Bargreen Ellingson, Inc.
Privacy and Electronic Monitoring Policy
All U.S. and Canadian Locations — Effective 10/1/2026
Bargreen Ellingson (“BE” or the “Company”) provides equipment, systems, and vehicles to help employees do their jobs, and collects personal information to run its business and meet its legal obligations. This policy explains how BE monitors Company property and systems, the limits BE places on that monitoring, how BE handles employees' personal information, and the rights employees have.
1. Purpose and Scope
This policy applies to all employees, applicants, and contractors at every BE location in the United States and Canada. Some states and provinces have additional requirements. Those are addressed in state- and province-specific appendices to this Handbook, such as the California Appendix — Privacy and Electronic Monitoring Policy. Where an appendix provides greater protection for employees, the appendix controls for employees working in that state or province.
2. Privacy Expectations at Work
Employees should not expect privacy when using Company-issued devices, Company systems, or Company vehicles, or in work areas monitored by security cameras. The Company may monitor, access, and review these at any time, with or without notice. BE monitors only for legitimate business purposes — including security, safety, regulatory compliance, protection of Company property, and investigation of misconduct — and uses monitoring methods that are reasonable in scope for those purposes.
3. Areas Where Monitoring Is Prohibited
At all locations, BE will not record or monitor employees in the following areas:
• Restrooms, locker rooms, and rooms designated for changing clothes. No camera, audio recording device, or other monitoring device will be placed in these areas.
• Lactation spaces. Spaces provided for expressing breast milk will be shielded from view and free from intrusion, and will not contain cameras or other monitoring devices.
• Bathrooms — all surveillance tools. BE will not use any monitoring tool — including cameras, GPS or location trackers, handheld scanners, badges, time-tracking applications, or other devices or software that collect employee data — to monitor employees in a workplace bathroom.
Employees may leave Company-issued phones, scanners, tablets, and other devices outside the bathroom. A required identification or access badge that does not record audio or video may be carried, and a badge reader may record a one-time entry to or exit from a secured area. BE does not use these records to track how often or how long employees use the bathroom.
4. Video Surveillance
Some BE locations use security cameras in work areas, warehouses, entrances, loading docks, and parking areas for facility security, employee and customer safety, and incident investigation. BE security cameras record video only and do not record audio. Signage is posted at locations where security cameras are in use.
Access to recorded footage is limited to authorized management, Human Resources, IT, and security personnel, and to law enforcement or other parties when required by law. Footage is kept for up to 3 years, unless it is needed longer for an incident, claim, or investigation.
5. Audio Recording
Several states where BE operates require the consent of every person in a conversation before it may be recorded. To keep one standard across all locations, BE applies that rule companywide:
• BE does not record audio of employees without notice and consent.
• If BE records any telephone calls (for example, customer service or dispatch lines), callers and employees will be notified at the start of each call that the call may be recorded.
• No employee may record a conversation with a coworker, supervisor, customer, or vendor without the consent of everyone participating in the conversation.
6. GPS and Vehicle Tracking
Company vehicles subject to U.S. Department of Transportation (DOT) requirements are equipped with GPS tracking devices. Some Company-issued phones and handheld devices may also have location features enabled. BE uses location data for vehicle and driver safety, dispatch and routing, DOT compliance, asset protection, and incident investigation.
• BE tracks only Company-owned vehicles and devices. BE will not place a tracking device on, or enable location tracking for, an employee's personal vehicle or personal device without the employee's written consent.
• Location data collected during meal periods, rest breaks, or off-duty time will not be reviewed to monitor employees' personal activities. It may be accessed only for vehicle security, theft recovery, accident or safety investigation, or as required by law.
• Employees authorized to take a Company vehicle home should understand that the GPS device remains active. Off-duty location data is subject to the access limits above.
• GPS data is kept for up to 3 years, unless it is needed longer for an incident or investigation.
7. Company Systems, Email, Internet, and Voicemail
BE provides voicemail, email, phone systems, networks, applications, and internet access to help employees work efficiently. All messages, files, images, and data created, sent, received, or stored on Company systems are Company property and may be accessed or reviewed by the Company.
Company systems automatically collect information when employees use them, including login and logout times, IP addresses, session tokens, device identifiers, authentication logs, and records of email, internet, and system use. BE uses this information for information security, system administration, fraud prevention, enforcement of Company policies, and investigations.
• Access to this information is limited to authorized IT, Human Resources, and management personnel with a business need.
• System records and voicemail are kept for up to 3 years, unless needed longer for a security incident or investigation.
• BE will not use credentials saved on a Company device to access an employee's personal email, banking, social media, or other personal accounts.
• BE does not use monitoring tools that use artificial intelligence to infer or predict employees' emotional states, or that collect neural data.
• BE does not rely solely on automated decision systems to make discipline or termination decisions. A person reviews and is accountable for those decisions.
Employees are expected to use Company systems honestly and to respect copyrights, software licenses, property rights, and the privacy of others.