ROCKFORD COVID-19 PREPAREDNESS AND RESPONSE PLAN Updated: May 20, 2020

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ....................................................................................................................................... 3

TRAINING AND COMMUNICATION ..................................................................................................................... 4

HYGIENE PROTOCOL .......................................................................................................................................... 5

CLEANING REQUIREMENTS ................................................................................................................................ 6

SITE ACCESS ....................................................................................................................................................... 7

OFFICE ............................................................................................................................................................................ 7

JOBSITE .......................................................................................................................................................................... 7

TENANT .......................................................................................................................................................................... 7

SOCIAL DISTANCING ........................................................................................................................................... 8

PERSONAL PROTECTIVE EQUIPMENT (PPE) REQUIREMENTS ............................................................................... 9

COVID-19 INCIDENT PROCEDURES ..................................................................................................................... 10

JOBSITE OR OFFICE COVID RESPONSE PLAN ....................................................................................................... 11

CONFIDENTIALITY ........................................................................................................................................................ 11

COVID-19 DISCLAIMER & PERSONAL ACCOUNTABILITY: ..................................................................................... 12

REPORTING .................................................................................................................................................................. 12

ADDITIONAL RESOURCES .................................................................................................................................. 13

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EXECUTIVE SUMMARY

At Rockford, nothing is more important than the safety of our team, our trade contractors, and the communities we serve. The COVID-19 pandemic requires safety measures that go above and beyond our normal safety operations. The ROCKFORD COVID HEALTH AND SAFETY HANDBOOK outlines procedures and protocols that will prevent the spread of COVID on our jobsites and in our offices and allow all of you to continue working in a safe and healthy environment. Rockford’s COVID procedures are based on the most recent guidelines from the Center for Disease Control (CDC), OSHA, and state and federal regulations related to COVID-19. As such, this is a living document that will change and adapt to new guidelines and legislation. As a result, you must ensure that you are referencing the most recent Handbook issuance. In addition to Rockford’s requirements as outlined in this handbook, there may be additional COVID requirements based on client demands, site-specific logistics, and other factors. ALL Rockford stakeholders must comply with the requirements outlined in this document in addition to project- and site-specific requirements related to COVID-19. In addition to your jobsite supervisor, Rockford’s dedicated safety team is available to assist you with questions. We thank you for your diligent efforts in complying with this handbook, for the health of you and those around you. Together, we can all continue to work safely. Mike VanGessel, CEO

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TRAINING AND COMMUNICATION

Rockford will provide tools and training necessary to prevent the spread of COVID-19 on its jobsites and in its corporate offices. We have implemented the following:

1. Rockford COVID Health and Safety Handbook will be updated regularly and communicated to our team members, trade partners, clients and stakeholder.

2. Changes to CDC, OSHA, federal, state or local guidelines, as well as updates to the Rockford COVID Handbook, will be communicated during jobsite meetings for field personnel or via email for corporate office workers.

3. Jobsite signage will include: a. Symptoms of COVID-19 b. Proper hygiene and protocol c. PPE requirements

4. Personnel new to the jobsite must review the Rockford Code of Conduct and

COVID-19 protocol before beginning work.

5. Each trade contractor must designate a site representative (competent person) to review, monitor and implement all COVID-19 safety practices for its employees.

6. A JHA must be completed daily by all trade contractors prior to the start of work. All trade contractor site representatives must complete a Trade Contractor Employee COVID-19 Health Assessment Form a sign-in form with information regarding their employees’ health and potential COVID exposure. This form may also be submitted electronically via PlanGrid.

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HYGIENE PROTOCOL

Appropriate hygiene is one of the best ways to prevent the spread of COVID-19. All personnel working on Rockford jobsites, in our corporate offices, or in our properties are required to do the following:

1. Frequent handwashing/sanitizing a. Wash hands with soap and water for a minimum of 20 seconds. OR b. Use hand sanitizer with a minimum 60% alcohol content. c. Rockford’s jobsites, offices and properties will provide handwash stations

and/or hand sanitizer.

2. Cover coughs and sneezes in a sleeve, elbow or tissue

3. Avoid touching your eyes, nose, mouth or face. If you do, wash hands immediately.

4. Do not shake hands.

5. Do not share food, utensils, phones, electronics, equipment or workspaces. Use

water bottles and personal beverages in lieu of water coolers, coffee pots, etc.

6. If you must share equipment or work surfaces, please wipe with sanitizing wipes before and after use.

7. Dispose of all personal items including food, utensils, tissues, etc. promptly and

in the appropriate containers.

8. If you are feeling sick, leave work immediately and contact your supervisor and healthcare provider for further instructions.

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CLEANING REQUIREMENTS

1. Common surfaces on jobsites, corporate offices, and properties, including

tables, restrooms, kitchen areas, break rooms, portable toilets, handrails and doorknobs must be cleaned frequently.

2. All jobsite and office personnel must use disinfecting wipes or cleaning products to sanitize equipment and worksurfaces before and after use.

3. Use disinfectants that are recognized by the EPA as effective against SARS-

CoV-2, including Clorox wipes or alcohol wipes.

4. Rockford will work to increase ventilation within its enclosed jobsites, corporate offices and properties to the greatest extent possible.

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SITE ACCESS OFFICE

1. Only essential visitors as determined by Rockford leadership and mail deliveries will be permitted in Rockford’s offices.

2. Visitor sign in will be required at all offices, with questions related to health and COVID exposure. Visitors may be denied access based on responses.

3. Until further notice, the ROC (Rockford Office Commons) will remain closed to external meetings or events.

JOBSITE

1. Only critical deliveries or visitors will be permitted on site by Rockford. These personnel will be asked to comply with COVID procedures.

2. Delivery process must minimize contact/exposure. If at all possible, delivery personnel should remain inside their vehicle.

3. Personnel and visitor sign in will be required at all jobsites, with questions related to health and COVID exposure. Personnel or visitors may be denied access based on responses.

4. Temperature checks will be required at all Rockford jobsites and corporate offices.

5. For occupied renovations, provide temporary walls or partitions to separate construction workers from other building residents whenever possible.

TENANT

1. Rockford property maintenance technicians may only enter tenant spaces for the purposes of urgent repairs or maintenance. Rockford Property Management must confirm that the tenant has not been exposed or quarantined for COVID-19 prior to the maintenance technician entering the space.

2. Tenant showings will be by appointment only. Rockford Property Management must confirm that the potential tenant has not been exposed or quarantined for COVID-19 prior to the maintenance technician entering the space.

3. Full PPE as outlined in this document must be worn and social distancing must be observed at all times.

4. In general, shared tenant spaces, including fitness rooms, community rooms and roof decks will be closed for use until the State of Michigan Stay at Home order is lifted. However, based on layout and property, some community rooms and roof decks may remain open with restrictions, including enforcement of social distancing practices.

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SOCIAL DISTANCING

1. Maintain at least 6 feet of distance between yourself and others whenever possible.

2. Use technology and virtual capabilities to avoid face to face meetings.

3. Jobsite meetings must occur outside to allow for social distancing.

4. Corporate office meetings must occur in spaces large enough to accommodate social distancing and limited to number of attendees per state regulations (currently 10 people in Michigan).

5. Lunch breaks will be staggered to accommodate social distancing. Do not

gather for lunch or other breaks. Corporate office team members should eat at their workstations.

6. Each jobsite will attempt to stagger work tasks to comply with social

distancing.

7. Directional arrows and signage will be used to avoid bottlenecks at site entrances, stairways and other common locations. Rockford may also designate work teams and limit access to work areas to minimize exposure to other personnel.

8. Limit elevator use to material handling, if possible.

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PERSONAL PROTECTIVE EQUIPMENT (PPE) REQUIREMENTS

In addition to OSHA-required PPE, all jobsite personnel must adhere to the following COVID-19 requirements:

1. Do not share PPE.

2. The use of FACE COVERINGS is mandatory if a worker cannot consistently maintain 6 feet of separation from other workers, whether on Rockford jobsites, in our offices or in our managed properties. If a worker is able to maintain 6 feet of distance from others consistently, face coverings are not required unless one of the following applies:

a. Rockford Property Management’s maintenance technicians are required to wear face masks or coverings in all occupied spaces and common areas of our managed properties. Masks are not required in vacant tenant spaces, unless workers cannot consistently maintain the required 6 feet of social distancing. In addition to the PPE outlined in this section, Rockford’s maintenance team is required to wear protective booties when working in occupied tenant spaces.

b. Team members and cleaning companies that are performing cleaning or food or beverage preparation will be asked to wear masks and gloves when performing those responsibilities.

3. In order to preserve N95 and other medical grade masks for healthcare

providers, cloth masks are preferred, unless OSHA guidelines dictate a different face covering for the task being performed. Follow CDC guidelines and instructions for face masks. Masks should be cleaned or replaced frequently, but at a minimum, on a daily basis.

4. The use of gloves during construction for preventing the spread of COVID-19 is discretionary, but not mandatory, for Rockford team members and trade contractors (please note that gloves should still be used during touchpoint cleaning). It is important to adhere to OSHA requirements for PPE; therefore, gloves required for a specific task should still be used. If not required by normal OSHA guidelines, then any type of glove is acceptable, including latex gloves. Gloves should be cleaned frequently and according to manufacturer guidelines or disposed of and replaced frequently.

5. Masks and gloves should be cleaned daily.

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COVID-19 INCIDENT PROCEDURES

1. COVID-19 Symptoms

If a worker exhibits symptoms of COVID-19, including fever, cough, shortness of breath or difficulty breathing, he/she must leave work immediately, notify the Rockford supervisor, and follow CDC guidelines regarding monitoring and treatment. Return to work requirements - If a worker has experienced COVID-19 or other symptoms, but has not tested positive, he/she may return to work once:

• he/she is symptom free for 72 hours (3 full days) without the use of fever-reducing or other symptom-altering medicines (e.g., cough suppressants) and for at least ten days after their symptoms first appeared;

• OR until after they no longer have symptoms and receive negative COVID-19 tests using at least two consecutive respiratory specimens collected more than 24 hours apart.

2. COVID-19 Exposure

If a worker has come in close contact (within six feet for a prolonged period of time) with an individual who has tested positive or shows symptoms of COVID-19, he/she must leave work immediately and notify the Rockford supervisor. Return to work requirements - If a worker has come in close contact with an individual who has tested positive for COVID-19:

• he/she must self-quarantine for 14 days from the last date of contact with the infected individual and remain symptom-free;

• OR the person who tested positive or displayed symptoms receives a negative COVID-19 test.

3. COVID-19 Confirmed If a worker has tested positive for COVID-19, he/she must leave work immediately, self-quarantine, and notify the Rockford supervisor. Return to work requirements - A worker who has tested positive for COVID-19 may return to work:

• after he or she is symptom free for 72 hours (3 full days) and ten days have passed since their symptoms first appeared or since they were swabbed for the test yielding a positive result;

• OR after their symptoms clear and they receive negative COVID-19 tests using at least two consecutive respiratory specimens collected more than 24 hours apart.

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JOBSITE OR OFFICE COVID RESPONSE PLAN

If a worker on one of Rockford’s jobsites or offices has tested positive for COVID-19, Rockford will immediately do the following:

1. Determine where the worker was located to identify other workers, he/she may have come in close contact with (within 6 feet over a prolonged period of time) during the prior 14 days.

2. Communicate COVID exposure to those workers and direct them to self-quarantine for 14 days from the last date of contact.

3. Rockford will shut down the area of jobsite or office where the worker was

located to perform appropriate cleaning.

4. Rockford will notify the appropriate authorities.

5. If a confirmed COVID-19 case is reported on a Rockford jobsite, Rockford’s Safety team will engage to determine if the case meets recordable/reportable OSHA guidelines and will communicate to the appropriate trade contractor to facilitate reporting.

CONFIDENTIALITY

Rockford will do its best to keep the identity of an individual diagnosed with COVID-19 confidential, unless legally required to disclose his/her identity by law. Medical information should remain private, and this approach will encourage those with symptoms, exposure or who test positive to communicate proactively. Rockford reserves the right to inform its team members, trade contractors, suppliers and other stakeholders that an unnamed worker has tested positive so that individuals who were in close contact can take measures to monitor and protect their own health, and the health of those around them.

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COVID-19 DISCLAIMER & PERSONAL ACCOUNTABILITY:

Rockford strives to operate and conduct its activities in a manner consistent with and in compliance with the most up-to-date laws, guidelines, and regulations regarding COVID-19. In preparing these materials, we used the current CDC guidelines, OSHA and MIOSHA regulations, and federal, state and local legislation in the effect at the time. These laws, guidelines and regulations continue to evolve as more is learned about COVID-19. As a result, the protocols in these materials are not exhaustive in nature and subject to change. These protocols do not supersede or otherwise replace each person’s own personal responsibility and diligence to comply with federal, state and local laws, guidelines and regulations to prevent the spread of COVID-19. We strongly urge all persons to carefully review and strictly follow these protocols as well as all applicable laws, guidelines and regulations. Any discrepancies in Rockford’s materials should be brought to the immediate attention of Rockford’s Safety Team.

Thank you for doing your part to keep yourself and those around you safe and healthy during COVID-19.

REPORTING

If you believe work conditions are unsafe based on local, state or Federal COVID-19 regulations, please contact our Grand Rapids office at 616-285-6933 or the following Rockford representatives:

• If you are a client, trade contractor, A/E or local authority - contact Director of Safety, Paul Rozich at prozich@rockfordconstruction.com.

• If you are a Rockford team member - contact Human Resources Director Jessi Sterk at jsterk@rockfordconstruction.com.

• If you are a Rockford tenant – contact Executive Vice President of Real Estate Development and Property Management, Monica Steimle-App at msteimleapp@rockfordconstruction.com.

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ADDITIONAL RESOURCES

Center for Disease Control (CDC) www.cdc.gov/coronavirus Occupational Safety and Health Administration (OSHA) www.osha.gov/SLTC/covid-19 State of Michigan www.michigan.gov/coronavirus State of Florida www.flgov.com/covid-19 State of Illinois www.coronavirus.illinois.gov State of Indiana www.coronavirus.in.gov State of Ohio www.coronavirus.ohio.gov State of Wisconsin www.wisconsin.gov/covid-19