.2000 Instructions for telecommunications plant accounts

The following specific guidelines apply to the capitalization of equipment purchases and construction of telecommunications plant:

Tangible telecommunications plant and equipment which ordinarily has a service life of more than 12 months. The individual items of equipment purchases classifiable to the following accounts and in excess of $500

(including any direct and indirect costs described below):o Account 2112 – Motor vehicleso Account 2113 – Aircrafto Account 2114 – Tools and other work equipmento Account 2122 – Furnitureo Account 2123 – Office equipment

The cost of tools and test equipment located in the central office in excess of $500 and classifiable to following central office accounts (including any direct and indirect costs described below):

o Account 2210 – Central office – switching o Account 2211 – Non-digital switching o Account 2212 – Digital electronic switchingo Account 2220 – Operator systemso Account 2230 – Central office – transmissiono Account 2231 – Radio systemso Account 2232 – Circuit equipment

The individual items of equipment purchases classifiable to the following account and in excess of $500 (including any direct and indirect costs described below):

o Account 2124 – General purpose computers Any other equipment or telecommunications plant assets not described above will be capitalized if the direct

and indirect costs of the item are in excess of $500. Direct and indirect costs include the following:

o Labor, engineering, materials and supplies, transportation costs, contract work, protection, privileges, permits, and rights of way, taxes, special machine service, allowance for funds used during construction, insurance, construction services and indirect construction costs

Any non-regulated equipment will be capitalized if the direct and indirect costs of the item are in excess of $500.

Repairs and Maintenance and Exceptions to Capitalization Policies Described Above

The following guidelines further clarify items that are to be classified as repairs and maintenance within the accounting records and clarifies exceptions to the capitalization policies described above.

Support and maintenance agreements for equipment and other services will be expensed pro ratably over the term of the services to be provided in accordance with the agreement.

Expenditures in the nature of repairs or other maintenance will be expensed. Installations at a customer’s premise are expensed.

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Storage Policy at Charley’sWhen a customer brings a vehicle or piece of equipment in to Charley’s to be worked on, the customer has 30 days from the day the bill is made out for the service, to come and pick up their vehicle/equipment. If that customer fails to remove their vehicle/equipment from the premises, he or she will be charged $5 for each day it remains. This will all need to be paid in full before the vehicle leaves the lot. (6/10/14)

KTCI Provided Utility Outage PolicyAn outage of a utility of one or more customers that KTCI provides, which would include CATV, wireline telephone, Internet, or special access, that extends beyond an hour in length from the time reported or identified the technician working on the outage shall notify the following people by phone Rod Bowar, Matt Collins, Trusty Mertens, and Jason Thiry. Additionally Chris Zirpel will be notified by email. At the conclusion of the outage the same notification procedure shall happen as above. (9/4/14)

Policy for Obtaining Telco Use Items

Employees must prepare an inventory checkout sheet with the item(s) they need, with account numbers for items to be expensed to, and before presenting it to the purchasing Co. Coordinator, this form must be signed by a manager/supervisor. The purchasing Co. Coordinator will assign a telco WO# to the item(s) and is responsible to do the work report associated with these telco items.

This procedure is for Telco use Items only. All other inventory requests require a different procedure (which remains the same as it always has been). It is not the purchasing Co. coordinator’s responsibility to complete the work reports for these other “non-telco” use items. (11/25/14)

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Return Policy at Chamberlain NAPA

Items purchased must be brought back with a receipt. Customer will receive the original purchase amount for the item but must be brought back within 30 days.

Special orders customers will be billed & must pay for items when ordered (unless it is a shop or customer has an established account) if they return the item the customer will be billed a re-stocking charge of 15% but they must be brought back within 30 days and have receipt if they do not have receipt we will not take back.

Anything item brought back without a receipt the customer will only be paid back the cost of that Item and must be returned within 30 days.

Anything brought back from another store without receipt will not be taken back, if they have a receipt they will receive the cost of the item back. (10/14/14)

No Hold Policy for Customer Checks

Kennebec Telephone Co., Inc. and all its divisions will not hold checks. Customer payments will be made when the customer has the money. Customer will not receive parts or services until they have a valid check or means of payment for the purchase. (7-22-15)

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Kennebec Telephone Company, Inc. Overhead Allocation Policy(1/27/15)

The Board of Directors hereby adopts the following policy for its allocation of overhead expenses amongst regulated and non-regulated activities:

As soon as is reasonably practicable following the end of each calendar year, the Company shall adopt a formula for the allocation of certain Company overhead expenses between identified regulated and unregulated activities for the coming year. Such formula shall provide for the allocation of the selected overhead expenses amongst identified regulated and unregulated activities based upon the respective totals of the Company’s total revenues in the identified regulated and unregulated activities in the preceding year. When calculating the formula for the allocation of overhead expenses to regulated unregulated revenue categories, the Company shall take into account any unusual or unique events and circumstances which are unlikely to re-occur and which would unduly skew the allocation of expenses in the upcoming year. Following the calculation and approval of such allocation formula, all overhead expenses incurred by the Company in the subsequent year shall be allocated to the regulated and unregulated activities in accordance with such formula.

The overhead expense accounts from which expenses will be allocated are identified on Exhibit A attached hereto and incorporated herein by this reference.

The regulated and unregulated revenue accounts on which the overhead expense allocation ratio will be based are identified on Exhibit B attached hereto and incorporated herein by this reference.

The expense account to which the overhead expenses will be allocated and the percentage of the total which will be allocated to each account are as set forth on Exhibit C attached hereto and incorporated herein by this reference.

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Exhibit A

Account #6121.100 Building & Grounds Repair - Office6121.200 Bldg & Grounds repair - Shop6121.500 Building & Grounds Repair - Warehouse6121.600 Building & Grounds repair 202 S Main6121.700 Bldg & Grounds repair - Presho Shop6121.800 Bldg & Grounds repair - Radio Tower6123.000 Office Equip Expense - Telephone, Radios6561.000 Depr. Expense6613.100 Advertising - Newsletter6623.000 Collections & Customer Service Bills6711.000 Exec Mgr Exp - Admin, Mail, Secretarial6712.000 Planning6720.000 GENERAL AND ADMINISTRATIVE EXPENSE6721.000 Acct Exp-General, Time Sheets, PR, Disb6723.000 Human resources General Emplly Services6728.100 Sick Leave6728.300 Other Expense - Audit & Finance

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Exhibit B

Account #  6121.100 Building & Grounds Repair - Office6121.200 Bldg & Grounds repair - Shop6121.500 Building & Grounds Repair - Warehouse6121.600 Building & Grounds repair 202 S Main6121.700 Bldg & Grounds repair - Presho Shop6121.800 Bldg & Grounds repair - Radio Tower6123.000 Office Equip Expense - Telephone, Radios6561.000 Depr. Expense 6613.100 Advertising - Newsletter6623.000 Collections & Customer Service Bills6711.000 Exec Mgr Exp - Admin, Mail, Secretarial6712.000 Planning6720.000 GENERAL AND ADMINISTRATIVE EXPENSE6721.000 Acct Exp-General, Time Sheets, PR, Disb6723.000 Human resources General Emplly Services6728.100 Sick Leave6728.300 Other Expense - Audit & Finance

Account #  7997.100 Rental Property Expense - Non-reg7360.101 SDN Other Allocation7980.701 R Cell Phones allocation7983.700 Infinera - Presho Allocation7984.701 KTC GARAGE Allocation 7985.701 TCS allocation7986.701 TCS Security Allocation7987.701 NAPA Chamberlain (annualized)7990.300 Lease Equipment Allocation7991.700 PowerCom allocation7992.113 Internet - DSL Allocation7992.700 Computer Allocation7995.700 CATV-Allocation7996.300 KT CONSTRUCTION Allocation7998.300 DWDM Allocation7999.010 SDN Lease Allocation

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Exhibit C

Account #  % of 2013

Revenue Total7997.100 Rental Property Expense - Non-reg 0.59%7360.101 SDN Other Allocation 1.17%7980.701 R Cell Phones allocation 1.15%7983.700 Infinera - Presho Allocation 4.39%7984.701 KTC GARAGE Allocation 15.80%7985.701 TCS allocation 2.43%7986.701 TCS Security Allocation 2.04%7987.701 NAPA Chamberlain (annualized) 17.18%7990.300 Lease Equipment Allocation 0.51%7991.700 PowerCom allocation 13.00%7992.113 Internet - DSL Allocation 4.97%7992.700 Computer Allocation 2.67%7995.700 CATV-Allocation 3.62%7996.300 KT CONSTRUCTION Allocation 27.63%7998.300 DWDM Allocation 2.67%7999.010 SDN Lease Allocation 0.18%

100.00%

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Credit Card Policy

Credit card purchases can only be made for amounts over $10. When customers want to use their credit cards for under this amount it is our responsibility to tell them that it must be a cash or check transaction or they must increase the amount of their purchase. When taking credit cards, either in person or over the phone, you must make sure that you enter all the information the credit card machine asks for. This may include the CVV Code on the back of the card, the expiration date, the zip code, etc. Entering this information not only helps determine fraud, it also helps reduce credit card processing fees. When the card is present and it is an unfamiliar customer, ask for an ID to verify the name or verify the signature on the back of the card. (4-29-15)

Cell Phone Return/Repair/Replacement Policy

To ensure the privacy of our cell phone customers, it is our policy to do a factory reset on their cell phones when a phone is sent in for repair, when a loaner is returned, or for any other similar situations. In certain situations there is a need to back up our customer’s information by taking it off of the phone and storing it. We store their cell phone information so that it is not passed on to another person, and give back the information to the rightful owner with the return of a phone. It is important that we inform the customer that there is a need to do this and that there is a chance that some or all of their information could be lost in this process. This is strictly done to protect their privacy usually in the event of having to send it in for repair or replacement. Also, when we loan out a phone we want to make sure it is clean by doing a factory reset and when the phone is returned back to us, we want to do another factory reset to make sure it is clean again. In all cases a company representative must inspect the phone to ensure the factory reset cleared all information off the phone. This assures that all our loaned out phones don’t carry any information to the wrong person. (5/22/2015)

Policy for payment regarding trailer sales

It is Kennebec Telephone Co., Inc.’s policy to receive payment in full for a trailer when it is picked up. If a customer is paying with a check, they will have to wait to receive the paperwork after the check clears. Absolutely no credit card payment will be acceptable unless, prior arrangements have been made. When a customer puts an order in for a trailer, he/she must pay a nonrefundable deposit of $500. Every trailer sale

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must make at least a $500 profit margin; unless passed by management. Any other special circumstances for the sale of a trailer must also be approved by management. (7/1/2015)

KTCI’s Copyright Infringement Policy(6/1/2016)

Copyright infringement most commonly involves the possession, downloading, or sharing of electronic copies of music, movies, or videos without the permission or approval of the copyright holder. To protect their interests, copyright holders frequently monitor websites and other popular download locations to record the title, date, time, and Internet Protocol (IP) address associated with infringing activity.

It is the policy of our company to discourage the use of its network and services, to download materials in violation of copyright, trademark or other intellectual property laws.

Based on the IP address involved, the copyright holder determines the Internet Service Provider (ISP) that manages the IP address and sends them a notice describing the event. When we receive such notices, we determine what customer was assigned the IP address at the date (s) and time (s) listed in the notice (s). We only track IP address assignment and not how or where the IP address is used. We do not monitor or track customer activity on the internet.

If we are able to identify a customer with the IP address, we will contact the customer so they are aware of the allegation (s) of copyright infringement and to provide them with an opportunity to prevent the activity or remove the material. We do not release a customer’s identity to the copyright holder unless we are required to do so by a court order or subpoena.

If we receive repeated copyright infringement notifications for the customer over a period of time, we will escalate our response to ensure the customer is aware of the situation and to provide suggestions that may help resolve the problem. If we continue to receive copyright infringement notifications against the customer, we will take appropriate action, which could include, but not limited to, reducing the customer’s bandwidth, or suspending or terminating their internet service.

If the customer feels a mistake has been made or that the copyright for the material mentioned is not being infringed upon, they may file a counter-notification with the copyright holder or work with them directly.

Customers may wish to seek legal advice from an attorney if they receive a copyright infringement notice.

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Policy Book Receipt Page

Name (print)____________________________________________, an employee of Kennebec Telephone Co., Inc., hereby states he/she has received and read Kennebec Telephone Co., Inc., Policy book and fully understand the policies within it.

Signature__________________________________________

Date_____/______/______

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