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i Intercoastal Mortgage, LLC 11325 Random Hills Rd Suite 600 Fairfax, Virginia 22030 Phone: (703) 449-6800 https://intercoastalmortgage.com/ Employee Handbook Issued: January 1, 2024

iI.  Introduction ................................................................................................................................................................... 1 About this Handbook ................................................................................................................................................ 1 II.  Employment with Intercoastal Mortgage, LLC ............................................................................................................. 2 Welcome .................................................................................................................................................................. 2 Our Goal ................................................................................................................................................................... 2 Our Mission .............................................................................................................................................................. 2 Our Core Values ........................................................................................................................................................ 2 Our Commitment to Diversity ................................................................................................................................... 2 Communicating with Our Employees ........................................................................................................................ 3 III.  Basic Employment Policies ........................................................................................................................................ 3 Equal Employment Opportunity Statement .............................................................................................................. 3 Reasonable Accommodation of Individuals with Disabilities ..................................................................................... 4 Reasonable Accommodation of Individuals’ Religious Beliefs and Practices .............................................................. 5 Pregnancy Disability Accommodation Policy ............................................................................................................. 5 Policy Against Harassment ........................................................................................................................................ 6 Harassment Defined ...................................................................................................................................................... 6 Sexual Harassment Defined .......................................................................................................................................... 6 Reporting Procedures .................................................................................................................................................... 7 Investigation Procedures ............................................................................................................................................... 7 No Retaliation ................................................................................................................................................................ 7 Whistleblower Protection Policy ............................................................................................................................... 8 Employee Dating Policy ............................................................................................................................................. 8 Drugs, Alcohol, and the Workplace ........................................................................................................................... 9 Consumption of Alcohol at Work and/or at Work-Related Events ............................................................................ 10 Minors and Alcohol ..................................................................................................................................................... 10 Workplace Violence Prevention .............................................................................................................................. 11 IV.  Working at Intercoastal Mortgage .......................................................................................................................... 11 Employee Classifications ......................................................................................................................................... 11 Personnel and Payroll Records ................................................................................................................................ 11 Promotions and Transfers ....................................................................................................................................... 12 Your Pay ................................................................................................................................................................. 12 Pay Transparency: Retaliation Prohibited ............................................................................................................... 12 Your Work Week .................................................................................................................................................... 12 Rest Breaks and Meal Periods – Non-Exempt Employees ........................................................................................ 13 Lactation Accommodation ...................................................................................................................................... 13 Overtime – Non-Exempt Employees ........................................................................................................................ 13 

ii Timekeeping - Non-Exempt Employees ................................................................................................................... 14 Timekeeping – Exempt Employees ............................................................................................................................. 14 Your Paycheck ........................................................................................................................................................ 14 Administrative Pay Correction Policy ...................................................................................................................... 14 Non-Exempt Employees – Pay Corrections ................................................................................................................. 14 Exempt Employees – Pay Corrections ......................................................................................................................... 14 V. Employee Benefits ....................................................................................................................................................... 15 Your Benefits Package ............................................................................................................................................ 15 Workers’ Compensation Insurance and Short-Term Disability Benefits ................................................................... 16 Leave Policies ......................................................................................................................................................... 16 Family and Medical Leave ........................................................................................................................................... 16 Eligibility Requirements .............................................................................................................................................. 16 Basic Leave Entitlement .............................................................................................................................................. 16 Military Family Leave .................................................................................................................................................. 17 Job Benefits and Protection ........................................................................................................................................ 17 Definition of Serious Health Condition ....................................................................................................................... 17 Use of Leave ................................................................................................................................................................. 18 Substitution of Paid Leave for Unpaid Leave .............................................................................................................. 18 Employee Responsibilities ........................................................................................................................................... 18 The Company’s Responsibilities .................................................................................................................................. 19 Unlawful Acts by Employers ........................................................................................................................................ 19 Enforcement ................................................................................................................................................................ 19 Vacation Leave ....................................................................................................................................................... 19 Eligibility ...................................................................................................................................................................... 19 Reasons for Use ........................................................................................................................................................... 19 Vacation Grant ............................................................................................................................................................. 19 Use and Scheduling of Vacation .................................................................................................................................. 20 Payment of Vacation ................................................................................................................................................... 20 Carryover of Vacation .................................................................................................................................................. 20 Vacation at Termination .............................................................................................................................................. 20 Sick Leave ............................................................................................................................................................... 20 Eligibility ...................................................................................................................................................................... 20 Reasons for Use ........................................................................................................................................................... 20 Sick Leave Grant .......................................................................................................................................................... 21 Use and Scheduling of Sick Leave ............................................................................................................................... 21 Payment of Sick Leave ................................................................................................................................................. 21

iii Carryover of Sick Leave ............................................................................................................................................... 21 Sick Leave at Termination ........................................................................................................................................... 21 Bereavement/Funeral ............................................................................................................................................. 22 Jury Duty ................................................................................................................................................................ 22 Holidays .................................................................................................................................................................. 22 School Visitation Leave ........................................................................................................................................... 22 Witness Duty Leave ................................................................................................................................................ 22 Crime Victim’s Leave ............................................................................................................................................... 23 Voting Time ............................................................................................................................................................ 23 Military Leave ......................................................................................................................................................... 23 Leave for Deployment of Family Member in the Armed Forces ................................................................................ 23 Organ or Bone Marrow Donor Leave .......................................................................................................................... 23 Benefits During Leave .................................................................................................................................................. 24 Return to Work ............................................................................................................................................................ 24 Disaster Relief Volunteer Leave .................................................................................................................................. 24 VI. Workplace Standards .............................................................................................................................................. 24 General Standards of Conduct ................................................................................................................................ 24 Attendance and Punctuality .................................................................................................................................... 25 Proper Call-In Procedure ............................................................................................................................................. 25 Job Abandonment ....................................................................................................................................................... 25 Excused Absences ........................................................................................................................................................ 25 Unexcused Absences ................................................................................................................................................... 26 Personal Appearance and Business Casual Guidelines ............................................................................................. 26 Business Casual Guidelines ......................................................................................................................................... 26 Social Media Policy ................................................................................................................................................. 26 Employee Network Usage Policy ............................................................................................................................. 27 Ownership of Information and No Expectation of Privacy ....................................................................................... 27 Appropriate and Inappropriate Use ........................................................................................................................ 28 Solicitation and Distribution ................................................................................................................................... 28 Searches of Company and Employee Property ........................................................................................................ 28 Non-Disclosure of Confidential Business Information .............................................................................................. 29 VII. Safety and Security .................................................................................................................................................. 29 Background Investigations ...................................................................................................................................... 29 General Safety ........................................................................................................................................................ 29 Accidents on Company Property ............................................................................................................................. 29 Inclement Weather and Emergency Policy .............................................................................................................. 30

iv VIII. If You Leave .............................................................................................................................................................. 30 Notice ..................................................................................................................................................................... 30 Return of Company Property .................................................................................................................................. 30 Final Pay ................................................................................................................................................................. 30 IX. Remote Work Policy ................................................................................................................................................ 30 Overview and Policy Statement .............................................................................................................................. 30 X. Employee Handbook Acknowledgement .................................................................................................................... 35 XI. Appendix A – Federal Family and Medical Leave Notice ........................................................................................ 36

1 I. Introduction About this Handbook This Employee Handbook has been prepared to provide you with general information about your benefits, work rules and policies under which Intercoastal Mortgage, LLC (“Intercoastal Mortgage,” “ICM, LLC,” or the “Company”) operates. This edition of our Handbook supersedes any previous editions. All rules and policies herein will apply and are intended for the guidance of all Employees, unless otherwise stated in the specific rule or Policy. Furthermore, conditions may require the Company to supplement, modify or eliminate the benefits, work rules and policies described in the handbook without prior notice. The Company therefore reserves the right, without prior notice, to exercise its discretion to unilaterally make changes in, deletions from, or additions to the handbook – except as required by law, and except for the rights of the parties to terminate employment at will, which may only be modified on an individual or collective basis, by an express written agreement signed by the Chief Executive Officer of the Company. The Handbook is not, nor should it be considered to be, an agreement, bargain, or contract of employment, expressed or implied, or a promise of treatment in any particular manner in any given situation. This Handbook states only general Company guidelines. To the extent anything contained in this Handbook conflicts with an applicable collective bargaining agreement, the collective bargaining agreement governs. The Company’s Policy is that employment is “at will.” You are free to leave the Company at any time, with or without a reason and with or without notice. The Company also has the right to end your employment at any time, with or without a reason and with or without notice. Although the Company may choose to end your employment for a cause, cause is not required. Further, the Company has the right to manage its work force and direct its Employees. This includes the right to hire, transfer, promote, demote, reclassify, lay off, terminate, or change any term or condition of employment at any time, with or without a reason and with or without notice, unless otherwise required by law. In the event that State and/or Federal laws and regulations differ from the policies detailed herein, the Company will comply with the applicable laws and regulations. If you have any questions as to the interpretation or application of a specific section of this Handbook you should consult the Human Resources department.

2 II. Employment with Intercoastal Mortgage, LLC Welcome Welcome to Intercoastal Mortgage! As an Employee, you are part one of the largest independent mortgage lending operations in the Mid-Atlantic Region. We are one great Company, serving our customers with decades of experience and a passion for customer service that exceeds expectations! Our Goal Our goal continues to be providing an unmatched customer experience while serving our communities and helping our clients achieve the American Dream of home ownership. Our Mission Our mission is to provide an experience that exceeds expectations! We challenge ourselves every day to enhance our clients’ knowledge and understanding of the mortgage process. Our business-savvy loan officers strive to be the most proficient, concerned, and proactive mortgage origination professionals in the industry. It is this commitment to excellence that will guarantee a successful and stress-free transaction for our clients. In our ever-changing regulatory world, our management team is constantly focused on improving our ‘best practices’ and streamlining our processes, such that decisions can be made that allow loan officers to act fast to benefit their clients. Our Core Values Commitment - With pride and dedication, we are committed to staying together through thick and thin. We are a team that cares for one another and recognizes that one person’s success is everybody’s success. We offer products and streamline experiences that fulfill our customers’ homeownership goals in a clear and transparent way, while delivering on the commitments we make to them. Innovation - We cultivate excellence by challenging ourselves to consistently adapt and improve processes that streamline the loan experience for our clients. We strive to deliver an enjoyable experience through our unrivaled service and seek to inspire a fun environment where innovation thrives. Trust - We trust the capabilities, character, and judgment of our colleagues. We strive every day to earn the trust of our clients and communities through honesty, transparency, and engagement. Respect - We promote and support a diverse and unified team where all members encourage and support each other. We consistently seek to treat others as we want to be treated, which is reflected in our relationships with team members, partners, clients, and community. Teamwork - We work as a team to achieve our goals and celebrate our successes. We value our differences and work together to create a workplace where everyone can contribute to the success of our Company. Our Commitment to Diversity Intercoastal Mortgage’s commitment reflects our recognition and value for the diversity that exists in our customer relationships, business partnerships, community involvement and vendor relationships. Embracing diversity is a key element of living our corporate values. We all live and work in a world where both our customers and or colleagues come from increasingly diverse backgrounds. For both our Company’s success and your personal success in this environment, we must understand and respect our differences as well as our similarities. We believe that a visible commitment to diversity will guide our business strategies, our corporate behavior, our relationships with customers, communities, suppliers, and each other in a manner that maximizes contribution to the success of the Company. Our commitment to diversity in our employment practices is about encouraging and enabling all Employees to reach their full potential in their employment experiences with our Company. We are committed to providing you with a

3 supportive work environment, exposure to challenging opportunities, and access to experiences that contribute to your success at Intercoastal Mortgage. Communicating with Our Employees Keeping our Employees up-to-date and well-informed are priorities at Intercoastal Mortgage. However, communication is a two-way process. Through internal communication channels and direct contact with Executive Management, Intercoastal Mortgage endeavors to keep its Employees abreast of business-related information. In turn, Employees are encouraged to provide feedback to management. Your manager plays an important role in Intercoastal Mortgage’s open-door approach. If you have any questions concerning your job or job-related activities, your manager is typically the best place to start. They can provide guidance and advice in dealing with most issues and can direct you to the best contacts within the Company for further assistance. (Please note, however, that Employees who have concerns about unlawful discrimination and/or unlawful harassment should follow the discrimination and harassment reporting procedures set forth later in this Handbook). Intercoastal Mortgage will not retaliate against Employees for conveying suggestions, questions, or concerns in good faith pursuant to this Policy. III. Basic Employment Policies Equal Employment Opportunity Statement It is the Policy of Intercoastal Mortgage not to discriminate against any Employee or applicant for employment because of race, (to include hairstyles historically associated with race such as braids, twists, lock and afro hairstyles), color, religion, sex (including pregnancy, childbirth, or a related medical condition), national origin, ancestry, citizenship status, age, marital status, genetic information, disability, military or veteran status, sexual orientation, gender identity and expression, transgender status, or any other classification protected by applicable federal, state, and local laws and ordinances (“Protected Characteristics”). Intercoastal Mortgage is committed to providing equal employment opportunities to Employees and applicants for employment regardless of Protected Characteristics and to base all employment decisions only on valid job requirements. This Policy shall apply to all employment actions, including but not limited to recruitment, hiring, placement, upgrading, promotion, transfer, demotion, leave of absence, layoff, recall, termination, rates of pay or other forms of compensation and selection for training and general treatment during employment. Employees and applicants of Intercoastal Mortgage will not be subject to harassment on the basis of any Protected Characteristic. Please review the Company’s Policy Against Harassment for additional information. Additionally, retaliation, including intimidation, threats, or coercion, because an Employee or applicant has objected to discrimination, engaged, or may engage in filing a complaint, assisted in a review, investigation, or hearing or have otherwise sought to obtain their legal rights under any Federal, State, or local EEO law is prohibited. As Chief Executive Officer at Intercoastal Mortgage, I am committed to principles of Equal Employment Opportunity. Any violation of this Policy will not be tolerated and will result in appropriate disciplinary action, up to and including termination. If an Employee believes someone has violated this Policy or otherwise has questions regarding this Policy, the Employee may bring the matter to the attention of Intercoastal Mortgage by following the Reporting Procedure in the Policy Against Harassment found in this Handbook. The Company will promptly investigate the facts and circumstances of any claim that this Policy has been violated and take appropriate corrective measures. We request the continued support of all Employees in accomplishing Equal Employment Opportunity. Harry Edward Dean Chief Executive Officer January 1, 2024

4 Reasonable Accommodation of Individuals with Disabilities Intercoastal Mortgage makes and will continue to make reasonable accommodations to promote the employment of qualified individuals with disabilities to perform the essential functions of the job unless such accommodations would impose an undue hardship on its business. A reasonable accommodation is any change in the work environment or in the way a job is performed that enables a person with a disability to enjoy equal employment opportunities including, for example, changes to a job application process, changes to the work environment, or to the way a job is usually done, or changes that enable an Employee with a disability to enjoy equal benefits and privileges of employment (such as access to training). Requests for reasonable accommodations should be submitted to the Human Resources team. We may ask you to complete a Request for Accommodation form or otherwise put your request in writing to confirm your request. Intercoastal Mortgage encourages you to include relevant information in your request such as a description of the accommodation you are requesting, the reason the accommodation is needed, and how the accommodation will help you perform the essential functions of your job. After receiving the accommodation request, the Company will engage in an interactive dialogue with the Employee to determine the precise limitations of the disability and explore reasonable accommodations that could overcome those limitations. The objective is finding a means by which an individual with a disability can perform the essential functions of the job. In accordance with applicable law, Intercoastal Mortgage encourages Employees to suggest specific reasonable accommodations; however, the Company is not required to provide the specific accommodation requested and may provide an alternative, effective accommodation, to the extent any reasonable accommodation can be made without imposing an undue hardship on the Company. If the Employee’s disability or need for accommodation is not obvious, the Company may ask the Employee to provide supporting documents showing that the Employee has a disability within the meaning of the Americans with Disabilities Act (ADA) and applicable state or local laws, and that the Employee’s disability necessitates a reasonable accommodation. If the information provided in response to this request in insufficient, the Company may require the Employee see a health care professional of the Company’s choosing, at the Company’s expense. In those cases, if the Employee fails to provide the requested information or see the designated health care professional, the request for a reasonable accommodation may be denied. Intercoastal Mortgage will keep confidential any medical information that it obtains in connection with a request for a reasonable accommodation. Intercostal Mortgage makes determinations about reasonable accommodations on a case-by-case basis considering various factors and based on an individualized assessment in each situation. The Company strives to make determinations on reasonable accommodation requests expeditiously and will inform the individual once a determination has been made. Any questions about a reasonable accommodation request should be made to Human Resources. Intercoastal Mortgage expressly prohibits any form of discipline, reprisal, intimidation, or retaliation against any individual for requesting an accommodation in good faith. The Company is committed to enforcing this Policy and prohibiting retaliation against Employees and applicants who request an accommodation in good faith. If Employees or applicants feel that they or someone else may have been subjected to retaliatory conduct that violates this Policy, they are encouraged to report it immediately to Human Resources. It is also the Policy of the Company that all its facilities, including its headquarters, all physical locations shall be in compliance with all applicable building codes. It is further the Policy of Intercostal Mortgage that all of its products and services shall be reasonably available in a convenient location to all customers that have a disability, and the Company shall use all reasonable efforts to accommodate all customers that have a disability. A Note on Genetic Information: Federal law prohibits employers from requesting or requiring genetic information of an individual or family member of the individual, except as specifically allowed by law(s). We respect your medical privacy and take our responsibility to comply with these laws seriously. Intercoastal Mortgage will not request or require you to

5 provide genetic information except in those limited circumstances allowed by law. “Genetic Information” as defined by federal law, includes an individual’s family medical history, the results of an individual’s or family member’s genetic tests, the fact that an individual or an individual’s family member sought or received genetic services, and genetic information of a fetus carried by an individual or an individual’s family member or an embryo lawfully held by an individual or family member receiving assistance reproductive services. If you have any questions about this Policy, please contact the Chief Human Resource Officer. If you believe there has been a violation of this Policy, please follow the Reporting Procedure set forth in the Policy Against Harassment. Reasonable Accommodation of Individuals’ Religious Beliefs and Practices Intercoastal Mortgage recognizes and supports its obligation to endeavor to reasonably accommodate job applicants and Employees with sincerely held religious beliefs or practices who can perform the essential functions of the position, with or without reasonable accommodation. Intercoastal Mortgage will endeavor to provide reasonable accommodation to other qualified job applicants and Employees, unless doing so would impose an undue hardship on the Company. An applicant or Employee who believes they needs a reasonable accommodation of a sincere religious belief or practice should discuss the need for a possible accommodation with Human Resources. Intercoastal Mortgage expressly prohibits any form of discipline, reprisal, intimidation, or retaliation against any individual for requesting an accommodation in good faith. The Company is committed to enforcing this Policy and prohibiting retaliation against Employees and applicants who request an accommodation in good faith. If Employees or applicants feel that they or someone else may have been subjected to retaliatory conduct that violates this Policy, they are encouraged to report it using the Reporting Procedures set forth in the Policy Against Harassment. Pregnancy Disability Accommodation Policy In compliance with applicable federal and state law, Employees have the right to be free from pregnancy discrimination and seek reasonable accommodation based on pregnancy, childbirth, or a related medical condition. If a pregnant Employee requests an accommodation for a disability caused or contributed to by the pregnancy, including leave, with the pregnant Employee, the Company will endeavor to provide a reasonable accommodation unless doing so would impose an undue hardship on the Company. Requests for accommodations should be made to Human Resources. Generally, a “qualified” applicant or Employee under this Policy is one who: (1) has an inability by the individual to perform an essential job function that is temporary; (2) can perform the essential job function in the near future; and (3) can perform the essential job function with a reasonable accommodation. Such accommodations may include, but are not limited to: (1) more frequent or longer bathroom breaks; (2) breaks to express breast milk; (3) access to a private location other than a bathroom for the expression of breast milk; (4) acquisition or modification of equipment; (5) access to or modification of Employee seating; (6) a temporary transfer to a less strenuous or hazardous position; (7) assistance with manual labor; (8) job restructuring; (9) a modified work schedule; (10) light-duty assignments; and (11) leave to recover from childbirth. The Company prohibits retaliation against any Employee with a pregnancy-related disability who seeks a reasonable accommodation under this Policy. If an Employee who takes leave under this Policy is also eligible for leave under the Family and Medical Leave Policy, then the leave taken under this Policy will run concurrently with Family and Medical leave. The Company need not make accommodations that would impose an undue hardship on the Company’s business. Three factors determine whether an accommodation would cause an undue hardship: (1) the nature of the employer’s operation, including composition and structure of the employer’s workforce; (2) the size of the facility; and (3) the nature and cost of the accommodations requested. The Company will not: • Require a qualified Employee or applicant to accept an accommodation without a discussion about the accommodation between the individual and the Company;

6 • Deny a job or other employment opportunities to a qualified Employee or applicant based on the individual’s need for a reasonable accommodation; • Require a qualified Employee to take leave, whether paid or unpaid, if a reasonable accommodation can be provided that would allow the Employee to continue working; • Retaliate against a qualified Employee for requesting or using a reasonable accommodation for a known limitation related to the Employee’s pregnancy, childbirth, or related medical condition; and • Retaliate against an individual for opposing or reporting unlawful discrimination or otherwise participating in a proceeding (including investigations into violations). Please contact the Human Resources Department if you have any questions about this Policy, or if you would like to request an accommodation. Policy Against Harassment Intercoastal Mortgage strictly prohibits harassment on the basis of an individual’s Protected Characteristic (defined in our EEO Policy in this Handbook). Harassment based on an individual’s Protected Characteristic is extremely offensive to the principles of fairness and equality for which Intercoastal Mortgage stands. Intercoastal Mortgage will not condone or tolerate unlawful harassment of any type by any Employee. This Policy applies to all Employee actions and relationships, within or outside the workplace (e.g., business trips, meetings, parties, etc.). Harassment Defined Harassment, as defined in this Policy, is unwelcome verbal, visual or physical conduct, based on an individual’s Protected Characteristic, creating an intimidating, offensive, or hostile work environment that interferes with work performance. Harassment can be verbal (including slurs, jokes, insults, epithets, gestures or teasing), graphic (including offensive posters, clothing, symbols, cartoons, drawings, computer displays, videos, messages via text, instant messaging, social media, or e-mails) or physical conduct (including physically threatening another, blocking someone’s way, etc.) that denigrates or shows hostility or aversion towards an individual because of any Protected Characteristic. Such conduct violates this Policy, even if it is not unlawful. Employees are always expected to behave in a professional and respectful manner. In the event any such prohibited conduct should occur in the workplace; you should follow the reporting procedures outlined in this Handbook. Any Employee who violates this Policy will be subject to disciplinary action up to and including termination. Sexual Harassment Defined Sexual harassment can include all the above actions, as well as other unwelcome conduct, such as unwelcome or unsolicited sexual advances, requests for sexual favors, conversations regarding sexual activities and other verbal or physical conduct of a sexual nature when: • Submission to such conduct is either explicitly or implicitly made a term or condition of an individual's employment; • Submission to or rejection of such conduct is used as the basis for employment decisions affecting the individual; or • Such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile, or offensive working environment. Examples of conduct that violates this Policy include: • Unwelcome sexual advances, flirtations, advances, leering, whistling, touching, pinching, assault, blocking normal movement; • Requests for sexual favors or demands for sexual favors in exchange for favorable treatment, or threatening an employment detriment for an Employee’s failure to engage in sexual activity; • Obscene or vulgar gestures, posters, or comments;

7 • Sexual jokes or comments about a person’s body, sexual prowess, or sexual deficiencies; • Propositions, or suggestive or insulting comments of a sexual nature (including sex stereotyping); • Derogatory cartoons, photos, posters, and drawings; • Sexually explicit messages, videos, emails, or voicemails; • Uninvited touching of a sexual nature; • Unwelcome sexually related comments; • Conversation about one’s own or someone else’s sex life; • Conduct or comments consistently targeted at only one gender, even if the content is not sexual; • Teasing or other conduct directed toward a person because of the person’s gender; All such conduct is unacceptable in the workplace and in any work-related settings such as business trips and business-related social functions, regardless of whether the conduct is engaged in by a supervisor, co-worker, client, customer, vendor, or other third party. Reporting Procedures The following steps have been put in place to ensure the work environment at Intercoastal Mortgage is free of harassment and discrimination. If an Employee believes someone has violated this Policy or the EEO Policy, the Employee should promptly bring the matter to the immediate attention of the Chief Human Resources Officer, unless the complaint involves the Chief Human Resources Officer, then the Employee should report the matter to the Chief Executive Officer. If an Employee makes a complaint under this Policy and has not received a satisfactory response within five (5) business days, they should contact the Chief Executive Officer immediately, unless the complaint involves the Chief Executive Officer, then the Employee should contact the President. Investigation Procedures Intercoastal Mortgage will promptly investigate the facts and circumstances of any claim of harassment. To the extent possible, the Company will endeavor to keep the reporting Employee’s concerns confidential; however, confidentiality cannot be guaranteed. During the investigation, the Company generally will: • Interview the complainant and the alleged harasser; • Conduct further interviews as necessary; • Document the investigators findings regarding the complaint; • Document recommended follow-up action and remedies, if warranted; and • Inform the complainant of the Company’s findings. Every supervisor/manager who observes conduct that may trigger the protections of this Policy or the EEO Policy or who learns of any Employee’s concern about conduct in violation of this Policy, whether in a formal complaint or informally, MUST immediately report the issues raised to the Chief Human Resource Officer or to the Chief Executive Officer. Upon completion of the investigation, the Company will take corrective measures against any person who has engaged in conduct in violation of this Policy, if the Company determines such measures are necessary. These measures may include, but are not limited to, counseling, suspension, or immediate termination. Anyone, regardless of position or title, whom the Company determines has engaged in conduct that violates this Policy will be subject to disciplines, up to and including termination. No Retaliation No Employee will be subject to, and the Company prohibits, any form of discipline or retaliation for reporting perceived violations of this Policy in good faith, pursuing any such claim, or cooperating in any way in the investigation of such claims in good faith. If an Employee believes someone has violated this no-retaliation Policy, the Employee should bring

8 the matter to the attention of Human Resources. Anyone, regardless of position or title, whom the Company determines has engaged in conduct that violates this Policy against retaliation will be subject to disciple, up to and including termination. We cannot remedy claimed harassment or retaliation unless you bring these claims to the attention of Human Resources. Failure to report claims of harassment and/or retaliation prevents us from taking steps to remedy the problem. Employees are responsible for reporting possible Policy violations to the Company so that we can take appropriate actions to address concerns. Whistleblower Protection Policy Intercoastal Mortgage will not discharge, discipline, threaten, discriminate or retaliate against, or otherwise penalize an Employee regarding the Employee’s terms and conditions of employment, such as compensation, work location, benefits or other privileges of employment for the following reasons: (1) the Employee, or person acting on behalf of the Employee, in good faith reports a violation of any federal, state or local law to a supervisor or to any governmental body or enforcement official; (2) a governmental body or law enforcement official asks the Employee to participate in an investigation, hearing or inquiry; (3) the Employee refuses to engage in a criminal act that would subject the Employee to criminal liability; (4) the Employee refuses an employer’s order to engage in conduct that violates any federal or state law or regulation and the Employee informs the employer that the order is being refused for that specific reason; or (5) the Employee provides information to or testifies before any governmental body or law-enforcement official that is investigating, inquiring into, or conducting a hearing about any alleged violation by the employer of a federal or state law or regulation. For additional information, please see our Whistleblower Policy located in the Federal Policy Manual. Employee Dating Policy As indicated above, Intercoastal Mortgage has a strong commitment to workplace free from inappropriate and illegal harassment. To ensure this Policy is carried out, Intercoastal Mortgage has adopted a Policy with respect to dating in the workplace. Although this Policy does not prevent the development of friendships or romantic relationships between co-workers, it does establish boundaries as to how relationships are conducted during working hours and within the working environment. Individuals in supervisory or managerial positions, and those with authority over others’ terms and conditions of employment, are subject to more stringent requirements under this Policy due to their status as role models, their access to sensitive information, and their ability to affect the terms and conditions of employment of individuals in subordinate positions. Specifically, there are some circumstances where romantic relationships may not be appropriate in a professional setting, particularly where one of the parties has management or supervisory responsibilities. Accordingly, a member of management should never become sexually involved with any subordinate Employee of Intercoastal Mortgage. Any supervisor, manager, executive or other Company official in a sensitive or influential position with Intercoastal Mortgage must disclose the existence of a romantic or sexual relationship with another co-worker. Disclosure may be made to the immediate supervisor and Human Resources. This disclosure will enable the Company to determine whether any conflict of interest exists because of the relative positions of the individuals involved. If a conflict-of-interest problem or other potential risk is identified, the Company will work with the parties involved to consider options for resolving the problem. The initial solution may be to make sure the parties no longer work together on matters where one is able to influence the other or has responsibility over the other. In some cases, other measures may be necessary, such as transfer to another position or departments. If one or both parties refuse to accept a reasonable solution or the offer of an alternative position, if available, such refusal will be deemed a voluntary resignation. Any Employee who violates this Policy may be subject to disciplinary action up to and including termination.

9 Drugs, Alcohol, and the Workplace The Company is committed to promoting a safe workplace. We want to maintain the quality and integrity of our services, as well as our reputation within the community; and we recognize that drug and/or alcohol abuse poses a significant threat to those goals. It is important that our Employees can work in a safe and productive environment. Accordingly, we have established this Drug and Alcohol Workplace Policy. The Company reserves the right to modify or rescind this Policy and to interpret this Policy in its sole discretion to the greatest extent permitted by law. An Employee may not: (1) use, possess, distribute, sell, or be under the influence of alcohol, state legalized marijuana, or illegal drugs while at work; (2) use prescription drugs in a manner not prescribed, including medical marijuana; or (3) use over-the-counter drugs in a manner not intended or that impairs an Employee’s ability to safely perform their job without impairment. A job applicant and/or Employee may be subject to testing under the following conditions: • Pre-employment: After an offer has been extended, as a condition of employment, job applicants may be required to submit to a drug and alcohol test; • By location and/or work area: All Employees may be subjected to unannounced, mandatory drug/alcohol testing by location and/or work area. If a mandatory drug drug/alcohol test is given, all Employees will be required to take the test during work hours. Employees who are absent from work on the day the test is given will be required to take the test at a later unannounced date. Employees who leave the facility without notification to the Company after the test is announced, but prior to being tested, will be considered to have tested positive and may be subject to immediate termination; • Reasonable suspicion: When the Company has evidence or reasonable suspicion that an Employee is under the influence of alcohol and/or drugs while at work in violation of this Policy, the Employee may be asked to submit to a drug and alcohol test. Testing based on reasonable suspicion will be conducted only when a supervisor or manager in partnership with Human Resources makes observations of the Employee’s suspicious or unusual conduct in the workplace; or • Post-Incident: The Company reserves the right to conduct post-incident drug testing following a work-related accident or incident. The Company will conduct post-incident drug testing if there is a reasonable possibility that Employee drug/alcohol use could have contributed to the reported injury or illness. In all testing circumstances, including tests based on reasonable suspicion, the Company reserves the right to test for all substances allowed under applicable state or federal law. The sample collection, transportation, chain of custody, and testing under this Policy will be conducted in accordance with the guidelines and standards of the U.S. Department of Health and Human Services (“DHHS”) and any applicable state law. Prior to any specimen collections, Employees will be requested to sign a consent form advising the Employee that a drug and/or alcohol test is being conducted. The results of the test will be reported in the strictest confidence to the Medical Review Officer (“MRO”) and the Company will only be notified as to whether the test was positive or negative. The Company will follow the guidelines established by the Department of Transportation (”DOT”) for drug and/or alcohol concentration levels. These levels are subject to change when the guidelines are changed by the DOT. The Company reserves the right to modify the testing method in accordance with DOT and/or DHHS standards or state requirements. All positive initial test results will be confirmed by a gas chromatography/mass spectrometry (“GC/MS”) test before being considered a positive result under this Policy. Test results will be kept confidential and only released with the Employee’s permission or when required by law. If a test is positive, the Company will give the Employee a copy of the lab’s test indicating the result, a copy of this Policy, notification of any disciplinary actions, if applicable, that the Company intends to undertake, and a copy of the statutory provision regarding the Employee’s right to seek an independent verification test. The Company will pay an Employee’s normal compensation for a reasonable time taken to submit to a test mandated by this Policy. The Company will cover the costs of the initial test and, when the initial test is positive, of the confirmation

10 test. Under certain states’ laws, an Employee may request a re-testing of the same sample before the Company makes any determination on the Employee’s or applicant’s status. The Company will notify the applicant or Employee in writing of any such rights under state law. A confirmed positive test result may be grounds for disciplinary action, up to and including immediate termination or recission of an employment offer. An Employee who refuses to submit to testing conducted in accordance with this Policy will be considered to be in a willful violation of this Policy and may be subject to disciplinary action, up to and including immediate termination, or in the case of an applicant, the offer of employment will be withdrawn. Additionally, tampering with a sample may be grounds for disciplinary action, up to and including immediate termination. The Company maintains a Policy of non-discrimination and will endeavor to make reasonable accommodation to assist individuals recovering from substance and alcohol dependencies, and those who have a medical history which reflects treatment for substance abuse conditions. However, Employees may not request an accommodation to avoid discipline for a Policy violation. It is a condition of employment that Employees abide by the terms of this Policy. It is a further condition of employment that Employees must notify Human Resources within (5) days of any felony violation of criminal law that results in a conviction relating to the unlawful manufacturing, possession, sale, distribution and/or use of drugs. Employees convicted of such criminal activity may be subject to discipline, up to and including immediate termination. The use of controlled substances prescribed to you by a licensed physician or are available over the counter is not prohibited by this Policy. However, if a physician has prescribed medication that requires any accommodation or poses safety concerns, please notify Human Resources to discuss what accommodations are necessary. Prescription and over the counter medications may result in a positive test result. If an Employee is concerned that their legal use of prescription and/or over-the-counter medications may result in a positive test result, the Employee may discuss this information with the MRO. For states in which medicinal and/or recreational marijuana use has been legalized, this Policy will be enforced to the full extent of the law. Without exception, Employees are prohibited from possessing, using, or being under the influence of marijuana while at work. If you have any questions regarding this Policy, contact Human Resources. Consumption of Alcohol at Work and/or at Work-Related Events Under all circumstances, an Employee’s conduct when consuming alcohol is their responsibility. At work related social events where alcohol is being served and/or is available to Employees, Employees who choose to drink are expected to do so responsibly and to behave respectfully towards colleagues as well as toward themselves. Employees must also ensure that they are well within the legal limits if they are driving. If an Employee planned to drive and overindulged, they should act responsibly and attempt to find a safe ride with a colleague who is not impaired or a taxi or ride-share service. Employees who violate this Policy may be subject to discipline, up to and including termination. The Company also maintains a Policy on drugs, alcohol, and the workplace in this Handbook. Drinking to excess at work-related events will not be tolerated and may be treated as a violation of our Drugs, Alcohol, and the Workplace Policy and may result in disciplinary action up to and including termination. Minors and Alcohol Persons under the age of twenty-one (21) are strictly prohibited from drinking alcohol at any Company-sponsored and/or work-related event.

11 Workplace Violence Prevention Intercoastal Mortgage is strongly committed to providing a safe workplace. The purpose of this Policy is to minimize the risk of personal injury to Employees and damage to Company property. We specifically discourage Employees from engaging in any physical confrontation with a violent or potentially violent individual. However, we do expect and encourage Employees to exercise reasonable judgement in identifying potentially dangerous situations and informing management accordingly. If an Employee witnesses and/or learns of anything that poses an immediate threat of danger to person or property, the Employee should immediately call “911” and alert the appropriate authorities of the concerns, then follow the reporting procedure in this Handbook. Threats, threatening language, or any other acts of aggression or violence made toward or by any Intercoastal Mortgage Employee will not be tolerated. For purposes of this Policy, a threat includes any verbal or physical harassment or abuse, attempts to intimidate or to instill fear in others, menacing gestures, bringing weapons to the workplace, stalking, or any other hostile, aggressive, injurious and/or destructive actions undertaken for the purpose of domination or intimidation. Weapons are prohibited on Company premises unless such prohibition is restricted by applicable law. All potentially dangerous situations including threats by co-workers should be reported immediately to the Chief Human Resource Officer. This includes threats by Employees, as well as threats by customers, vendors, solicitors, or other members of the public. Reports of threats may be made anonymously. All threats will be promptly investigated. No Employee will be subject to retaliation, intimidation, or discipline because of reporting a threat under this Policy. If an investigation confirms that threat of a violent act or violence itself has occurred, the Company will take appropriate corrective action. Anyone, regardless of position or title, whom the Company determines has engaged in conduct that violates this Policy, including retaliation, will be subject to discipline, up to and including termination. If you are the recipient of a threat made by an outside party, please follow the steps detailed in this section. It is important for the Company to be aware of any potential danger in our workplace. Indeed, we want to take every precaution to protect everyone from the treat of a violent act by an Employee or anyone else. IV. Working at Intercoastal Mortgage Employee Classifications • Regular Full-Time Employees: Employees who are regularly scheduled to work at least 30 hours per week. Regular Full-Time Employees are eligible for all Company benefits, subject to the terms and conditions of the applicable plans. • Regular Part-Time Employees: Employees who are regularly scheduled to work fewer than 30 hours per week. Part-time Employees are eligible for some, but not all, Company benefits, subject to the terms and conditions of the applicable plans. • Temporary Employees: Employees who are hired for a specific task, internship, or project; usually involving fewer than 180 days. While they do receive all benefits as required by law, temporary Employees are generally not eligible for Company benefits. Personnel and Payroll Records To obtain your position, you provided us with a great deal of personal information, such as your address and telephone number. This information is contained in your confidential personnel file. It is important that your personnel records are accurate and up to date. Certain information also is necessary to determine the amount of wage deductions for federal and state income tax. Any change in your name, address, telephone number, marital status, or emergency contact telephone number should be updated in the ADP Employee Portal. Employees will be granted access to and copies of personnel files to the extent required and in accordance with applicable state law.

12 Promotions and Transfers As the Company continues to grow there will be opportunities for Employees to advance their professional development. Career management means more than just the traditional corporate ladder to be climbed. For some people career advancement may still mean moving “up;” for others it may mean growing in place and gaining satisfaction by expanding current responsibilities. For others it may mean choosing a lateral direction, a move to a less senior position, or even a move to a previous position. It all depends on how you choose to manage your career. When positions become available, they usually will be posted and available to Employees to apply for a specified period of time. These positions will be posted on the careers page of the Company website. Keep in mind that internal and external candidates may be considered simultaneously. You are eligible to apply for a posted position if you are not on a Performance Improvement Plan (PIP) and have been in your current role for a minimum of one year. These guidelines can be adjusted with Executive Management approval. You are encouraged to maintain open communication with your manager throughout the job posting process as they can be an invaluable source of coaching. If you are selected to interview for an internal position, as a prerequisite, you are required to advise your Manger before the interview occurs. If you have any questions about the job posting process, please reach out to a member of the Human Resources Team. Your Pay A key objective of Intercoastal Mortgage is to attract and retain top talent who demonstrate an ability to succeed and grow professionally and who model the Company’s values. We believe that an effective compensation practice rewards performance and behaviors that drive and enhance the Company’s performance. Your pay is influenced by many factors, including your skills, experience, salary history, education, nature and scope of your job, performance, and the Company’s budgetary needs. Wage and salary increases are based on several factors, including the Company’s financial wellbeing, your performance, and wages within our industry. Length of service may also be among the factors considered. Pay Transparency: Retaliation Prohibited In compliance with federal and certain states’ laws, Intercoastal Mortgage will not discharge or in any other manner discriminate or retaliate against Employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another Employee or applicant. Employees who have access to the compensation information of other Employees or applicants as part of their essential job functions cannot disclose the pay of other Employees or applicants to individuals who do not otherwise have access to compensation information, unless the disclosure is: (a) in response to a formal complaint or charge; (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer; or (c) consistent with the Company’s legal duty to furnish information. If you have questions about this Policy or believe that you have been subjected to discrimination or retaliation for inquiring about, discussing, or disclosing your own pay or the pay of another Employee or applicant, you should contact Human Resources to make a report. The Company will investigate your report and take corrective action, if necessary. Intercoastal Mortgage prohibits retaliation against any Employee for making a report under this Policy. Your Work Week Intercostal Mortgage maintains office hours consistent with our customer’s need and marketplace standards. Your department manager will establish your hours of work. Keep in mind that we reserve the right to adjust your work hours based on the business needs. When you begin your employment with us, you will be advised of your schedule. From time-to-time, it may be necessary to change your work schedule. Your cooperation with any such changes is both expected and appreciated.

13 We will do our best to give you as much advance notice as possible of any changes in your work schedule. We also will try to keep all unscheduled changes to a minimum. For payroll purposes, the workweek starts on a Sunday and ends on a Saturday. While your manager will try to accommodate your special needs, such as time off for emergencies, we expect that you will respond to the special needs of our customers and the Company by being flexible when necessary. Rest Breaks and Meal Periods – Non-Exempt Employees Non-exempt Employees will be provided with rest breaks and/or unpaid meal periods to the extent required and in accordance with applicable law. Department managers determine the times at which meal periods may be taken. Employees are required to record their meal period on their time sheet. Non-exempt Employees must refrain from performing any work during their meal period unless their manager approves it in advance, in which case such an Employee shall be paid for the time worked. If a non-exempt Employee fails to obtain advance approval for working during a meal break, the Employee will be paid for the time worked; however, the Employee may also be subject to discipline, up to and including discharge from employment. Lactation Accommodation The Company will provide a reasonable amount of break time to accommodate an Employee’s need to express breast milk for the Employee’s infant child. The break time should, if possible, be taken concurrently with other break periods already provided. Non-exempt Employees should clock out for any time taken that extends beyond 20 minutes, and such time will be unpaid in accordance with federal and state law. The Company will also provide the Employee with the use of a room or other location that is not a staff toilet, for the Employee to express milk in private. Employees should notify the Human Resources department to request times to express breast milk under this Policy, no provision of this Policy applies or is enforced if it conflicts with or is superseded by any requirement or prohibition contained in a federal, state, or local law or regulation. Overtime – Non-Exempt Employees Unless state law provides otherwise, non-exempt Employees will be paid one and one-half times their regular rate of pay for all hours they work more than forty (40) in a single workweek. Paid time, such as vacation, sick leave, holiday, or jury duty, and the like are not “hours worked” and do not count toward the computation of overtime. Employees are required to work the hours specified by their manager. The only reason for overtime is to meet our operational objectives in serving our customers and working overtime must be approved in advance by the Employee’s manager. By default, overtime is not authorized. This includes working through meal periods, coming in early or staying late. Every single hour worked by a non-exempt Employee must be properly recorded on the Employee’s timecards. The Employee is solely responsible for recording the correct hours worked on their timecard. Working “off the clock” is not permitted, and no one in the Company has the authority to require any non-exempt Employee to perform off-the-clock work. Employees will be paid for all hours worked in accordance with the law. However, Employees who work overtime without prior approval will be subject to disciplinary action for not following Company Policy. A daily unpaid meal break is permitted for all full-time non-exempt Employees. During the meal break, Employees may not perform any work on behalf of the Company, a vendor, or a customer. However, if an Employee is directed to work during their meal break, that time will be counted as time worked and the Employee will receive overtime if the Employee’s hours are more than 40 in that same workweek. Employees who work during their meal break must have prior permission from their managers.

14 Timekeeping - Non-Exempt Employees Federal and state law requires the Company to maintain an accurate record of hours worked by non-exempt Employees. Non-exempt Employees are required to record their time daily. Non-exempt Employees must maintain a record of the time they started and ended each day and the time in and out for a meal break. Non-exempt Employees are also required to record use of vacation or other paid or unpaid absences from work. Unless pre-authorized by your manager for overtime, you may not sign in or start your work more than five (5) minutes before your scheduled start time or sign out more than five (5) minutes after your scheduled quitting time. At the end of each pay period, non-exempt Employees must provide their verification of the accuracy of their timecard. No one is permitted to verify the working time for anyone other than themselves. Non-exempt Employees are responsible for failing to record work time and/or recording inaccurate time. In the event of missed time recording or timekeeping errors or discrepancies, it is the non-exempt Employee’s responsibility to promptly report the issue to their manager and work with their manager to correct the issue before the close of the pay period. Falsification of payroll-related records (including but not limited to hours worked and paid leave usage) may result in disciplinary action up to and including termination. Timekeeping – Exempt Employees Exempt Employees are not required to sign in and out daily. As used, or at a minimum of every two weeks, exempt Employees must record any vacation, sick, or any other types of paid or unpaid absences from work in the Time & Attendance section of the ADP Employee Portal. Falsification of payroll-related records (including but not limited to hours worked and paid leave usage) may result in disciplinary action up to and including termination. The Company’s pay practices, procedures and records are the basis for establishing the number of hours worked by each Employee. Nothing in this Handbook is a guarantee of hours of work per day, per week, per year, or of any specific work schedule. Your Paycheck Employees are paid on a bi-weekly basis every other Friday. Although you may receive your pay voucher itemizing your earnings and your deductions prior to payday, funds are not deposited in your account until the payday. Checks that are presented for payment the evening before payday could create an overdraft. Employees who are paid by check, instead of direct deposit, may also receive their paycheck prior to payday. However, the check cannot be cashed until the effective pay date. Certain deductions must be paid from your pay for federal and state taxes. In addition, the Company must deduct for court-ordered liens, attachments, garnishments, and levies. If you wish to change your tax withholding for federal or state income taxes, you may update the forms using the ADP Employee Portal. Payroll deductions can also be used for benefits premiums and 401(k) contributions. These deductions will only be made with your authorization. Administrative Pay Correction Policy All Employees are responsible for reviewing their pay statements and commission statements to ensure they are properly paid. Non-Exempt Employees – Pay Corrections: Non-exempt Employees should report discrepancies immediately to Human Resources for review and correction, as necessary. Exempt Employees – Pay Corrections: As an exempt salaried Employee, you receive a salary which is intended to compensate you for all hours you work for the Company. This salary will be established at the time of hire or when you become classified as an exempt Employee. While it may be subject to review and modification from time-to-time, the salary will be a predetermined amount that will not be subject to deductions for variations in the quantity or quality of the work you perform.

15 Under federal and state law, your salary is subject to certain deductions. For example, absent contrary state law requirements, your salary can be reduced for the following reasons: • Full-day absences for personal reasons; • Full-day absences for sickness or disability if you have exhausted the sick and vacation leave available to you; • FMLA absences (either full or partial day absences); • Full-day disciplinary suspensions for infractions of safety rules of major significance. Unpaid disciplinary suspensions of one or more full days for significant infractions of major workplace conduct rules set forth in Company Policies; • To offset amounts received by you as payment for jury duty and witness fees or military pay; • During your first or last week of employment in the event you work less than a full week; or • Any workweek in which you perform no work for the Company; Your salary also may be reduced for certain types of deductions, such as your portion of health, dental or life insurance premiums; state, federal or local taxes, social security; or voluntary contributions to a 401(k). In any workweek in which you performed any work, your salary will not be reduced for any of the following reasons: • Partial-day absences for personal reasons, sickness, or disability; • Your absence on a holiday when the Company is closed or when the Company is otherwise closed on a scheduled workday; • Absences for jury duty, attendance as a witness, or military leave in any week in which you have performed any work; or • Any other deductions prohibited by state or federal law. If you believe you have been subject to any improper deductions, you should immediately report the matter to your manager. If the manager is unavailable or if you believe it would be inappropriate to contact that person (or if you have not received a prompt and fully acceptable reply), you should immediately contact Human Resources. Every report will be fully investigated, and corrective action will be taken where appropriate, up to and including termination for any Employee(s) who violate this Policy. In addition, the Company will not allow any form of retaliation against individuals who report alleged violations of this Policy or who cooperate in the investigation of such reports. Retaliation is unacceptable, and any form of retaliation in violation of this Policy will result in disciplinary action, up to and including termination. V. Employee Benefits Your Benefits Package Intercoastal Mortgage offers of number of benefits to its eligible Employees such as health, dental and vision insurance, 401(k) plan, life insurance, disability insurance to name a few of the key benefits offered. Most benefits will be described for you in a benefits orientation meeting when you commence employment, and annually during open enrollment. Some Employee benefits are summarized in this Handbook. The provisions of the plans, including eligibility and benefits provisions, are summarized in the Summary Plan Descriptions (“SPDs”) (which may be revised from time to time) for the plans. Additionally, the official plan documents are available for your review upon your request from Human Resources. In the determination of benefits or other matters under each plan, the terms of the official plan documents shall govern over the language of ay descriptions of the plans, including in this Handbook and in the SPDs. Further, the Company (including the officers and administrators who are responsible for administering the plans) retains full discretionary authority to interpret the terms of the plans, as well as full discretionary authority regarding administrative matters arising in connection with the plans and all issues concerning benefit eligibility and entitlement.

16 While the Company intends to maintain these Employee benefits, it reserves the absolute right to modify, amend or terminate these benefits at any time and for any reason. If you have any questions regarding your benefits, please contact Human Resources. Workers’ Compensation Insurance and Short-Term Disability Benefits Accidental injuries which occur during working hours or conditions caused by work activities are covered under our Workers’ Compensation Policy, which is paid for by the Company. This insurance provides for the payment of medical expenses and weekly compensation payments during the period of an Employee’s work-related injury or illness. Report all injuries, no matter how slight, to Human Resources as soon as possible. You must file your claim forms promptly for your claim to be processed and Company records to be prepared properly. Failure to follow these procedures may affect your ability to receive Workers’ Compensation benefits. Employees also may be entitled to receive Short-Term Disability payments for non-occupational injuries. Workers’ Compensation and Short-Term Disability are solely monetary benefits and not leaves of absence. Leave Policies Family and Medical Leave Intercostal Mortgage complies fully with the federal Family and Medical Leave Act (“FMLA”). This Policy generally summarizes Employees’ right and responsibilities under the FMLA. Please also refer to the notice at the end of this Handbook, which provides Employees with a general notice of their rights and responsibilities under the FMLA. Eligibility Requirements To qualify to take family or medical leave under this Policy, the Employee must meet the following conditions: • The Employee must have worked for the Company for 12 months or 52 weeks. The 12 months or 52 weeks need not have been consecutive. Separate periods of employment will be counted, provided that the break in service does not exceed seven (7) years. Separate periods of employment will be counted if the break in service exceeds seven (7) years due to National Guard or Reserve military service obligations. For eligibility purposes, an Employee will be considered to have been employed for an entire week even if the Employee was on the payroll for only part of a week or if the Employee is on leave during the week; • The Employee must have worked at least 1,250 hours during the 12-month period immediately before the date when the leave is requested to commence. Paid or unpaid time away from work does not count as hours worked. Consequently, those hours are not counted in determining the 1,250 hours eligibility test under the FMLA; and • The Employee must work at a location where at least fifty (50) Employees are employed by ICM, LLC within a seventy-five (75) mile radius. Basic Leave Entitlement The FMLA requires covered employers to provide up to 12 weeks of unpaid, job-protected leave in a 12-month period to eligible Employees for certain family and medical reasons. The 12-month period is determined on a “rolling” 12-month period dating back from the time the Employee requests leave. Leave may be taken for any one, or for a combination, of the following reasons: • To care for the Employee’s child after birth, or placement for adoption or foster care within one (1) year of the birth of placement of the child; • To care for the Employee’s spouse, son or daughter, or parent (but not in-law) who has a serious health condition; and/or

17 • For the Employee’s own serious health condition (including any period of incapacity due to pregnancy, prenatal medical care, or childbirth) that makes the Employee unable to perform one or more of the essential functions of the Employee’s job. Military Family Leave Eligible Employees with a spouse, son, daughter, or parent on covered active duty or called to covered active-duty status (or has been notified of an impending call or order to covered active duty) in the Reserve component of the Armed Forces in support of a contingency operation or Regular Armed Forces for deployment to a foreign country may use their 12-week leave entitlement to address certain qualifying exigencies. Qualifying exigencies may include short-notice deployment, attending certain military events, arranging for alternative childcare and related activities, addressing certain financial and legal arrangements, attending certain counseling sessions, caring for the parents of the military member on covered active duty, taking up to 15 calendar days of leave to spend time with a military member who is on short-term, temporary rest and recuperation leave during deployment, and attending post-deployment reintegration briefings. FMLA also includes a special leave entitlement which permits eligible Employees to take up to 26 weeks of leave to care for their son, daughter, parent or next of kin who is a covered service member with a serious injury or illness during a single 12-month period (one time basis only). A covered service member is a current member of the Armed Forces, including a member of the National Guard or Reserves, who is undergoing medical treatment, recuperation, or therapy, is otherwise in outpatient status, or is on the temporary retired list, for a serious injury or illness. These individuals are referred to in this Policy as “current members of the Armed Forces.” Covered service members also includes a veteran who is discharged or released from military services under condition other than dishonorable at any time during the five-year period preceding the date the eligible Employee takes FMLA leave to care for the covered veteran, and who is undergoing medical treatment, recuperation or therapy for a serious injury or illness. These individuals are referred to in this Policy as “covered veterans.” The FMLA definitions of a “serious injury or illness” for current Armed Forces members and covered veterans are distinct from the FMLA definition of “serious health condition” applicable to FMLA leave to care for a covered family member. Job Benefits and Protection If applicable, during FMLA leave, ICM, LLC must maintain health coverage under any “group health plan” on the same terms as if the Employee had continued to work. If paid time off is substituted for unpaid leave, the Company will deduct the Employee’s portion of any applicable health plan premium as a regular payroll deduction. If the Employee’s leave is unpaid, the Employee must make arrangements with Human Resources prior to taking leave to pay their portion of any applicable health insurance premiums each month. If the Employee’ premium is more than thirty (30) days late, the applicable coverage may cease. Upon return from FMLA leave, most Employees must be restored to their original or equivalent positions with equivalent pay, benefits, and other employment terms. The use of FMLA leave cannot result in the loss of any employment benefits that accrued prior to the start of an Employee’s leave. Upon returning from FMLA, Employees are required to work 30 days from the date of return to ensure continued benefit coverage. If the Employee fails to work the 30 days following, benefits will be cancelled retroactively to the last day worked, unless the failure to work is due to a serious health condition of the Employee or the Employee’s family member or a circumstance beyond the Employee’s control. Definition of Serious Health Condition Generally, a serious health condition is an illness, injury, impairment, or physical or mental condition that involves either an overnight stay in a medical care facility, or continuing treatment by a health care provider for a condition that either prevents the Employee from performing the functions of the Employee’s job or prevents the qualified family member from participating in school or other daily activities. Subject to certain conditions, the continuing treatment requirement may be met by a period of incapacity of more than three (3) consecutive calendar days combined with at least two visits to a health care provider or one visit and a regimen

18 of continuing treatment, or incapacity due to pregnancy, or incapacity due to a chronic condition. Other conditions may meet the definition of continuing treatment. Use of Leave An Employee does not need to use this leave entitlement in one block. Leave can be taken intermittently or on a reduced leave schedule when medically necessary. Employees must make reasonable efforts to schedule leave for planned medical treatment so as not to unduly disrupt the Company’s operations. Leave due to qualifying exigencies may also be taken on an intermittent basis. Substitution of Paid Leave for Unpaid Leave Employees must use granted, unused vacation and sick time while on unpaid FMLA leave. The substitution of paid time for unpaid FMLA leave time does not extend the length of FMLA leave and all paid time (e.g., vacation, sick and safe leave, Short-Term Disability Benefits; Workers’ Compensation Benefits, and the like, as applicable) will run concurrently with an Employee’s FMLA entitlement and do not extend the maximum amount of leave to which an Employee may be eligible under the FMLA. Employee Responsibilities All Employees requesting FMLA leave must provide Human Resources with verbal or written notice of the need for the leave. Within five (5) business days after the Employee has provided this notice, Human Resources will provide the Employee with a Notice of Eligibility and Rights and the appropriate medical certification form. 1. Notice: If the need for leave is foreseeable, the Employee must provide at least 30 days advance notice in writing when the need for the leave is foreseeable. When the need for the leave is not foreseeable, Employees should request leave in writing as far in advance as possible and practical. Employees who fail to give 30 days’ notice for foreseeable leave without a reasonable excuse for the delay, or otherwise fail to satisfy FMLA notice obligations, may have FMLA leave delayed or denied. 2. Certification: The Employee must provide the required certification form (medical or military) from a healthcare provider within 15 days after receiving the Notice of Eligibility (information must be valid, complete, and sufficient under FMLA regulations). If submission of the certification form is delayed due to extenuating circumstances, a reasonable extension can be granted; however, the Employee must notify Human Resources of the delay and the date the certification form will be returned. Under Department of Labor regulations, reinstatement may be denied or delayed to Employees who fail to provide appropriate certification. 3. Call-In Procedure: Employees on FMLA leave still must comply with appropriate call-in procedures and absence notification as set forth the Attendance & Punctuality Policy. Calling in “sick,” without providing the reasons for the needed leave, will not be considered sufficient notice of a need for FMLA leave under this Policy. Employees must respond to the Company’s questions to determine if absences are FMLA-qualifying. 4. Recertification: Pursuant to applicable regulations, Employees may be required to provide periodic recertification by a healthcare provider, if requested. 5. Status Reports: Employees must provide periodic status reports as requested during the leave. Under Department of Labor guidelines, the Company may question Employees to confirm whether the leave is still needed and being taken for FMLA purposes. In addition, the Company may require periodic reports on the Employee’s status and intent to return to work. 6. Fitness For Duty: Provide a return-to-work release or fitness for duty statement prior to or upon return from leave for the Employee’s own serious health condition. The fitness for duty statement that your health care provider provides must assess your ability to perform the essential functions of your job, with or without a reasonable accommodation. Should the Employee need an accommodation to return to work, the Company will address that need pursuant to its Policy governing reasonable accommodation under the Americans With Disabilities Act and/or similar state or local law. If the Employee is released to return to work sooner because the circumstances of the FMLA leave change, please notify your supervisor and Human Resources as soon as you know of the change. 7. Respond to Requests for Information: Employees must provide accurate, valid, complete, and sufficient requests, certifications, and documentation. Intentionally providing misleading information or falsified

19 documents or using FMLA for reasons not covered by federal or state regulations may result in disciplinary action up to and including termination. 8. Follow Policies: Employees must abide by all Company policies and procedures as well as all departmental policies. 9. Employees must provide sufficient information for a determination to be made as to whether the absence qualifies as FMLA as well as the anticipated timing and duration of the leave. In addition, Employees must state whether the requested leave is for a FMLA period that was previously taken or designated as FMLA leave. The Company’s Responsibilities The Company must inform Employees requesting leave whether they are eligible under the FMLA. If they are, the notice must specify any additional information required as well as the Employees’ rights and responsibilities. If they are not eligible, the employer must provide a reason for ineligibility. The Company must inform Employees if leave will be designated as FMLA-protected and the amount of leave counted against the Employee’s leave entitlement. If the employer determines that the leave is not FMLA-protected, the employer must notify the Employee. Unlawful Acts by Employers FMLA makes it unlawful for the Company to: • Interfere with, restrain, or deny the exercise of any right provided under the FMLA; or • Discharge or discriminate against any person for opposing any practice made unlawful by the FMLA or for involvement in any proceeding under or relating to the FMLA; If you believe that the Company has violated either of these obligations, please report your concerns to the Human Resources Department. Enforcement Employees may file a complaint with the U.S. Department of Labor or may bring a private lawsuit against an employer. FMLA does not affect any Federal or State law prohibiting discrimination or supersede any State or local law or collective bargaining agreement, which provides greater family or medical leave rights. Vacation Leave Eligibility Full-time non-sales Employees working at least 32 hours each work week are eligible for paid annual vacation leave immediately upon hire. (Interns are not eligible for vacation leave). Reasons for Use Intercoastal Mortgage provides eligible Employees with paid vacation time each calendar year to use for any reason, including, but not limited to: • Vacation; • School activities or conferences; • Variable holidays; • Religious observances; • Bereavement leave, if paid time available under the Company’s Bereavement Policy is exhausted; • Personal business; or • Unpaid portion of a leave under FMLA if Sick Leave is exhausted under the Company’s Sick Leave Policy. Vacation Grant The “vacation year” runs from January 1 and ends on December 31 (“Policy year”). Employees hired during a Policy year will be granted a prorated amount of vacation leave based on their date of hire. Eligible Employees are granted vacation leave allotment on January 1 of each year as outlined in the chart below: Grant Amount Full-Time Employees Hours Days 0 to 5 Years of Service 120 15

20 6 to 15 Years of Service 160 20 15+ Years of Service 200 25 Limited exceptions to the above may be made at the sole discretion of the Company with approval from Executive Management. Use and Scheduling of Vacation Request for time off must be scheduled at least seven (7) days in advance for any foreseeable vacations, personal leave, and other events/activities. If the need to use vacation leave is unforeseeable and sick leave has been exhausted under the Company’s sick leave Policy, the Employee must notify their manager as soon as is practical and must follow the proper call-in procedure for absence or lateness/leave. The timing and duration of an Employee’s use of successive days of vacation leave are subject to manager approval, unless vacation leave is being used for purposes of approved medical leave under the FMLA Policy, for leave provided to an Employee as a reasonable accommodation, or for other forms of job protected leave. Employees are required to use available vacation leave when taking time off from work for any reason, unless another form of paid leave applies, for example: Sick Leave, Bereavement, or Military Leave, or unless Company Policy, state law or federal law provides otherwise. Vacation leave may be taken in 15-minute increments. When an Employee plans to use vacation leave for the entire workday, the Employee must request vacation hours according to his or her regularly scheduled workday. For example, if an Employee works a six (6) hour day, he/she would request six (6) hours of vacation leave when taking that day off. When an Employee plans to use vacation leave for a partial workday, the working hours and vacation hours used may not exceed a total of 8 hours in any given workday. Generally, time away from work without pay will not be granted if vacation pay is available for the Employee’s use. Should a non-exempt Employee deplete all available vacation leave and sick leave, any additional time away from work is not permitted unless the Employee qualifies for FMLA leave, short-term disability benefits, workers’ compensation benefits or similar. Employees who exhaust their vacation leave and sick leave will be paid in accordance with applicable law. Payment of Vacation When an Employee uses vacation leave, it is paid to the Employee at the Employee’s base rate of pay. It does not include overtime or any special forms of compensation such as incentives, commissions, or bonuses. Vacation leave is not counted as hours worked for the purposes of calculating overtime. Carryover of Vacation Intercoastal Mortgage management firmly believes that periodic vacations from work are necessary for the health and well-being of its Employees. Unused vacation leave may be carried over from the previous year up to 80 hours. Employees may not accrue or use more than 200 hours per calendar year. Vacation at Termination Employees with one (1) year or more of service who separate from employment for any reason will be paid up to 80 hours of unused vacation leave with their final paycheck. Once an Employee provides the Company with notice of his or her decision to resign from employment, the Employee may not use vacation leave during their notice period. Sick Leave Eligibility All Employees are eligible for paid annual sick leave immediately upon hire. Intercoastal Mortgage complies with applicable sick and safe leave laws in the various states and localities in which it operates. To the extent that those state and or local laws grant greater rights to Employees than this Policy, those greater rights will apply. Reasons for Use Intercoastal Mortgage provides eligible Employees with paid sick leave each calendar year to use for the following reasons: • To care for or treat the Employee’s mental or physical illness, injury, or condition;

21 • To obtain preventative medical care for the Employee or the Employee’s family member; • To care for a family member with a mental or physical illness, injury, or condition; • If the employer’s place of business has closed by order of a public official due to a public health emergency; • If the school or childcare center for the Employee’s family member is closed by order of a public official due to a public health emergency; • For the birth of a child or for the placement of a child with the Employee for adoption or foster care; • To care for a newborn, newly adopted, or newly placed child within one year for a newborn or adoption or placement; • To care for a family member if a health official or health care provider has determined that the family member’s presence in the community would jeopardize the health of others because of the family member’s exposure to a communicable disease; • The absence from work is necessary due to domestic violence, sexual assault, or stalking committed against the Employee or the Employee’s family member and the leave is being used: (1) to obtain medical or mental health attention; (2) to obtain services from a victim services organization; (3) for legal services or proceedings; or (4) because the Employee has temporarily relocated as a result of the domestic violence, sexual assault, or stalking; or • Bereavement, if paid leave under the Company’s Bereavement Leave Policy has been exhausted. Sick Leave Grant Intercoastal Mortgage provides eligible Employees paid sick leave benefits on January 1 of each year for periods of temporary absence due to illness, injury, or medical appointments. Eligible full-time Employees receive 60 hours of sick leave the beginning of each calendar year. Eligible part-time Employees grant will be based on the Employee’s regular scheduled hours in a work week and will receive a grant of at least one (1) hour of sick leave for every 30 hours scheduled to work. New hires will receive sick leave based on their hire date. The amount of sick leave for a new Employee is prorated according to date of hire in the calendar year. Use and Scheduling of Sick Leave Employees who are unable to report to work due to illness or injury should notify their direct supervisor before the scheduled start of their workday if possible. The direct supervisor must also be contacted on each additional day of absence. Employees may also elect to deduct time from their accrued sick leave for medical/dental appointments. Intercoastal Mortgage requests that you provide reasonable advance notice of your need to use sick leave of at least seven (7) days before the date the Employee intends to use the leave. If the need to use leave is not foreseeable, the Employee must provide notice as soon as practicable. Intercoastal Mortgage may request a physician’s certification from the Employee for absences lasting more than three (3) consecutive workdays. Payment of Sick Leave Sick leave is paid to the Employee at the Employee’s base rate of pay. It does not include overtime or any special forms of compensation such as incentives, commissions, or bonuses. Sick leave is not counted as hours worked for the purposes of calculating overtime. Sick leave may be taken in 15-minute increments for illness or related appointments of the team member. When an Employee uses sick leave for the entire workday, the Employee must input sick hours according to his or her regularly scheduled workday. For example, if an Employee works a six (6) hour day, he/she would submit six (6) hours of sick leave when taking that day as a sick day. When an Employee plans to use sick leave for a partial workday, the working hours and sick hours used may not exceed a total of 8 hours in any given workday. Carryover of Sick Leave Up to 40 hours of unused sick leave will be carried over from year to year. A maximum of 100 hours of sick leave is available for use in any one year. Sick Leave at Termination Sick leave will not be paid out upon separation or termination from the Company unless required by applicable state law.

22 Bereavement/Funeral Bereavement/Funeral leave of up to five (5) days with pay may be requested by all eligible Employees. Full-time and part-time regular Employees are eligible. These benefits are payable in the event of a death in your immediate family (spouse, child, parent, brother, sister, grandparent, grandchild, or similar relationships created by marriage or adoption). Up to three (3) days with pay may be requested in the event of a death related to other family members such as an aunt, uncle, niece, or nephew. In the case of a death of someone other than immediate family members, time off with pay may be granted to attend the funeral, subject to supervisory approval. Bereavement leave must be taken within 90 days of the date of death. Exceptions can be made with manager and Human Resource approval. If you need additional time off, you must first request and obtain approval from your supervisor/manager and you will be required to use available granted, unused Vacation or Sick Leave. During a leave under this Policy, your pay will be based on the number of hours you were regularly scheduled to work on the day(s) that you are on leave. Employees may be required to provide documentation regarding their Bereavement/Funeral leave request. Jury Duty ICM, LLC encourages Employees to fulfill their civic responsibilities by serving jury duty when required. Regular full-time Employees may request up to five (5) days of paid jury duty leave during any one-year period. Jury duty pay will be calculated on the Employee’s base pay rate times the number of hours the Employee would otherwise have worked on the day of absence. If non-exempt Employees are required to serve jury duty beyond the period of paid jury duty leave, they may, but are not required to use any available vacation time. Exempt Employees will be paid their full salary for any week in which they perform authorized work for the Company. Employees must provide a copy of the jury duty summons to their supervisor as soon as possible so that the supervisor may plan to accommodate their absence. An Employee will not be required, on a day in which the individual is summoned and appears for jury duty for four or more hours, including traveling time, to work an employment shift that begins: (1) on or after 5:00 p.m. on the day of the Employee’s appearance for jury duty; or (2) before 3:00 a.m. on the day following the Employee’s appearance for jury duty. Otherwise, an Employee is required to return to work for the remainder of the workday if he or she is released from jury duty. Employees will not be discharged solely because of job time lost by the Employee as a result of responding to a summons for jury duty, or as a result of attending court for service or prospective service as a petit or grand juror. Holidays ICM, LLC offers regular full-time and part-time non-sales Employees paid holiday time to cover a variety of occasions. Each year, the holiday schedule will be announced. If you wish to observe a holiday not included on the schedule, you may use your vacation days. Non-exempt Employees are eligible for holiday pay if the holiday falls on a regularly scheduled workday. The hours of holiday pay will reflect the number of hours that you are normally scheduled to work for that day. If you are non-exempt and are required to work on a holiday, you will be paid at your regular rate for hours worked in addition to the holiday pay. School Visitation Leave Any Employee, who is a parent, guardian, or person standing in loco parentis of a school aged child, is entitled to four (4) hours of leave per year to attend or otherwise be involved in that child’s school. Leave under this Policy is subject to the following conditions: • The Company and the Employee must mutually agree on the time for the leave; • The Employee must provide the Company with at least forty-eight (48) hours’ notice prior to the need for leave; and • The Employee must submit written verification from the school that she/he attended or was otherwise involved at that school during the time of the leave. The leave is unpaid; however, Employees may substitute any paid leave available for the time away from work due to the leave. Exempt Employees will be paid in accordance with applicable law. Witness Duty Leave ICM, LLC will grant you a leave if you are subpoenaed to appear as a witness in a civil or criminal proceeding, or if you are required to attend a criminal or juvenile proceeding as a victim or the victim’s representative. You are not required

23 to use available granted vacation time for such leave, but you may choose to do so. Witness Duty leave for non-exempt Employees will otherwise be unpaid. Exempt Employees will be paid in accordance with applicable law. Employees will not be discharged solely because of job time lost by the Employee as a result of the Employee’s response to a subpoena requiring the Employee to appear as a witness in any civil or criminal proceeding, including discovery proceedings. Crime Victim’s Leave In compliance with states’ laws, when an Employee has been identified by local law enforcement authorities as a “victim” of a crime, ICM, LLC will grant unpaid leave of absence from work to permit the Employee to attend criminal proceedings relating to the crime, unless the leave will create an undue hardship on the ICM, LLC operations. For purposes of this Policy, a “crime” means a felony or assault, stalking, sexual battery, maiming, or DUI. A “victim” may include not only the specific individual who has suffered harm as the result of a crime, but also that person’s spouse or child, parent, or legal guardian (where the victim is a minor), and spouse, parent, sibling, or legal guardian, where the victim is incapacitated or deceased. “Criminal proceeding” applies not only to a criminal trial, but to other judicial proceedings, such as the initial appearance of the suspect, any proceeding in which a negotiated plea is presented to the court, any sentencing proceeding, and all proceedings relating to probation. An Employee taking leave under this Policy must provide ICM, LLC with a copy of a form which he or she receives from the police after being identified as the victim of a crime, and a copy of notices the Employee receives of each scheduled criminal proceeding. Voting Time During any election, any Employee who is a registered voter and who does not have two (2) hours of continuous off-duty time to vote while the polls are open will be allowed a period of up to two (2) hours in which to arrive late to work or leave work early to vote on Election Day. ICM, LLC will pay you for this two (2) hour absence, if you furnish ICM, LLC with proof that you voted. Military Leave If you are called to active military duty or enlist in the uniformed services, you are eligible for unpaid military leave of absence in accordance with state and federal law. Present your supervisor with a copy of your service papers as soon as you receive them. To be eligible for military leave, you must provide your supervisor and Human Resources with advance notice of your service obligations unless you are prevented from providing such notice by military necessity or it is otherwise impossible or unreasonable for you to provide such notice. During your absence, your length of service accumulates, and your benefits will continue as required by applicable law. Provided your absence does not exceed applicable statutory limitations, you will retain reemployment rights and accrue seniority and benefits in accordance with applicable federal and state laws. If you are required to attend yearly Reserves or National Guard duty, you may apply for an unpaid temporary military leave of absence not to exceed the number of days allowed by law (including travel). However, if you prefer, you may use your granted vacation for this purpose. You should give your supervisor as much advance notice as possible so we can ensure proper coverage while you are away. Please ask your supervisor or Human Resources for further information about your eligibility for Military Leave. Leave for Deployment of Family Member in the Armed Forces ICM, LLC will provide eligible Employees with one (1) day of unpaid leave on the day that an immediate family member is leaving for or returning from active military duty out-side the United States as a member of the armed forces. An “eligible” Employee is one who has worked for the Company for the last 12 months and has worked at least 1,250 hours during that time. An “immediate family member” means the Employee’s spouse, parent, stepparent, child, stepchild, or sibling. Employees may, but are not required to, use granted vacation during this one-day leave of absence. If the Employee also is eligible for leave under FMLA, then the day of leave also may qualify as, and will run concurrently with, FMLA leave. Organ or Bone Marrow Donor Leave ICM, LLC will grant eligible Employees: (a) up to 60 days of unpaid leave in any 12-month period to serve as an organ donor; and (b) up to 30 days of unpaid leave in any 12-month period to serve as a bone marrow donor.

24 An Employee is eligible if he or she has worked for ICM, LLC for at least 12 months and at least 1,250 hours during the previous 12-month period. Leave under this Policy will not be counted as leave under the FMLA Policy. To receive organ or bone marrow donation leave, the Employee must provide a written physician verification to the Company stating that: (a) the Employee is an organ donor or a bone marrow donor; and (b) there is a medical necessity for the donation of the organ or bone marrow. Benefits During Leave Any leave granted under this Policy will not be considered a break in continuous service for the purpose of salary adjustments, paid time off, or seniority. The Company will maintain continued coverage under its group health plan for the full duration of the leave (provided that the Employee is enrolled in such a plan) on the same basis as coverage would have been provided had the Employee been working during that time. Employees are required to use any available accrued sick or vacation leave during their leave. Return to Work Upon expiration of leave, the Employee shall be restored to his or her previous position, or an equivalent position, although the Company reserves the right to decline to restore the Employee to their previous position or an equivalent position because of conditions unrelated to the Employee’s exercise of their leave rights under this Policy. Disaster Relief Volunteer Leave ICM, LLC will provide eligible Employees with leave for emergency volunteer activities. To be eligible for leave, an Employee must be participating in an activity of a civil air patrol, civil defense, volunteer fire department, or volunteer rescue squad. An eligible Employee must submit written proof that his or her participation in an emergency declared by the governor on the request of a county or municipal corporation was required. ICM, LLC will not discharge an Employee for participation in an activity of civil air patrol, civil defense, volunteer fire department, or volunteer rescue squad if the activity was in response to an emergency declared by the governor on the request of a county or municipal corporation. VI. Workplace Standards General Standards of Conduct Because it is impossible to define in detail every standard of conduct for every circumstance, the Company expects that, in most cases, your common sense will guide you as to proper workplace conduct. If you have any questions about our standards of conduct, or about what to do or not to do in a situation, please contact your manager or consult Human Resources. When Employee misconduct occurs, the approach we take to discipline may vary depending on, among other things, the gravity of the offense, circumstances under which it occurred, job duties, length of service and work record, including any prior misconduct. In order of severity, corrective action can take one or more of the following forms: verbal counseling, written warning, suspension, or termination of employment. Keep in mind that the Company has no obligation to use any one or more of these forms of corrective action prior to discharging an Employee. Any or all of these steps can be omitted as the Company deems appropriate, in its sole and exclusive discretion. By establishing this corrective action procedure, the Company is not relinquishing or limiting its managerial right to discharge for any or no reason at all, at any time, with or without notice. As expressed in this Handbook, employment with Intercoastal Mortgage is on an “at will” basis. The use of progressive discipline is NOT a pre-condition to termination; rather, it is discretionary, in the Company’s judgment. The Company’s decision in every case is final and binding on all concerned, including the disciplined Employee and all other persons or entities involved in any way, directly or indirectly. If you do receive the benefit of any of these methods of constructive counseling, however, the Company urges you to take advantage of the opportunity to learn and improve. To avoid discipline, up to and including termination from employment, follow common sense guidelines, and do not commit offenses including, but not limited to, the following:

25 • Theft, embezzlement, or participation in criminal activity; • Falsification of Company or customer documents; • Engaging in or provoking any act of violence or damaging Company property or the property of another; • A violation of the Company’s EEO Policy and/or Policy Against Harassment; • A violation of the Drug & Alcohol-Free Workplace Policy; • Possession of weapons of any kind at work or on Company property, unless prohibition is restricted by applicable law; • A violation of any Company Policy; • Poor performance; • Failure to fulfill job responsibilities to the extent it might or does cause injury to a person, or cause substantial damage or loss to Company equipment, facilities, or cash; • Making a false, fraudulent, misleading, or harmful statement, action or omission involving another Employee or customer of the Company; or falsification of hours worked; or • Violation of the Workplace Violence Prevention Policy. Attendance and Punctuality The efficient operation of the Company depends upon the regular attendance and punctuality of its Employees. Regular attendance and punctuality are an essential part of an Employee’s job and overall performance. This Policy is designed to allow needed time off for absences as circumstances arise. It is not designed to allow perpetual and/or excessive absence or tardiness. Employees who establish such patterns will be subject to disciplinary action, up to and including termination. Employees should schedule all personal appointments so as not to interfere with the Employee’s work schedule, to the extent possible. Proper Call-In Procedure Employees must notify their immediate supervisor or manager as soon as they are aware they cannot report to work as scheduled. Employees should speak directly with their immediate supervisor or manager. If the supervisor or manager is unavailable, Employees should leave a message with their name, number, reason for absence, return to work date and time as well as their contact number for the supervisor. A doctor’s note may be required for an illness that necessitates an absence of three (3) or more days. Falsifying the reason for an absence will be grounds for termination. In some situations, such as approved Family and Medical Leave, an Employee may not be required to call in each time they are absent. Employees will be notified if they are not required to call-in each workday they cannot report to work as scheduled. Employees who fail to follow this call-in procedure will be subjected to discipline, up to and including discharge. Job Abandonment If the Employee is absent three (3) consecutive workdays without reporting to a supervisor or manager, the Employee will be considered to have voluntarily terminated their employment without notice. Excused Absences Generally, absences for the following reasons are excused: • Absence in accordance with an approved leave of absence; • Approved family and medical leave of absence or leave of absence pursuant to a similar paid or unpaid state leave law; • Approved absence in accordance with leave provided as an accommodation under federal or state disability laws; • Leave provided under certain state leave laws; • Approved absences related to a work-related injury; • Approved Vacation, Sick Leave, and Holiday Pay; • Approved Bereavement Leave;

26 • Approved Jury Duty Leave; • Approved Military Leave; • Approved Voting Leave; • Approved Organ and Bone Marrow Donor Leave; or • Approved Disaster Relief Volunteer Leave. Unexcused Absences Excessive absences or tardiness and leaving early for any reason other than the reasons stated above will be unexcused and may serve as the basis for disciplinary action, up to and including termination of employment. Other reasons an absence may be unexcused include but are not limited to: questionable reason(s) for an absence; failure to provide valid documentation of the tardiness or absence such as healthcare provider note, etc.; or the Employee is on previous disciplinary action for tardiness, attendance, performance, or related work reasons. Intercoastal Mortgage is committed to complying with applicable laws providing you a legal right to be absent from or late to work. All aspects of this Attendance Policy will be interpreted and applied to ensure compliance with these laws. Specifically, any unscheduled absence, tardiness or other incident that is protected by federal, state, or local law will NOT count against an Employee under these attendance guidelines or otherwise including, for example, absences for jury duty, military duty, or when provided as a reasonable accommodation related to a disability or a sincerely held religious belief and for other excused reasons as listed in this Policy. If you believe an absence, lateness, or leave early is entitled to legal protection, please notify Human Resources in writing within five (5) business days of the absence, lateness or leave early. Personal Appearance and Business Casual Guidelines Although we want to establish a Company-wide image of good taste and professionalism, standards of dress may vary depending on the work environment of the department and/or the nature of the job. Your manager will establish and enforce, in conjunction with Human Resources, the appropriate standards of dress for your department. Business Casual Guidelines All casual clothing is not suitable for the office; these guidelines will help you determine what is appropriate to wear to work as your attire needs to be suitable for the workplace. Although the Company allows a business casual dress code, casual clothing that you might wear to the beach, the gym, dance clubs or to run errands, is not suitable for the business casual workplace. You are the first impression that someone receives of Intercoastal Mortgage, and you want your attire to reflect a clean, polished, professional appearance. In a business casual environment, wrinkled, torn, dirty or frayed and tattered clothing is unacceptable. Clothing that has words, terms, or pictures that may be in violation of the Company’s EEO and/or Policy Against Harassment or related Policies is unacceptable. When you are with a customer, how you behave, and dress is a reflection on Intercoastal Mortgage. Your neat and pleasant appearance all contribute to our customer’s image of the Company. It is your responsibility to make this image a positive one. The Employee’s manager will establish and enforce, in conjunction with Human Resources, the appropriate standards of dress for your department. If clothing fails to meet these standards, as determined by the Employee’s supervisor and Human Resources staff, the Employee will be asked not to wear the inappropriate item to work again. If the problem persists, the Employee may be sent home to change clothes and may be subject to discipline, up to and including termination from employment. Social Media Policy Intercoastal Mortgage recognizes that social networking (such as personal websites, blogs, Facebook, YouTube, Twitter, Instagram, LinkedIn, online discussion groups, message boards, chat rooms, etc.) on social media are used by most of our Employees. The Company respects the right of our Employees to maintain a blog or post a comment on social networking sites. Considering the nature of our business there are also risks for violations of federal and/or state laws governing sensitive personally identifiable information such as an individual’s name combined with financial

27 information, which could cause harm to an individual if compromised or disclosed, whenever anyone posts any information which may be prohibited by law. Please make sure you are aware of your obligations in this regard. To protect the Company’s interests and ensure Employees focus on their job duties, Employees must adhere to the following rules: • Employees may not post on a blog or social networking site during their working time. Working time includes the time during which any of the Employees involved are scheduled to work, but does not include scheduled rest periods, meal breaks and other specified times when Employees are not expected to be working. This rule does not apply to production/sales Employees who are utilizing social media for marketing purposes; • If an Employee mentions Intercoastal Mortgage on any social networking site and expresses either a political opinion or an opinion regarding the Company’s actions, the communication must include a disclaimer that the views expressed are those of the author and do not necessarily reflect the views of Intercoastal Mortgage. This is necessary to preserve the Company’s goodwill in the marketplace; • Any conduct which is impermissible under the law if expressed in any other form or forum is impermissible if expressed through a social networking site. For example, posted material relating to Intercoastal Mortgage and its Employees that is discriminatory, defamatory, libelous, or threatening is not permitted. Company policies prohibiting discrimination, retaliation, and/or harassment based on any Protected Characteristic as well as the Workplace Violence Prevention Policy apply equally to Employee comments concerning Intercoastal Mortgage, and its Employees on social networking sites, even if done on nonworking time. Employees are encouraged to review those sections of the Handbook for further guidance; and • Employees are prohibited from misappropriating or using without permission Intercoastal Mortgage’s corporate logo and intellectual property on any social networking site or other online forum for commercial purposes. Employees are reminded that there are civil and criminal penalties for posting copyrighted material without authorization. Any Employees who violate this Policy may be subject to disciplinary action, up to and including termination. The Company reserves the right to monitor all public blogs and social networking forums for the purpose of protecting its interests and maintaining compliance with this Policy. For additional information about social media and the workplace, please refer to our Information Security Systems Policy and our Social Media Policy in the Federal Policy Manual. If you have any questions regarding this Policy, please contact Human Resources. Employee Network Usage Policy The following Policy addresses Employees’ use of all computers, software, networks, e-mail, text messaging, instant messaging, internet, online services, voicemail, facsimile machines, video cameras used in the workplace for purposes of safety and security of our facilities, and any and all other similar electronic devices, and the tools used for their access (all referred to as “Electronic Systems”). Use of Company Electronic Systems to commit infractions and/or violations of Company policies such as misuse of Company assets or resources, sexual harassment, unauthorized public speaking and misappropriation or theft of intellectual property is also prohibited and may be grounds for discipline, up to and including termination. Ownership of Information and No Expectation of Privacy The Electronic Systems are established, maintained, owned, and provided by the Company for Employees to run the Company’s business operations efficiently and effectively. The messages and information sent/retrieved/stored via the Company’s Electronic Systems are at all times the property of the Company and at all times subject to its review without prior notification of, or permission by, the individual user. To this end, please be reminded that if any Employee saves personal information to the Company’s Electronic Systems, which is discouraged, they will not have access to this data when their employment with the Company ends. No Company information or data should be actively saved outside of Company systems and devices. The Company has software and systems in place that can monitor internet usage and site visits, as necessary. Please be reminded that the systems belong to the Company and Employees have no right of privacy with Company systems, to include access to personal information saved on our system. Electronic systems are in place for business purposes and should be used accordingly. Abuse of electronic systems for non-business reasons may lead to disciplinary action up to and including termination.

28 Appropriate and Inappropriate Use The display of any kind of sexually explicit image or document on any Electronic Systems is a violation of our Policy against harassment. In addition, sexually explicit material may not be archived, stored, distributed, edited, or recorded using our network or computing resources. The Company uses independently supplied software and data to identify inappropriate or sexually explicit internet sites. We may block access from within our networks to all such sites that we know of. If an Employee finds themselves connected incidentally to a site that contains sexually explicit or offensive material, they must disconnect from that site immediately regardless of whether that site had been previously deemed acceptable by any screening or rating program. The Company’s Electronic Systems must not be used to knowingly violate the laws and regulations of the United States, or the laws and regulations of any state, city, province, or other local jurisdiction in any material way. Use of any Company resources for illegal activity is grounds for immediate dismissal, and we will cooperate with any legitimate law enforcement activity. Any software or files downloaded via the internet, or otherwise, onto the Company network become the property of the Company. Any such files or software may be used only in ways that are consistent with their licenses or copyrights. No Employee may use Company systems to knowingly download or distribute pirated software or data. No Employee may use the Electronic Systems to deliberately propagate any virus, worm, Trojan horse, or trap-door program code. No Employee may use the Company’s Electronic Systems to knowingly disable or overload any computer system or network, or to circumvent any system intended to protect the privacy or security of another user. The use of Company e-mail servers to broadcast bulk e-mail is strictly prohibited as such activity will impair the efficient functioning of our systems. Contact the IT Department for all e-mail broadcast needs. For more information on Employee’s obligations to our Electronic Systems, please refer to our Information Security Systems Policy, located in the Federal Policy Manual. Solicitation and Distribution At Intercoastal Mortgage, we believe Employees should not be disturbed or disrupted in the performance of their job duties. For this reason, solicitation of any kind by one Employee to another Employee is prohibited while either person is on working time. Working time includes the time during which any of the Employees involved are scheduled to work, but does not include scheduled rest periods, meal breaks and other specified times when Employees are not expected to be working. Solicitation by non-Employees on Company premises is always prohibited. Distribution of advertising material, handbills, or printed or written literature of any kind in working areas is always prohibited. Distribution of literature by non-Employees on Company premises is prohibited at all times. Neither this Policy nor anything in this Handbook is intended to unlawfully restrict an Employee’s right to engage in any of the rights protected by Section 7 of the National Labor Relations Act, including, but not limited to, the right to engage in concerted protected activity for the purposes of mutual aid and/or protection. Searches of Company and Employee Property To ensure that our job sites are free from contraband drugs, weapons and other unauthorized and/or illegal substances or materials, and to protect Company Employees, files, information, equipment, products, materials, substances, and other property, Intercoastal Mortgage reserves the right, at our discretion, to question, inspect, and search any Employee or other person before they enter or leave any Company location. This Policy also applies to any Employees on Company business, whether on our job sites, premises, and other facilities. Any such search may be made by authorized Company personnel and/or our agents. Any search can include a search of any packages or other items that the individual may be carrying, have in his or her possession, or have brought onto our premises or work sites, and any vehicles, lockers, containers, briefcases, handbags, desks, business equipment including telephones, laptop computers and other electronic equipment, and any parcels and personal belongings that are on Company premises. Desks and/or lockers always remain the property of the Company. For security reasons, desks, cabinets, and lockers may be inspected periodically, without notice, as a condition of employment. The Company cannot be responsible for

29 theft and damage to property placed in desks, cabinets, or lockers. We strongly discourage storing money, jewelry, or other valuable items in them. If you resign or otherwise terminate employment, your belongings will be removed from your workspace and any unclaimed items remaining after termination may be removed and donated to a charitable institution of the Company’s choice or otherwise disposed. Employees have no expectation of privacy when using the Company’s network or resources. These procedures are necessary for the safety, health, and security of everyone at the Company and the protection of our property and facilities. Submission to and compliance with these rules is a condition of your continued employment. Non-Disclosure of Confidential Business Information As part of your responsibilities at ICM, LLC, you may learn of or be entrusted with sensitive information of a confidential nature. During your employment, any information, including, but not limited to, customer lists, customer account and financial information, customer habits, customer preferences; computer processes, programs, and codes; marketing methods, programs, or related data; tax records; or accounting procedures (collectively referred to as “Confidential Business Information”), will be considered and kept as the private and confidential records of the Company. Confidential Business Information may only be used in performing work for ICM, LLC and must be divulged to any firm, individual, or institution except on the direct written authorization of the Chief Executive Officer. Your failure to honor this confidentiality requirement may result in disciplinary action, up to and including termination. If you leave employment with ICM, LLC for any reason, you will remain subject to this Policy. As such, you must continue to treat as private and privileged any such sensitive information after your employment with ICM, LLC ends. ICM, LLC will pursue legal remedies for unauthorized use or disclosure of sensitive, confidential information. VII. Safety and Security Background Investigations Intercoastal Mortgage reserves the right to complete a background investigation on all applicants who are offered employment. Employees also agree that the Company may conduct background checks of Employees for legitimate business reasons, for example, consideration of an Employee for a promotional opportunity or other legitimate business reason. Failure to authorize the release of information for the investigation will withdraw a candidate from consideration for employment. The Company complies with federal and state laws governing background checks. General Safety Your safety, and that of those who work with you, is one of our greatest concerns. With an alert safety attitude, you can help eliminate painful and costly accidents. You can help by: • Keeping work areas clean and clear; • Reporting hazards or unsafe conditions to your supervisor; • Smoking ONLY in designated outside areas; • Reporting all injuries, however minor, to Human Resources and your manager immediately; • Walking and not running in buildings; • Keeping aisles clear; and • Never performing a job that you feel is unsafe. Report such situations to your supervisor immediately. Accidents on Company Property Any accident that occurs on Company property, be it that of a customer, guest, or Employee, should be reported immediately to Human Resources and your supervisor. For your own safety and the safety of our guests, please do not attempt to give medial aid to an injured guest or fellow Employee unless you have been trained to do so. Seek the assistance of a supervisor and call 911 if warranted. In addition, please remember that only Human Resources can

30 answer questions about the Company’s liability to injured customers or guests. Please direct those asking questions to Human Resources. If an Employee is injured on the job, they may be entitled to workers’ compensation benefits. If you are injured while working, please report it immediately to Human Resources and your supervisor, no matter how minor the injury may be. Failure to timely report workplace injuries or illnesses may result in a denial of workers’ compensation benefits. Inclement Weather and Emergency Policy When bad weather conditions or other emergency situations arise, you are expected to make every effort to report to work. In the event of inclement weather or an emergency, ICM, LLC will operate under normal business hours unless communicated otherwise via email. Should the Company be open, and you are unable to report to work either in person or remotely, you must notify your supervisor in accordance with the Proper Call-In Procedure and, if an Employee has unused vacation leave, the Employee will be required to use it. Non-exempt Employees who have used all their paid leave balances may use a day without pay. Exempt Employees will be paid in accordance with applicable law. Employees should call their supervisor if there is any question regarding the weather or other emergencies that may affect the status of ICM, LLC. VIII. If You Leave Notice If you decide to resign from ICM, LLC for any reason, the Company requests that you provide your supervisor and Human Resources at least a two-week notice in writing. Return of Company Property Upon your departure from ICM, LLC you are required to return all Company property including, but not limited to, Company issued computer equipment, access card/keys, parking passes, and any other items belonging to the Company. Remote Employees will be provided with boxes and pre-paid shipping labels to facilitate the return of Company property. Final Pay Your final paycheck will be paid via the normal payroll cycle less applicable statutory withholdings and any benefit enrollment deductions. If you are eligible for commissions or incentives, you may receive a final commission or incentive paycheck after your last regular pay has been issued in accordance with our commission payment process. IX. Remote Work Policy Overview and Policy Statement Intercoastal Mortgage LLC, (“Intercoastal” or “Company”) allows approved Employees to work remotely so long as all of the requirements within the Remote Work Policy are consistently met. Remote working can also be referred to as working from home, working remotely, and teleworking. Remote work may be appropriate for some Employees and job roles, but not for others. Remote working is not guaranteed, it is not a companywide benefit, and in no way changes the terms and conditions of employment with Intercoastal. Intercoastal has the right to refuse to make remote work available and can terminate the ability to work remotely at any time. Failure to follow this policy could result in the inability to work remotely and/or possible disciplinary action and/or termination of employment. All conditions of the Remote Work Policy apply to Employees that are approved for either remote work or hybrid remote work. Remote Employees spend more than 50% of their time at the remote work location. Hybrid Employees have an assigned physical office or workplace and combine elements of both remote work and traditional office-based work and, working remote 50% or less of the time.

31 Intercoastal adopts this Policy to ensure compliance with state and federal requirements. Licensed activities from a remote location shall be permitted when under the supervision of Intercoastal and when all of the following apply: • Access to company platforms and customer information shall be in accordance with Intercostal’s comprehensive written Information Security Policy, Privacy and Safeguarding Information Policy, and Acceptable Use Policy. • No in-person customer interaction will occur at an Employee’s residence unless such residence is a licensed location, and • Physical records shall not be maintained at a remote location. Intercoastal recognizes the benefit remote work has for its Employees’ overall job satisfaction. The ability to remote work can positively impact the balance between work responsibilities and life. Intercoastal strives to remain agile by providing a remote working program that allows for flexibility for its Employees to work remotely as well as in person. Face-to-face collaboration between teams will always remain a strong part of Intercoastal’s culture. The purpose of this policy is to establish: 1. Eligibility for remote work arrangements. 2. Eligibility of a location for remote work 3. General expectations and conditions for remote working arrangements. 4. Procedure for reporting policy violations 1. Eligibility for Working Remotely Employees requesting remote work arrangements must be employed with Intercoastal and have a satisfactory performance record. A remote work arrangement is not applicable to all positions within the organization and is not a guaranteed benefit. Before entering into any remote work arrangement, the Employee and their supervisor, with the assistance of the Human Resource Department, will evaluate the suitability of a remote work arrangement, reviewing the following areas: • Job responsibilities: The Employee and supervisor will review job responsibilities and determine if the Employee can successfully complete the responsibilities while working remotely. • Department standards: Review whether the department can support the team members’ remote working arrangement without affecting the services provided and quality and/or quantity of work produced. • Employee suitability: The Employee has consistently demonstrated performance that consistently meets or exceeds performance expectations, and the supervisor is confident the Employee can sustain the same level of performance while remote working. • Tax and other legal implications: The Employee must determine any tax or legal implications under IRS, state, and local government laws, and/or restrictions of working out of a home-based office. Responsibility for fulfilling all obligations in this area rests solely with the Employee. Requests for remote work should not be considered when: • The Employee’s current responsibilities require frequent in person supervision. • The Employee’s current responsibilities require regular in-person collaboration with other employees. • The Employee’s performance evaluations indicate improvement is required or they are currently on a Performance Improvement Plan or have attendance related issues. Human Resources must be notified immediately of remote working approvals as well as any changes to an Employees physical working location to ensure compliance with workers’ compensation insurance policy and state tax implications. 2. Remote Location and Safety The Employee shall designate a workspace within a remote location for the placement and installation of equipment to be used while remote working. The Employee shall maintain this workspace in a safe condition, free from hazards and other dangers to the Employee and equipment. The Employee is responsible for correcting any safety deficiencies at the remote location in a timely manner at their own expense.

32 Intercoastal has the right to make on-site visits (with 48 hours advance notice) to the remote work location for purposes of determining that the site is safe and free from hazards, and to maintain, repair, inspect, or retrieve company-owned equipment, software, data, or supplies. By working remotely, the Employee confirms that their workspace has been inspected and conforms to all of Intercoastal’s safe workplace standards as outlined below: GENERAL • Floors are clear and free of hazards • Work area is reasonably quiet and free of distractions • File drawers are not top heavy • Phone lines and electrical cords are secured under a desk or along the wall, away from heat sources • Temperature, ventilation, and lighting are adequate • First aid supplies are readily available FIRE SAFETY • Walkways, aisles, and doorways are unobstructed • Working smoke detector covering the designated work space • Charged, accessible fire extinguisher in area • More than one exit from work area • Workspace is kept free of trash, clutter, and flammable liquids • All radiators and portable heaters are located away from flammable items ELECTRICAL SAFETY • Computer equipment is connected to a surge protector • Electrical system is adequate for office equipment • All electrical plugs, cords, outlets and panels are in good condition--no exposed/damaged wiring • Extension cords and power strips are not daisy chained and no permanent extension cord is in use • Electrical cords run in non-traffic areas, do not run under rugs, and are not nailed or stapled in place • Equipment is turned off when not in use • Electrical outlets are grounded with three-pronged plugs WORKSTATION ERGONOMICS • Office furniture and equipment are ergonomically correct • Chair is sturdy, adjustable and provides adequate back support • When keying, forearms are close to parallel with the floor • Monitor is 20-24 inches from eyes, and top of screen is slightly below eye level • Feet reach the floor when seated or are fully supported by a footrest • Computer screen is free from noticeable glare • Workstation has adequate lighting OTHER SAFETY/SECURITY MEASURES • Files and data are secure • Company equipment and materials are in a secure place that can be protected from damage or misuse during and after working hours Injuries sustained by the Employee in remote location and in conjunction with their regular work duties during work hours are normally covered by Intercoastal’s workers’ compensation policy. Employees are responsible for notifying their supervisor of any injuries as soon as possible.

33 3. General Expectations and Conditions All systems and applications used for business purposes must be accessed from Company provided or approved device or virtual network. It is imperative that all Employees access all systems with security measures in place that are in practice in our office environments. Please reference Intercoastal’s Information Security Policy, Privacy and Safeguarding Information Policy, and Acceptable Use Policy for more information on Intercoastal’s security policies and controls. Due to the risks in the industry that we are in, consumer and internal Employee security measures are our top priority. Working remotely can put consumers information and our own internal security in a higher risk category if this policy is not followed. Our goal is to provide the same level of security whether Employees are working in an Intercoastal office or remotely. A. Employee Accessibility All Employees working remotely should have a reliable phone number for all external contacts and internal Employees to reach them. If using a personal cell phone for a contact number, please be sure this is included in your company email signature as well as with NMLS, if applicable. All Employees working remotely must have access to Intercostal’s provided email account as well as phone service provider. B. Compliance with Policies All Employees with a remote work arrangement are expected to abide by all Intercoastal Mortgage policies and procedures at any location where work is performed. Employees working remotely agree to do so under the supervision and in compliance with Intercoastal’s written policies and procedures subject to the following conditions: • Consumer interactions and conversations about consumers will follow federal and state information security requirements, including applicable provisions under the Gramm-Leach-Bliley Act and the Safeguards Rule established under the Federal Trade Commission. • Employees working remote must access Intercoastal’s secure systems (including cloud-based systems) directly from company issued or company approved devices (laptop, mobile device, desktop computer, tablet, etc.). • Intercoastal ensures that appropriate security updates, patches, or other alterations to the security of all devices used at Remote Locations are installed and maintained. • Intercoastal has the ability to remotely lock or erase company-related contents of any device or otherwise remotely limit all access to a company’s secure systems. • Intercoastal may certify periodically that Employees engaging in remote activity meet the appropriate standards and safeguards to continue such activity. C. Reliable Internet Speeds and Connectivity All Employees working remotely or from home must have a constant and reliable internet connection from where they are working. Any connectivity issues that impact productivity must be reported to your supervisor immediately. D. Hours Worked and Compensation Intercoastal Employees working remotely are required to work their normal hours in a normal business day, unless Intercoastal is closed due to holidays. All time worked by non-exempt Employees must be logged into the designated time reporting software accordingly. If an Employee is to take a lunch break, they are required to let their direct supervisor know when they will be unavailable, and that time offline must be represented on their timesheet. Any overtime worked or paid time off should be approved by the Employee’s direct supervisor. The Employee’s compensation, benefits, work status and work responsibilities will not change due to participation in the remote working program. The amount of time the Employee is expected to work per day or pay period will not change because of participation in the remote working program.

34 The Employee’s remote work hours will conform to a schedule agreed upon by the Employee and his or her supervisor. If such a schedule has not been agreed upon, the Employee’s work hours will be assumed to be the same as before the Employee began working. Non-Exempt and hourly Employees who are approved for remote work are not exempt from the overtime requirements of the Fair Labor Standards Act and will be required to accurately record all hours worked using Intercoastal’s ADP Employee Portal. Overtime hours worked require the advance approval of the Employee’s supervisor. It will be the Employee’s responsibility to determine any income tax implications of maintaining a home office area. Intercoastal will not provide tax guidance, nor will Intercoastal assume any additional tax liabilities. Employees are encouraged to consult with a qualified tax professional to discuss income tax implications. E. Mortgage Loan Originator Activity All Intercoastal originators have specific requirements per each state’s law allowing or not allowing originators to work with consumers at office locations or public institutions. Please ensure that if you are meeting with a consumer in person that meeting is at an authorized and approved office location is always the best option as the network and security settings and controls are more effective at one of Intercoastal’s office locations. If meeting at a public place, please ensure that you follow this policy and all security-related company policies, strictly. Any event that occurs in violation of this policy must be reported to your supervisor and escalated to Intercoastal’s IT Team and Compliance Officer accordingly. Please reference this link with up to date and accessible state guidance on remote work policies throughout the United States: https://www.mba.org/advocacy-and-policy/residential-policy-issues/remote-work-policies It is Intercoastal’s expectation that all licensed Employees are aware and educated on any and all state and federal laws. If you are a licensed originator, it is your responsibility to ensure you are following the state laws as they change. Intercoastal will monitor these and provide communications as they are made aware of any changes impacting state licensure. F. Dependent Care Remote working is not intended to serve as a substitute for child or adult care. If children or adults in need of primary care are in the same alternate work location during the Employees’ work hours, another person must be present to provide care. 4. Reporting Violations Reports of incidents or violations of this policy should be made to Human Resources. If the violation applies to security violations, support@lenderworks.net should be contacted immediately to determine mitigation and remediation.

35 X. Employee Handbook Acknowledgement I have been provided digital access to Intercoastal Mortgage, LLC’s Employee Handbook. I understand that my employment with Intercoastal Mortgage, LLC is for an unspecified term and may be terminated at the will of either the Company or myself, with or without reason or cause, and with or without notice. No words or actions of the Company will be deemed to create an express or implied contract of employment or require the Company to have good cause for terminating my employment. No Company representative is empowered or authorized to modify this at-will relationship, on an individual or collective basis, other than the President. I acknowledge I have received a copy of the Intercoastal Mortgage, LLC’s Employee Handbook. I understand I am responsible for reading and understanding the contents of the Employee Handbook. I further acknowledge that I have read the Employee Handbook in its entirety in accordance with this responsibility. I understand that any rules, policies, and benefits described in the Employee Handbook may be modified or varied from by the Company at any time—except as required by law and except for the rights of the parties to terminate employment at will (which may be modified, on an individual or collective basis, only by an express written agreement signed by the President of the Company). NOTE: Employees are required to acknowledge receipt of the Employee Handbook via the ADP Policy acknowledgement protocol.

36 XI. Appendix A – Federal Family and Medical Leave Notice