Compliance Overview OVERVIEW By properly selecting and maintaining Compliance Codes in CMiC, Swinerton can ensure subcontract payments are not released until the subcontractor has provided all necessary documentation and/or fulfilled all requirements. Compliance Codes in CMiC include various insurance requirements, contractual and non-contractual requirements and manual Project Manager holds. If applicable, the codes can be designated as date sensitive for items that expire such as insurance certificates. If a code is date sensitive, subcontract payments are automatically placed on hold once the expiration date has passed. Compliance requirements for jobs will be determined based on 1) Company policy and 2) The requirements specific to a particular job. Compliance will be managed at the subcontract (commitment) level in CMiC. For subcontracts managed in Textura, the compliance information will be managed in CMiC and will export to Textura daily. All compliance data will be maintained in CMiC. Compliance Setup CMiC offers the ability to assign Compliance Codes automatically to all subcontracts entered into CMiC or at the job level if a job has specific requirements. This will reduce the administrative burden of manually selecting the appropriate Compliance Codes for each subcontract. Compliance Codes can be flagged to default as compliant or to require dates to track expiration dates. Compliance Codes can also be assigned to a subcontract on the fly as needed. Only items listed on the LOV or drop down menu can be selected. Subcontract Level – Certain Compliance Codes are automatically assigned to ALL subcontracts entered in CMiC. As of January 2017, the codes in the table below are automatically assigned once a subcontract is entered into CMiC. These codes are required by Risk Management and should not be removed without proper authorization. PMHOLD should NEVER be removed from the subcontract. This code is required for PMHOLD to work via workflow. Subcontract Level – Codes BUSLIC (Business License) and CONTLICBRD (Contractor's License Board) are automatically assigned only to jobs located in certain regions. If these codes default onto your job, they must be used per legal requirements. Subcontract Level – Code DIRREG# (DIR Registration # of Public Works) is automatically assigned to jobs if Public Works Project = YES on the User Defined Fields tab of Opportunity Management. Subcontract Level – Code CERTPR (Certified Payroll) is automatically assigned to jobs if Prevailing Wage Project = YES on the User Defined Fields tab of Opportunity Management. List of all Codes that are auto-assigned to all commitments Code Description Date Sensitive Default Compl. CLOSEOUTDS Closeout Documentation Date Sensitive Y Y COMMSIGN Commitment Signed N N PMHOLD PM Hold N Y SAFEMANUAL Safety Manual (IIPP) N N WRAPUP Wrap Up Enrollment Completed N N Job Level – If all subcontracts for a specific job have a code that is required and not automatically assigned at a global level, the Financial Manager (at the job level) has the ability to add any other compliance codes and automatically assign them to all subcontracts on the job. Other available codes – The following codes can be selected at the subcontract level as needed. The insurance related codes would be used for jobs that are not enrolled in a WRAP program. Other non-insurance codes can be used as needed. NOTE - List of all available codes is attached below. Compliance Maintenance Once the appropriate Compliance Codes have been added to the subcontract, compliance can be edited as needed. Depending on the region, compliance will be updated by the Project Administrator or the Job Accountant. Project Administrators will access compliance in CMiC via JSP, Subcontract, Compliance. Other Project Team members will have view access to this screen. Project Managers will have access to update PMHOLD. Job Accountants will access compliance via Enterprise, Subcontract Management, Status, Change Compliance Status. From either location, Compliance Codes can be added or deleted. Dates can be updated for Date Sensitive items. Once the subcontract is posted, any updated information will export to Textura during the following integration run. If the subcontract has Compliance Codes that are not marked as compliant, as in the examples above, a payment will not be released against this subcontract until all items are compliant. Compliance on the Voucher Compliance is also attached to the voucher as shown above. Changes to Compliance on the subcontract (above) must be properly performed in order for the compliance hold on the voucher to hold and release holds properly. Please see Compliance Training Guides for details.

As a Project Administrator, How do I Manage Compliance on the Project? OVERVIEW This document provides the steps necessary to manage compliance in CMiC’s Project Management module and is intended for Project Administrators responsible for maintaining compliance. It is important to understand the compliance process in CMiC to ensure subcontractor’s payments are being held and released appropriately in Textura and CMiC. Items to note: • CMiC a. There is a separate compliance table that is attached to the vouchers in CMiC. Voucher compliance is updated based on the information entered in the subcontract compliance screen. Please read the steps below in detail so you understand how the two compliance tables work together. b. On expiring certification, do not update the Start Date. After the initial certification is received and the Start Date is entered, only the End Date should be updated on expired documents. c. For date sensitive codes to be compliant, both the compliant box and the Date Complaint box must be checked. • Textura a, Once a subcontract is posted, ‘In Process’, compliance exports to Textura on a daily basis.  b. Do not enter Start Dates and End Dates for Compliance Codes that are not Date Sensitive in CMiC. This creates an issue with the Project Requirement Setup in Textura and places incorrect holds. c. If a Compliance Code is deleted from a subcontract in CMiC after the subcontract was exported to Textura, you must contact the job accountant to manually delete the requirement from Textura. Locating Subcontract Compliance  STEP 1: Select the job.  STEP 2: Select Budget & Cost Management on the tree view. STEP 3: Click the Subcontract link. STEP 4: Click on the desired Subcontract. STEP 5: Click Compliance. Compliance screen will pop up and can be updated as needed.  Understanding the Compliance Screen 1) Date Sensitive – If a code is setup to track expiration dates, the Date Sensitive box will be checked when you click on the line. 2) Start Date and End Date – If a code is Date Sensitive, a Start Date and End Date is required. Do not enter dates for non-date sensitive items. 3) Date Compl. – The system will check this box if the code is date compliant meaning the ‘As of Date’ falls between the Start Date and the End Date. This box cannot be updated by the user. 4) Compl. – When a requirement is met, the user must check this box to make the code compliant. NOTE: For a date sensitive code to be compliant both Date Compl. and Compl. box must be checked.  5) Insurance – This field is not used. 6) Cert. Num., Cert. Location and Amount – These fields are optional and can be used for tracking insurance information. 7) Documents and Notes – These fields are optional and can be used as needed. You cannot upload documents. If Documents or Notes exists, an * will be shown on the tab when you click on a line. 8) Action – Click + to add additional Compliance Codes. Click X to delete codes. 9) Update – Checking this box updates vouchers posted in CMiC for this subcontract and applies the changes. If this box is not checked, compliance attached to any unpaid vouchers will not be updated. Compliance Codes Automatically Assigned to Subcontracts Risk Management requires certain compliance codes be added to all subcontracts entered in CMiC. These codes are set up in CMiC to automatically assign to a subcontract when the subcontract is created. These codes can vary based on the region the job is located in. Some codes such as PMHOLD and SCOSIGN default as being compliant. If a code is Date Sensitive, the date the subcontract was created will default as the Start Date and End Date. Additional codes can be added as needed. See separate section for process. Compliance Codes Assigned to Subcontracts – Job Specific If subcontracts for a specific job have a code that is required and not automatically assigned at a global level as detailed above, the Financial Manager (at the job level) has the ability to add any other compliance codes and automatically assign them to all subcontracts on the job. This can also be done for a job already in process. The Financial Manager can add a Compliance Code at the job level and have the code added to all subcontracts for the job.

Adding and Deleting Compliance Codes on a Subcontract in Project Management Adding Compliance Codes to Subcontract Select the subcontract. See Locating Subcontract Compliance above. STEP 1: Click (+) to add another line for a new compliance requirement. STEP 2: System automatically checks the Update button when adding a new Compliance Code. This will add the requirement to any unposted vouchers in the system. STEP 3: Click on the Compliance Code drop down for the LOV. STEP 4: Select the code you want to add by clicking on the Code or using the Find option to search. If you have received the requirement information for the code you are adding, you can complete the information at this time. STEP 5: NOTE: The Compliance Code added in this example is Date Sensitive so Start Date and End Date must be entered. If you have not received the insurance certification, enter the current date in both fields. Do not use Start Date and End Date of requirements that are not Date Sensitive. STEP 6: The system automatically checks the Date Compl. box because the system views the requirement as being compliant for the day. STEP 7: The Compl. box is not checked so the requirement will hold payment. For a date sensitive requirement to be compliant, both boxes must be checked. STEP 8: You can add additional requirements if you need to or Click Save. If the requirement has not been met at the time you add the code to the subcontract, you can update the record at a later time. See Updating Compliance. STEP 9: Once you've modified the compliance and saved it, a pop up box will appear asking you to update existing records, click OK. Deleting Compliance Codes from a Subcontract If a compliance code was added to a subcontract in error, it can be deleted from the subcontract. Note: If the subcontract has been posted “In Process” and has exported to Textura, the job accountant will need to be notified so they can manually remove the compliance code from the subcontract and/or the Project Requirements in Textura. Deleting a code in CMiC does not remove the code from Textura. Do not delete PMHOLD. PMHOLD must remain on the subcontract for an image in Workflow to be placed on PMHOLD. Select the subcontract. See Locating Subcontract Compliance above.  STEP 1: Click the X. STEP 2: Confirm this is the requirement you want to remove and click OK. If you have selected this in error, click Cancel. STEP 3: Click Save. STEP 4: You will receive a message asking if you would like to delete the compliance code from all vouchers. If you do not want this requirement to hold payment on any unpaid vouchers in the system, click Yes. Note: If you click No, the compliance code will remain on the voucher compliance. If No was click in error or it is decided later it needs to be removed from the voucher, the job accountant must go into compliance in Accounts Payable and manually remove the code.  STEP 5: Click Close.

Updating Compliance on a Subcontract in CMiC Project Management Select the subcontract. See Locating Subcontract Compliance above.    Updating Non-Date Sensitive Compliance Codes This is how to update the Compliance Code when the requirement has been met. **** DO NOT USE START and END DATES on non-date sensitive codes**** STEP 1: Click on the line you want to update. It will turn blue. STEP 2: Click Compl. STEP 3: Click Update. This will remove the hold from any unpaid vouchers in CMiC. If Update is not clicked, the voucher will remain on hold. See Resolving Discrepancies between Compliance on Subcontract and Compliance of Vouchers.  STEP 4: Click Save. STEP 5: Click Close. Updating Date Sensitive Compliance Codes Updating Compliance when initial certification is received. STEP 1: Click on the line to be updated.  It will turn blue. STEP 2: Start Date - Enter the effective date of the certification into the Start Date field. This field should only be entered when the initial requirement is met. When a certification has expired and a new certification has been received, only the End Date should be updated. See Updating Compliance for Expired Certifications.  STEP 3: End Date - Enter the expiration date of the certification. Once this date passes, any vouchers will be placed on hold. STEP 4: Date Compl. Since the ‘As of Date’ falls between the Start Date and the End Date, CMiC has automatically checked this box. STEP 5: Compl. – Click the box. STEP 6: Update – Click the box to update compliance attached to vouchers. Prior to saving, any additional updates can also be made at this time. STEP 7: Click Save, STEP 8: Click Close. Updating Compliance for Expired Certificates STEP 1: Click on the line to be updated.  It will turn blue. STEP 2: Start Date – Do not update this field unless this is the initial certification received for this requirement. Updating the Start Date with the new effective date of the certification will place any unpaid vouchers with an invoice date prior to the new effective date on hold.  STEP 3: End Date - Enter the expiration date of the certification. Once this date passes, any vouchers will be placed on hold. STEP 4: Date Compl. Since the ‘As of Date’ falls between the Start Date and the End Date, CMiC has automatically checked this box. STEP 5: Compl. – Click the box. STEP 6: Update – Click the box to update compliance attached to vouchers. NOTE: Prior to saving, any additional updates can also be made at this time. STEP 7: Click Save. STEP 8: Click Close.

Viewing the Compliance Log in CMiC Project Management The Compliance Log gives you a summary view of all compliance for the project.  STEP 1: Select the job.  STEP 2: Click on Budget & Cost Management on the tree view. STEP 3: Click the Compliance Log link. To sort the log, click on the Heading you would like to sort by. This information can also be exported to Excel by clicking Export.

Resolving Discrepancies between Compliance on Subcontract and Compliance on Vouchers Below are examples of instances where a voucher is on compliance hold but the compliance attached to the subcontract shows the sub is compliant. 1. Enterprise > Subcontract Management > Status > Change Compliance Status 2. Enter Vendor & Job numbers (change Company if not 010) 3. Go to the Contract tab 4. Click Compliance 5. Open up the compliance section from within the Subcontract • Date Issue Compliance on subcontract shows compliant. Voucher is on compliance hold because the Invoice Date of the voucher was 08/01/2013, prior to the Start Date. The BUSLIC Start Date was updated. The Start Date should not have need updated when the business license expired. Resolution: Change the Start Date on the subcontract compliance to reflect the initial start date. If Update is click, the voucher will update and hold will be removed.    • Changed to Compliance on Subcontract did not update Compliance on the Voucher Compliance item was updated on subcontract compliance Resolution: Go back into the subcontract compliance, click Update Vouchers and Save.

Contractor's License Board (CONTLICBRD) Compliance Code - Requirements By State   See below for the list of states, and whether the Contractor's License Compliance Code (CONTLICBRD) is required. State CONTLICBRD Assigned? Alabama YES Alaska YES Arizona YES Arkansas YES California YES Colorado NO Connecticut YES Delaware YES Florida YES Georgia YES Hawaii YES Idaho YES Illinois NO Indiana NO Iowa YES Kansas NO Kentucky NO Louisiana YES Maine NO Maryland NO Massachusetts NO Michigan NO Minnesota NO Mississippi YES Missouri NO Montana YES Nebraska YES Nevada YES New Hampshire NO New Jersey NO New Mexico YES New York NO North Carolina YES North Dakota YES Ohio NO Oklahoma NO Oregon YES Pennsylvania NO Rhode Island YES South Carolina YES South Dakota NO Tennessee YES Texas NO Utah YES Vermont NO Virginia YES Washington YES West Virginia YES Wisconsin NO Wyoming NO                                                                                                                                                                                                

CARB (California Air Resources Board) Off-Road Certification Tracking at the Business Partner Level WHY: According to the California Code of Regulations Title 13, Section 2449 (the “Regulation”), subdivisions (i) & (j), prime contractors are required to obtain copies of valid “Certificates of Reported Compliance” from all subcontractors operating self-propelled off-road diesel-fueled vehicles horsepower 25 or greater used in California and most two-engine vehicles. This requirement applies to vehicles that are owned, rented, or leased. For this reason, Swinerton requires that its subcontractors either (a) submit a valid Certificate of Reported Compliance regarding its vehicles that are subject to the Regulation, or (b) provide a statement that subcontractor does not operate any vehicles that are subject to the Regulation. For more information about the Regulation or to obtain a Certificate of Reported Compliance, please visit the following California Air Resources Board website: https://ww2.arb.ca.gov/our-work/programs/use-road-diesel-fueled-fleets-regulation. The enforcing agency may require an inspection and inspection reports in accordance with CA requirements, both during and at completion of construction to demonstrate substantial conformance. How the Log Works: The log is filtered for all Business Partners (BPs) that have an office in California so that everyone can see who has their certificate and who does not. If you are going to email a BP, please make sure to put your name in the "Swinerton Reviewer" field so that the subs don't get bombarded. We are currently NOT holding payment for this Certificate, please DO NOT add it to your commitment's Compliance Tab in CMiC. When/If that changes in the future, we will let you know. How To Add to CMiC: NOTE: For each new certificate, please insert a new row and add all information including new Start/Expiration Date. If you are the one chasing a new cert but don't have it yet, please put your name in the Swinerton Reviewer field and make a note of the day you sent the email to the vendor so that everyone knows the current status. STEP 1: Open Budget & Cost Management STEP 2: Click the CARB Off Road Certificates (CA Only) log STEP 3: Find the Business Partner (BP) you are looking for (See Notes on Filtering), and highlight the number and copy it STEP 4: Click on Business Partner Request STEP 5: Paste the BP# into the "Find" Box STEP 6: Click Go STEP 7: Click on the Edit icon for the BP STEP 8: Click the Classification Tab STEP 9: Click Insert STEP 10: Click the magnifying glass STEP 11: Double Click the Code "CARBEQUIP" STEP 12: Click the magnifying glass STEP 13: Double Click the Code "CARB" STEP 14: Enter the Certificate # STEP 15: Enter the Start Date STEP 16: Enter the Expiration Date STEP 17: Enter the name of the person that will now track for this BP STEP 18: Click Save STEP 19: Click Attachments STEP 20: Either Drag and Drop the Document or Choose the File from your computer (Naming convention = BP Name_BP Number_CARB Cert. Number_Expiration Year) STEP 21: Click Ok STEP 22: Click Save Filtering by Date: Email to be sent to subcontractors: Dear (Name): Swinerton has been asked to start collecting a new Compliance item for the California Air Resources Board, see below. We are working together to make sure you only have to submit this item once a year for all projects in California. According to the California Code of Regulations, Title 13, Section 2449 (the “Regulation”), subdivisions (i) & (J), prime contractors are required to obtain copies of valid “Certificates of Reported Compliance” from all subcontractors operating self-propelled off-road diesel-fueled vehicles horsepower 25 or greater used in California and most two-engine vehicles. This requirement applies to vehicles that are owned, rented, or leased. For this reason, Swinerton requires its subcontractors either: (1) submit a valid Certificate of Reported Compliance regarding its vehicles that are subject to the regulation, or (2) provide a statement that the subcontractor does not operate any vehicles that are subject to the Regulation. Please submit the document for whichever item number above your company falls under. For more information about this Regulation or to obtain a Certificate of Reported Compliance, please visit the following California Air Resources Board website: https://ww2.arb.ca.gov/our-work/programs/use-road-diesel-fueled-fleets-regulation. If you have any questions, please feel free to reach out. Thank you, BTECH NOTE: CHN-4266 Go Live 2/10/2025