Effective Date: October 15, 2026 Version: 1.0 Applies to: All Company employees.
Article 1: Introduction and Scope
1.1 This document states the duties that attach to the records of the business: what a record is, how a record is made and corrected, how long records are kept, who may see them, and how the Company audits them. Records are the evidence on which pay is calculated, disputes are decided, incidents are answered, and the Company's obligations to regulators are met; a duty in this document is therefore a duty of substance, not of form.
1.2 This document governs every record an Employee creates, changes, or holds in a Company System or on Company premises, including time entries, appointment and status records, notes, photographs, payment and refund records, incident reports, and personnel records. Retention periods are stated in the Regulatory Record Retention, which this document applies and does not restate.
1.3 If a provision of this document conflicts with the Terms of Use, this document controls for the subject it governs. If a provision conflicts with the terms of a program in which the Employee participates, the program terms control for that program. Help pages explain this document; they do not amend it.
Article 2: Definitions
2.1 The definitions in the Employee Code of Conduct are incorporated into this document by reference. This article defines only the additional terms used in this document, in alphabetical order.
2.2 Audit Log: the record a Company System makes of acts taken in it, identifying the person who acted, the act, and the time, including grants of access, sign-ins, and changes to records.
2.3 Business Record: a record created or received in the course of the Company's business, in any form, that evidences an act, a transaction, a decision, or an event, including a time entry, a status history, a note, and an Incident Record as defined in the Incident Response Policy.
2.4 Correction: a change to a Business Record made under Article 4, recorded as a correction, that leaves the original entry and the correction both visible.
Article 3: Making Records
3.1 The Employee shall make each Business Record the Employee's duties require at the time of the act or event the record describes, completely and accurately. A record shall state facts: what occurred, what the Employee observed, and what the Employee did, with the time stated where the time matters. A record made from memory at a later time, where the Employee could have made the record at the time, does not satisfy this duty and is identified as reconstructed where the System provides for that identification.
3.2 Time entries are Business Records. The Employee's duties for time entries are stated in the Employee Code of Conduct: the Employee records the Employee's own time, at the time, and reports an error to the Manager rather than repairing the record personally. Manager corrections to time entries are Corrections under Article 4.
3.3 The Employee shall create and keep Business Records only in the Company Systems designated for them. A Business Record kept in a personal account, a personal application, or a personal notebook is a record outside the Company's custody: the Employee shall transfer such a record into the designated System promptly and shall not rely on the personal copy as the record of the business.
3.4 A Business Record is Company Property. No Employee acquires a personal right in a Business Record by creating it, and no Employee may remove, copy, or retain a Business Record except as the Employee's duties require and the Confidentiality and Non-Disclosure Policy permits.
Article 4: Corrections and the Prohibition on Alteration
4.1 A Business Record, once made, is not edited in place, deleted, overwritten, or backdated. Status histories, time entries, Audit Logs, and Incident Records are preserved as made: each later statement about the same act or event is added as a new entry or as a Correction, so that the sequence of what was recorded, and when, remains visible. This preservation is the reason a contemporaneous entry carries weight in a dispute and a reconstructed entry is identified as such.
4.2 Where a Business Record is wrong, the person authorized to correct that class of record shall make a Correction that states what was wrong, what the correct fact is, the reason for the Correction, and the identity of the person making it. A time entry is corrected by the Manager. An appointment or status record is corrected by a person whose Grant permits the correction. No Employee corrects the Employee's own record of the Employee's own act where another person is designated to make the Correction.
4.3 The Employee shall not falsify a Business Record, direct another person to falsify one, conceal a record that a duty requires, or destroy a record the Employee knows relates to an open dispute, claim, incident, investigation, or legal demand. On notice of such a matter, the Employee shall preserve every record that relates to it, in accordance with the direction given by the Company through legal@aapawz.com where legal process is involved.
Article 5: Retention, Access, and Disposal
5.1 Business Records are retained for the periods stated in the Regulatory Record Retention, by record class. Where that document states a period, no Employee shall destroy a record of that class before the period ends, and no Employee shall retain a personal copy after the period ends except as that document permits. Where a record is subject to a preservation duty under Article 4, the preservation duty prevails over the retention period until the Company releases it in writing.
5.2 Access to Business Records is governed by the Data Access and Least Privilege Policy: a record is available to the Employees whose Grants and duties require it, and to no others. Personnel records are available only as the Confidentiality and Non-Disclosure Policy provides; the shared surface of an Employee's own record is the employee portal, and the remainder is held on the manager side.
5.3 Disposal of a Business Record at the end of its retention period is an act of the Company, performed by the role the Regulatory Record Retention designates and recorded in the manner that document states. An Employee shall not destroy a Business Record on the Employee's own decision, in any medium, including paper records, which the Employee shall deliver for disposal through the location's process rather than discard.
Article 6: Audit
6.1 The Company may audit Business Records and Audit Logs at any time, without notice, for accuracy, for compliance with this document and the documents it supports, and in response to a dispute, an incident, or a regulatory requirement. An audit may examine time entries against schedules, payment and refund records against Grants, exports against the tasks they served, and corrections against the reasons recorded for them.
6.2 The Employee shall cooperate with an audit, shall produce the records the Employee holds, shall answer questions about the Employee's own entries truthfully, and shall not alter, complete, or reconstruct a record after an audit of that record has begun. A record altered after notice of an audit is treated as falsified for the purposes of Article 8.
6.3 The findings of an audit are recorded. Where an audit establishes an error made in good faith, the error is corrected under Article 4 and the correction closes the matter unless the pattern of errors shows a failure of the duty in Article 3. Where an audit establishes a falsified record, a concealed record, or access or an export no duty supported, the matter is enforced under Article 8 and, where it involves misconduct, reported under the Whistleblower and Internal Reporting Policy.
Article 7: Liability
7.1 The Employee is responsible for the Employee's own conduct and shall bear the loss that the Employee's violation of this document causes, to the extent permitted by applicable law. Nothing in this document makes the Company responsible for a loss caused by an act taken in violation of this document or outside the scope of employment.
7.2 To the fullest extent permitted by law, neither party is liable to the other for indirect, incidental, special, punitive, or consequential damages, or for lost profits, lost revenue, or loss of goodwill, arising out of or relating to this document, even if the party has been advised of the possibility of those damages.
7.3 To the fullest extent permitted by law, the Company's total liability arising out of or relating to this document shall not exceed one hundred dollars ($100). This clause does not limit (a) wages, commissions, benefits, or other compensation owed under applicable law or a written agreement, including compensation that depends on a record governed by this document; (b) indemnification obligations under this document; (c) liability for fraud or willful misconduct; or (d) liability that cannot be limited under applicable law.
7.4 The parties agree that this article allocates risk between them, that it is an essential part of the basis of their bargain, and that it applies even if a limited remedy fails of its essential purpose.
Article 8: Indemnification
8.1 The Company shall indemnify, defend, and hold harmless the Employee from and against a claim, loss, liability, judgment, settlement, cost, and expense (including reasonable attorneys' fees) brought by a third party and arising out of an act the Employee took within the scope of employment and in compliance with this document and applicable law.
8.2 The Company does not indemnify an Employee for the Employee's own unlawful acts. No indemnification is owed under this article for a claim arising out of (a) the Employee's willful misconduct or fraud, including the falsification of a record; (b) an act outside the scope of employment; or (c) an act taken in violation of this document.
8.3 The Employee shall indemnify, defend, and hold harmless the Company and its members, managers, employees, and agents from and against every claim, loss, liability, judgment, settlement, cost, and expense (including reasonable attorneys' fees) arising out of (a) the Employee's breach of this document; (b) the Employee's violation of any law or of the rights of any person; and (c) an act outside the scope of employment.
8.4 The party seeking indemnification shall give prompt written notice of a claim under this article. The indemnifying party shall control the defense with counsel reasonably acceptable to the other party; the indemnified party may participate at its own expense. The indemnifying party shall not settle a claim in a manner that imposes an obligation on the other party, or that does not release the other party fully, without the other party's prior written consent. This article survives the end of employment.
Article 9: Enforcement and Appeals
9.1 The Company may investigate any suspected violation of this document, including by audit under Article 6. The Employee shall cooperate with an investigation and shall produce the records this document requires the Employee to keep.
9.2 If the Company determines that the Employee has violated this document, the Company shall give written notice stating the provision violated and the facts relied on, except where notice would compromise an investigation of fraud, a safety risk, or a legal obligation. The Employee may submit a written response within ten (10) business days, and the person deciding the matter shall consider the response before a measure is imposed. Where a violation is capable of cure, the Employee has ten (10) business days from notice to cure it and to confirm the cure in writing; no cure period applies to fraud, falsification, destruction of a record, or a violation that cannot be cured.
9.3 If a violation is established, the Company may, proportionate to the violation: (a) issue a written warning; (b) require retraining; (c) restrict or withdraw access or a Grant; (d) place the Employee on a written improvement plan; (e) suspend the Employee's employment; (f) terminate the Employee's employment; and (g) exercise any other right or remedy available at law. Falsification of a record, and destruction of a record subject to a preservation duty, are serious violations for the purposes of this article.
9.4 The Employee may appeal a measure under this article by written notice to the Employee's Manager within thirty (30) days of the measure, stating the grounds and attaching the records relied on. Where the measure arises out of a preservation duty or a legal demand, the appeal is made in writing to legal@aapawz.com. Where the Manager made the decision appealed from, the appeal is made to the Manager's manager. The appeal is decided by a person who did not make the original decision, and the Company's decision on appeal is final. A measure remains in effect during an appeal unless the Company directs otherwise in writing.
9.5 No measure under this article may be imposed in retaliation for a report made in good faith under the Whistleblower and Internal Reporting Policy or for the exercise of a right protected by applicable law. The Company's delay in acting on a violation is not a waiver of the violation or of any later violation of the same kind.
Article 10: Term and Termination
10.1 This document applies from the commencement of employment until the employment ends for any reason. Records an Employee created during employment remain Business Records after the employment ends, and the duties not to alter, delete, or disclose them continue as the Confidentiality and Non-Disclosure Policy states.
10.2 On the end of employment, Articles 7, 8, 9 (for measures taken before the employment ended), 11, and 12 survive, and retention of the records continues under Article 5. The end of employment and of access is governed by the Termination and Offboarding Policy.
Article 11: Dispute Resolution
11.1 Any dispute arising out of or relating to this document, or to the relationship it governs, is governed by the Dispute Resolution Policy, which is incorporated into this document by reference.
11.2 Nothing in this document limits an Employee's right to file a charge or complaint with a government agency, to participate in an agency proceeding, or to engage in concerted activity protected by applicable law, and no provision of this document requires the Employee to give notice of, or to obtain consent to, the exercise of such a right.
Article 12: General Provisions
12.1 The Company may amend this document by posting the amended document in the Document Center and giving notice to the Employee at the email address in the Employee's employment record. An amendment that materially increases the Employee's obligations takes effect thirty (30) days after notice; other amendments take effect on posting.
12.2 Legal notices under this document shall be sent to legal@aapawz.com; operational notices and all other communications shall be sent to support@aapawz.com. A notice to the Company is effective when the Company acknowledges receipt or, for email, one business day after sending, whichever is earlier. Notices to the Employee are effective when sent to the email address in the Employee's employment record or posted in the employee portal, whichever occurs first. The Employee shall keep that email address current. Notices under the DMCA and Copyright Policy are given as provided in that policy, to the designated agent at legal@aapawz.com.
12.3 This document is governed by the laws of the State of Tennessee, without regard to its conflict-of-laws rules. Subject to the Dispute Resolution Policy, any proceeding arising out of this document shall be brought in the state or federal courts located in Shelby County, Tennessee, and the parties consent to personal jurisdiction there.
12.4 If any provision of this document is held unenforceable, the provision shall be enforced to the fullest extent permitted, and the remaining provisions continue in full effect.
12.5 This document, together with the documents it incorporates by reference, is the entire agreement between the Company and the Employee for the subject it governs and supersedes every prior statement or agreement on that subject. This clause does not supersede an offer letter or a written employment agreement signed by the Company.
12.6 The Employee shall not assign this document or any right or obligation under it, and an assignment without the Company's prior written consent is void. The Company may assign this document to an affiliate or in connection with a sale of all or part of its business, on notice to the Employee. A waiver of any provision of this document is effective only in writing and only for the instance stated; no waiver is a waiver of any other provision or instance.
12.7 Headings are for convenience only. "Including" means "including without limitation." This document shall not be construed against a party on the ground that the party prepared this document. The English-language text controls over any translation.
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