COVID-19 PREPAREDNESS PLAN AND

STANDARD OPERATING PROCEDURES

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Legends is committed to providing a safe and healthy workplace for all our workers and customers. Based on the COVID-19
pandemic, Legends has provided suggestions for its workspace and the guest experience to allow for a safe and enjoyable
environment based on risk assessments of our workers’ duties, customers’ exposures, and the overall impact of the
pandemic. The risk assessments are based on the hierarchy of controls – elimination, substitution, engineering controls,
administrative controls, and personal protective equipment. In conjunction with recommendations from local, state, and
federal authorities, Legends has developed additional policies and procedures to add to its existing high standard personal
safety and food safety programs so that guests and workers are safe. Additional details for the activities listed below
should be customized for each client and venue, and the approval process should be with the venue’s leadership team and
the Legends Health Support team. Federal, state, and local requirements also need to be incorporated to ensure
compliance with those regulations. Managers and workers are all responsible for implementing this plan, and all workers
are responsible for using safe work practices, following all directives, policies, and procedures, and assisting in maintaining
a safe work environment using these Standard Operating Procedures in conjunction with other Legends Policies and
Procedures (including but not limited to Legends Injury and Illness Prevention Program and Legends COVID-19 Vaccination,
Testing, and Face Covering Policy). No worker can be discriminated against or terminated for raising any reasonable
concern about infection control related to COVID-19.

ASSESSING THE WORKSPACE

The workspace needs to be set up for safety success based on the current risks of the COVID-19 pandemic. Email
[email protected] if there is outside need to evaluate new potential workplace exposures that were not
addressed at the earlier stages of the pandemic.

• If no employee has been in the workspace for more than four weeks, complete a personal safety audit to
determine if any weather, maintenance, and theft damage occurred in order to confirm all safety standards are
in place.
• Confirm that the workspace has been cleaned with approved disinfectant products.
• Order, stock, and set up hygiene stations.
o Review high touch surfaces and determine if equipment should be replaced with no-touch options
• Create a venue-specific checklist to list high touch surfaces and designate an employee to confirm that those
surfaces are cleaned per the SOPs below.
• Meet with the client and/or the building to determine which party is handling certain cleaning activities, how
the ventilation system will be maintained and adjusted, how people are entering the building, where shared
sanitize stations will be located, and what PPE and/or activities will be mandatory for workers and guests.
• Provide a communication to returning workers that provides an overview of the procedures in your location.
These SOPs will provide additional safety details.
• Train all returning workers on COVID-19 policies and procedures.

WORKER HEALTH (IN CONJUNCTION WITH GOVERNMENT DIRECTION)

Workers who exhibit COVID-19 symptoms or have been recently exposed to COVID-19 cases are not allowed to work
within the venue until they are determined to be able to return safely to work. All workers are encouraged to self-
monitor for signs and symptoms of COVID-19 and report these signs and symptoms to their respective manager if they are
scheduled to work. Managers must reach out to temporary worker agencies and non-profit organizations to inform them
about their requirements in following these SOPs.

• All new workers must affirm Legends’ existing policies and procedures and affirm the new COVID-19 policies
and procedures before returning to the venue.
• Every workday, each worker should be asked if s/he is experiencing COVID-19 symptoms and if s/he has
interacted with anyone who has a case of COVID-19. Symptoms of COVID-19 include, but are not limited to
coughing, shortness of breath, and fever. The following questions can be assessed by a designated manager
(any deviation from asking these questions may lead to claims of discrimination, harassment, and/or a
HIPPA/ADA violation):

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 o Have you exhibited any symptoms related to COVID-19 and/or food borne illnesses in the last twenty-
four (24) hours? Symptoms include, but are not limited to:
▪ Coughing
▪ Shortness of breath or difficulty breathing
▪ Chills
▪ Repeated shaking with chills
▪ Muscle or body aches
▪ Headache
▪ Sore throat
▪ Loss of taste or smell
▪ Congestion or runny nose
▪ Diarrhea or nausea
▪ Fever
o Have you tested positive for COVID-19 in the last ten (10) days?
o In the last ten (10) days, have you come in close contact with a person who has a confirmed case of
COVID-19 and/or suspected case of COVID-19, which could include but is not limited someone who is
under self-quarantine or required to be self-quarantined? Close contact is defined as a person who
was within 6 feet of an infected person for a cumulative total of fifteen (15) minutes or more over a 24-
hour period starting from two (2) days before illness onset (or, for asymptomatic patients, two (2) days
prior to test specimen collection) until the time the patient is isolated.
o If a worker answers yes to exhibiting one or more of those symptoms, then the worker cannot work
and must be sent home. The situation must be reported through Origami Risk’s COVID-19 Incident
Form.
o If a worker answers yes to having COVID-19, then the worker cannot work and must be sent home.
The situation must be reported through Origami Risk’s COVID-19 Incident Form.
o If a worker answers yes to coming into contact with a person who has a confirmed or suspected case of
COVID-19, then the situation must be reported through Origami Risk’s COVID-19 Incident Form to
determine when the worker is eligible to return to work. The Centers for Disease Control and
Prevention (CDC) guidelines and/or state, local, or client requirements will be taken into account when
determining the length of quarantine and masking requirements. For COVID-19 testing needs, the local
HR representative, Legends General Manager, and/or the [email protected] team will be
able to provide Legends workers with nearby COVID-19 testing locations. 1
o If a worker is dishonest or untruthful about his/her response(s) to the above questions, the worker may
face discipline up to and including immediate termination.
• If available, survey the workers twenty-four (24) hours prior to their scheduled work shift to assist in staffing
scheduling.
• All workers may be tested with a non-invasive thermometer by a designated person. Anyone displaying a
temperature at or above 100.4°F will be taken to a private area for a secondary temperature screening. If the
second test reveals that the worker has a temperature at or above 100.4°F, then the worker cannot work and
must be sent home.
o Those workers who display a temperature at or above 100.4°F to degrees will be allowed a ten (10)
minute normalization period prior to their temperature being re-checked. They must wait away from
the primary screening area and in the shade.
o If the worker then displays a temperature of below 100.4°F degrees, the worker will be permitted into
the venue.

1
In California workplace locations, employees who had a close contact are offered COVID-19 testing at no cost during their working
hours, except for COVID-19 cases who were allowed to return to work per our return-to-work criteria and have remained free of
symptoms for 90 days after the initial onset of symptoms, or for cases who never developed symptoms, for 90 days after the first
positive test. If a COVID-19 outbreak, as defined under the California law, occurs, periodic (at least weekly or twice per week depending
on the magnitude of the outbreak) COVID-19 testing will be available to all employees in the exposed workplace.
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 o If the worker still shows a temperature above 100.4°F after the ten (10) minute normalization process,
the worker will be denied entry into the venue and will be instructed to contact his/her manager and
his/her human resources representative.
o The thermometer will be disinfected any time it comes in direct, or close, contact with a person.
o Temperature records of each worker shall be stored separately from any personnel or contract folders.
In no case shall their actual temperatures be recorded. The temperature records would be noted that
the worker passed or failed the temperature requirement.
• If a worker has traveled internationally to a Level 2, Level 3 ,or Level 4 country, per the CDC
(https://www.cdc.gov/coronavirus/2019-ncov/travelers/map-and-travel-notices.html), then that worker must
self-quarantine for per the latest guidance from the CDC before the worker returns to the job location.
Depending on the worker’s vaccination status, a quarantine may not be necessary.
• Some states/cities have specific travel restrictions. If the job location is in a state/city with a travel restriction,
those restrictions must be followed. If someone is unsure how to interpret those local travel restrictions,
please email [email protected].
• Some clients/buildings have specific travel restrictions. All workers must follow the specific travel restrictions
of the client/building before entering the location.
• All Legends vendors and subcontractors are also required to determine if their workers meet the above
standards.
• Contact tracing is the process of identifying, assessing, and notifying people who have been exposed to a
disease to prevent onward transmission. When in a work location, all Legends Employees must maintain
awareness of who they were in “close contact” with on a daily basis.
• If a manager learns that a worker/vendor/subcontractor has a suspected or confirmed COVID-19 case,
complete the COVID-19 Incident form in Origami Risk for additional handling and support.
o The manager will need to determine what areas the worker visited, used, and/or impacted.
o The manager will also need to identify workers who were in close contact (within about six (6) feet for
fifteen (15) minutes or more) with a person with a confirmed or suspected case of COVID-19 from the
period 48 hours before symptom started to the time at which the worker isolated.
o The manager will work with the Legends Health Support to notify workers of any potential exposures
within one (1) business day (and work with the client, if applicable, to notify any other employer who
has potentially exposed employees in the workplace). This notice will be provided to all employees
(and their authorized representative), independent contractors, and other employers on the premises
at the same worksite as the COVID-19 case during the high-risk exposure period.2
• In case a worker has a confirmed case or suspected case of COVID-19 and comes into the workspace,
o Close off the areas where the worker visited as best as possible;
o If available, open outside doors and windows and use ventilations fans to circulate air in the area;
o Wait at least twenty-four (24) hours, or as long as practical, before disinfecting and cleaning the
affected areas; and
o Disinfect and clean all shared areas such as offices, bathrooms, break rooms, shared electronic
equipment, etc. used by the worker.
• In the case of a worker who was diagnosed with COVID-19, the individual may return to work based on the CDC
guidelines and/or state, local, or client requirements and that at least 24 hours have passed since the
resolution of symptoms.
• In the case of worker who has symptoms that could be COVID-19 and does not get evaluated by a medical
professional or tested for COVID-19, the individual is assumed to have COVID-19, and the individual may not
return to work until the individual has completed the same above.
• If the worker has symptoms that could be COVID-19 and wants to return to work before completing the above
self-isolation period, the individual must obtain a medical professional’s note clearing the individual for return
based on an alternative diagnosis.

2
These notifications will meet the requirements of California requirements – T8CCR section 3205(c)(3)(B) and Labor Code
section 6409.6(a)(4); (a)(2); and (c).
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 • If an employee is requesting an accommodation under the Americans with Disabilities Act (ADA) because
his/her disability results in a fever, his/her disability results in the inability to wear a face covering, or s/he has a
safe work environment concern, reach out to the local human resources representative, Director of Benefits
Tracey Scott, and/or [email protected]. Each case will have to be analyze separately to determine if
a requested accommodation constitutes undue hardship on the company. Employees with disabilities that put
them at a high risk for complications of COVID-19 may request telework as a reasonable accommodation.
• All health records will be kept in a separate file and not mixed with an employee’s personnel file. Any
employee handling health records will complete designated training in order to protect the privacy of workers’
health status and health information.

PHYSICAL DISTANCING
• The Centers for Disease Control and Prevention (CDC) reported COVID-19 is thought to spread mainly through
close contact from person to person, including between people who are physically near each other (within
about 6 feet). Per the CDC’s recommendations, Legends will enact physical distancing procedures by assessing
and arranging workstations and customers spaces to allow for at least six (6) feet between individuals
whenever possible. The CDC has announced that fully vaccinated people (people are considered fully
vaccinated: two (2) weeks after their second dose in a 2-dose series, such as the Pfizer or Moderna vaccines, or
two (2) weeks after a single-dose vaccine, such as Johnson & Johnson’s Janssen vaccine), do not have to
physical distance. Consider removing furniture to allow for easier ingress and egress. Physical distancing can
be supported by decreasing the personal items and inventory in workspaces and staggering worker shifts.
Employee applicants are encouraged to apply for positions online and sign up for a designated time to appear
at a job fair or interview.
o In place of in-person interviews, online services, such as Microsoft Teams or Zoom can be used to
conduct interviews.
• The worker check-in process can be extended to allow for more staggered shifts.
o Workers are encouraged to bring as few personal items into the venue as possible. Ideally, their
personal items should all fit into one gallon-sized bag.
o If uniforms are distributed at the venue, workers must follow defined lines and waiting areas.
o If worker lockers are available, available lockers should be clearly marked to allow for physical
distancing. All lockers must be cleaned and disinfected at the end of every shift.
o If worker meals are still offered at the venue, those mealtimes should also be extended and staggered.
Meals should be individually packed for each work or served by serving attendants.
o All workers should wear approved uniforms to and from work whenever possible, with the exception of
the Culinary Team, in order to avoid congestion in locker rooms.
• Trainings are encouraged to be available online with a short quiz at the end for proof of knowledge retention.
Any in-person training sessions are recommended to be in smaller groups in a space that allows for physical
distancing.
• Try to eliminate handshaking. Refer to Legends Customer Service team information for alternative suggestions.
• Where possible, any indoor spaces should be limited to one (1) person per thirty-six (36) square feet until
physical distancing rules are removed. Capacities may need adjusting based on furniture layout.
• Assess each workstation to determine where workers can stand while allowing for at least six (6) feet of
distance between another worker.
o Review the spatial plan with workers during their pre-shift/departmental meetings.
o Determine if tape would help workers stay within their designated workstations.
o Redesign or retool the workspaces, if possible, so employees are not sitting at adjacent desks and not
sharing offices.
o Look for interior doors that can be left open to avoid contact by multiple people.
o Determine if floor markings should be used to encourage one-way traffic flow.
o Consider using staggered workdays/weeks to prevent too many people in a work area.

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 o Try to avoid sharing an office at the same time. Use staggered workdays so both workers are not in the
office at the same time or develop a daily calendar of when workers will share the space without being
in the office at the same time. Post this calendar on the door for easy reference.
o Empty offices should not be used as an available temporary workplace for any employee. If an empty
office must be used, someone (either the employee or designated cleaning person) must clean and
disinfect the office before leaving it.
o Continue to follow Legends’ Injury and Illness Prevention Plan so that even when there is a smaller
workforce on site, a manager/supervisor needs to regularly check workers who are alone in their
workstations.
• Workers should not congregate in small areas, such as offices, if they are able to avoid it.
• If possible, moveable barriers, such as plexiglass partitions, should be erected between the guest and the
worker.
• Use fans to increase the effectiveness of open windows. To safely achieve this, fan placement is important and
will vary based on room configuration. Avoid placing fans in a way that could potentially cause contaminated
air to flow directly from one person over another. One helpful strategy is to use a window fan, placed safely
and securely in a window, to exhaust room air to the outdoors. This will help draw fresh air into room via other
open windows and doors without generating strong room air currents.
• Consider employing a line manager to encourage customers to stand six (6) feet apart. Other considerations
can include:
o Having a decrease in open point of sale (POS) options and re-deploy workers to be line managers.
o Using floor decals and/or stanchions/signage as markers and to help clarify where the customers lines
are.
o Moving POSs to allow for longer lines with spacing.
o Remembering people in the same family may be in line together, which may require the floor
decals/signage to have an increased distance to maintain six (6) feet between groups of customers.
• Use game/event day notes to avoid long pre-shift meetings so Close Contact between workers would not
occur.
• Try to avoid eating and drinking in break rooms. Eating and drinking can be done at a desk or in a person’s
vehicle.
o Workers should not eat and drink within a shared small office space, such as a chefs’ office or
warehouse office.
o If workers are getting outside food for meals at work, delivery and carry-out are the best options.
• Conference calls using Microsoft Teams is encouraged.
• Try to limit the number of people for an in-person meetings.
• Each elevator should be assessed to determine how many people/equipment can be accommodated in the
elevator while providing for reasonable physical distancing.
• To avoid extra handling and to decrease employees at the venue, employees are encouraged to use direct
deposit or cash cards.

PROTECTIVE EQUIPMENT

• Legends requires all employees who are not fully vaccinated to wear a face covering. Face coverings must:
o completely cover the nose and mouth;
o be made with two or more layers of a breathable fabric that is tightly woven (i.e., fabrics that do not let
light pass through when held up to a light source);3
o be secured to the head with ties, ear loops, or elastic bands that go behind the head. If gaiters are worn,
they should have two layers of fabric or be folded to make two layers;
o fit snugly over the nose, mouth, and chin with no large gaps on the outside of the face; and

3
Los Angeles County venues must offer KN 95 or N 95 masks to employees.
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 o be a solid piece of material without slits, exhalation valves, visible holes, punctures, or other openings.
• Acceptable face coverings include clear face coverings or cloth face coverings with a clear plastic panel that, despite
the non-cloth material allowing light to pass through, otherwise meet these criteria and which may be used to
facilitate communication with people who are deaf or hard-of-hearing or others who need to see a speaker’s
mouth or facial expressions to understand speech or sign language respectively.
• Gina Kreisher and John Barbarino will be able to assist in face covering procurement. Please remember to provide
as much lead time as possible so there will be enough PPE supplies available in case of a delay in shipments.
• Face coverings can help protect people near the wearer, but do not replace the need for physical distancing and
frequent handwashing.
• Face coverings must be cleaned or replaced after use or when damaged or soiled, may not be shared if they are
single-use coverings, and should be properly stored or discarded.
• Due to heat concerns, plan for additional breaks that will be needed for workers. If available, have an area where
workers can physically distance and remove their face coverings during their breaks to help them cool down. For
break areas, consider unused concession stands, suites, and prep rooms.
• If face coverings become wet (especially from sweat), replace the wet face covering with a new clean dry face
covering.
• Face coverings cannot include inflammatory markings, designs, or language, but instead must be professional.
• Employees who are not fully vaccinated must wear face coverings over the nose and mouth when
o indoors and
o occupying a vehicle with another person for work purposes.
• The following are exceptions to Legends’ requirements for face coverings:
o When an employee is alone in a room with floor to ceiling walls and a closed door.
o For a limited time, while an employee is eating or drinking at the workplace or for identification purposes in
compliance with safety and security requirements.

HANDWASHING
Going beyond Legends’ existing handwashing procedures, all food and beverage workers are encouraged to wash their
hands every thirty (30) minutes for at least twenty (20) seconds each time. All Legends workers are encouraged to wash
their hands the beginning and end of their workdays, but at a minimum must sanitize their hands with hand sanitizer that
has at least 60% alcohol upon entering the building.

• Stand supervisors or designated office employees are responsible for handwashing stations to be set up so that
workers can easily wash their hands. They also should store an extra supply of handwashing station needs
inside their location or nearby for easy access. Check to make sure there is enough
o Paper towels,
o Soap,
o Hot water,
o Waste cans,
o Hand washing signage, and
o Keys to open the paper towel dispenser, if applicable.
• If the restrooms are not under the control of Legends, find who the building contact is in case these required
items are missing. Inform the team who they can contact so that all necessary supplies are available.
• To bring an increased awareness hand washing, food and beverage workers (including suites and banquet
servers) are encouraged to wash their hands every thirty (30) minutes in addition to their regular handwashing
per food safety policies and procedures.
o Stand supervisors can use a timer for every thirty (30) minutes in each work area (such as each kitchen
and concession stand) and have workers wash their hands each time the timer rings.
o To avoid lines at hand washing sinks,
▪ Break each work area into smaller groups,
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 ▪ Assign hand washing sinks that each smaller group will use, and
▪ Give them numbers to order themselves on who will wash their hands first, second, third, etc.
o Stand supervisors in each work area would be responsible for confirming each person is following this
increased handwashing.
o Workers at portables should be included in the thirty (30) minute hand washing break
▪ Can provide a portable hand washing sink, if available
▪ Can work with the venue to determine where hand sanitizer dispensers are best placed for
guests and workers
• If a person just applied hand sanitizer to his/her hands, that person cannot be near an open flame or ignition
site (stove, candles, electrical switches, etc.) until the hand sanitizer dries. Because of the initial vapors the
hand sanitizer produces as it dries, a person could catch on fire.

CLEANING, SANITIZING, AND DISINFECTING

The CDC has also reported that when respiratory droplets land on surfaces and objects, it is possible that a person could get
COVID-19 by touching a surface or object that has the virus on it and then touching their own mouth, nose, or eyes. The
frequency of cleaning and disinfecting has been increased in both the guest areas and the back of house areas. Special
emphasis on cleaning and disinfecting has been in the high traffic areas and on the high touch surfaces. All disinfectants
must come from the EPA’s List “N” with an emerging pathogens claim to be effective against COVID-19. To determine if the
chemical is under the EPA’s “N” list, visit: https://cfpub.epa.gov/giwiz/disinfectants/index.cfm. The disinfectants are
typically not food safe, and therefore, after the disinfectants are used, food and beverage areas then need to be rinsed and
sanitized per Legends’ Food Surfaces Sanitize Policy.

• Designate a dedicated employee to actively clean and monitor the cleanliness of the area. Ideally, the
employee will be in an identifiable uniform that visually stands out to guests.
o Designate additional workers to be responsible for cleaning and sanitizing.
• Each space must be cleaned and disinfected at least once a day.
o Create opening and closing checklists for all locations in order to confirm the required cleaning and
disinfecting has been completed. A supervisor or manager must verify that those checklists have been
completed.
• Depending on the type of material of the containers/boxes, received containers/boxes are disinfected with
applicable food grade solutions before they are stored.
o If any raw fruits and vegetables that can be washed immediately, they are washed during the receiving
process.
• High touch objects that need to be cleaned and disinfected frequently and, if possible, in between each use.
Equipment includes but is not limited to, security collection basket in entrance areas, time clocks (such as the
ABI equipment), phones, radios, shared computers, point of sale terminals, doorknobs, door plates, shared
pens, tools, utensils, cleaning equipment, kitchen equipment, thermometers, carts, speed racks, hand trucks,
pallet jacks, industrial motorized vehicles, handles to coolers/freezers/hot boxes, and keys.
o Shared equipment is discouraged, and if possible, assign equipment, such as point of sale systems, to a
single cashier. That system would then be cleaned and disinfected between each user and before and
after each shift.
o If multiple servers use the same point of sale system, servers will either wash their hands or use hand
sanitizer after each use.
• Each venue leader must coordinate with the venue and, if applicable, the venue’s cleaning company to
determine responsibility for public space and guest space cleaning and disinfecting. Complimentary or
compatible protocols and procedures must be established.
o Dining tables, bar tops, stools, and chairs must be cleaned and disinfected after each guest’s use.
o Determine what doors can safely be left open to avoid the need for people to touch any part of the
door.
• As per the employee handbook, smoking is not permitted at the work site.

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 CONSIDERATIONS FOR SPECIALIZED AREAS DEPENDING ON THE LOCAL IMPACT OF COVID-19

RESTAURANT SPACES AND BANQUET/CATERING SPACES

• Spaces should be limited to one (1) unvaccinated person per every thirty-six (36) square feet until physical
distancing rules are removed. Capacities may need adjusting based on furniture layout.
• Parties should maintain at least 6 feet distance apart from other parties at all times, including while waiting to
be seated in the restaurant.
• Consider using disposable plates, prepackaged silverware, and individually packaged beverages.
o Condiments, silverware, flatware, glassware, or other traditional tabletop items should not be left on
an unoccupied table.
• Consider using single use or digital menus. Digital menus could include menus accessible on the venue’s
website, digital menu boards, and QR codes that takes the guest directly to the menu.
• Try to avoid customers ordering and/or waiting at the bar. Consider having a table in front of the bar where
customers can order their drinks. The customers can be given a number, practice physical distancing while
waiting, and then pick up their drinks at the designated area. Use customer facing signs to help direct the
customers.
o Customer should not drink their beverages at the bar, but look to local regulations for additional
guidance.
• Food that is not individually plated should be transported from the kitchen in sealed containers or wraps.
• Original buffet layouts can have serving attendants. These attendants would use an assembly line approach to
prepare the guest’s plate with the guest’s food choices.
o When pans need to be changed on the buffet, only the buffet attendant should replace the pan.
o Buffets must include sneeze guards.
• Original buffet layouts can also use wrapped/packaged products for guests to take their selection.
• Replace bulk-made items with individual servings that are handed directly to the guest.
• Existing porous placements should be replaced with single use placements or machine washable placements
that are cleaned and sanitized after each use.
• Chafers, jockey boxes, and utensil buckets must be cleaned and disinfect after each use.
• If the venue is offering customer food pickup:
o Reserve parking spaces near the front door for curbside pickup only;
o Avoid direct hand-off, when possible;
o Display a door or sidewalk sign with the services available, instructions for pickup, and hours of
operation; and
o Encourage customers to pay ahead of time by phone or online, if feasible.

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CONCESSIONS

• Consider having distinct areas for only ordering food and drinks. Provide the customer an order number, and
have the customer pick up his/her completed order in a different area. This system will help to reduce lines
and allow the waiting customers to physical distance from one another. Place customer facing signs in these
areas to help direct the customers.
• Refillable items should not be refilled.
o Refills on drinks should be provided in new cups designated by management.
o If other products are refillable (such as popcorn), new containers should be used for the refillable
product, but those containers must be designated by management.
• If the venue is using straws, order wrapped straws. Do not have the workers unwrap the straw and place it in
the customer’s drink. Instead, hand the wrapped straw directly to the customer.
• For drink containers that must be opened before the transaction is completed, use a bottle opener to open
cans instead of handling the can directly with your fingers and hand. For screw-top bottles, a worker could use
o a food safety gloved hand to open the bottle (remembering that if that glove hand touched money and
then the bottle, the glove is dirty and there would be no difference if the worker was using a glove or a
bare hand to open the bottle);
o a sanitizer wipe; or
o simply ask the customer to open the screw-top bottle and collect the lid.
• Condiments can be provided in an individual takeaway container or pre-packaged packets and can then be
provided by the worker directly to the guest.
• All menu items should be issued in wraps, clam shells, boxes, bags, etc.
• If possible, arrange cash only and credit card only service lines to allow guests to choose their preferred
method of payment.

WAREHOUSE
• Move to contactless signatures for deliveries.
• All items will be inspected before being brought into the kitchen.
o Where possible, limit cardboard or any other boxes from deliveries into the kitchen.
o All items that are received should be broken down outside the kitchen.

MERCHANDISE
• If the local/state regulations are silent, permanent stores should be limited to one (1) person per every thirty-
six (36) square feet until physical distancing rules are removed. Capacities may need adjusting based on
furniture layout.
o The building/fire marshal will act as a helpful resource in determining that capacity level.
o Designate an employee to regularly check the number of people in the store. If the number of people
is getting too close to the capacity limit, have an employee outside the entrance monitor the level and
ask guests to wait outside if the capacity is at its maximum.
• Consider displaying signage that indicates dedicated period of time each day for only at-risk customers. At-risk
customers include customers are those who are 65 or older, especially those with chronic lung disease;
moderate to severe asthma; chronic heart disease; severe obesity; diabetes; chronic kidney disease undergoing
dialysis; liver disease; or weakened immune system.
• Encourage merchandise workers to wear gloves as an added protection.
o Have automatic hand sanitizer stations at each point of sale for worker and guest use. Workers must
sanitize hands regularly.
• Consider prepackage merchandise with “Display Only” merchandise.
• Consider removing fixtures from retail locations to increase space for guests to maximize the social distancing
strategy.
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 • Position product types by category to eliminate back tracking within the store (all headwear together, all tee
shirts together, all sweatshirts together, etc.).
• The return policy will change to require a receipt and the original tag still attached to the apparel.
o Returned items can be toted for at least 72 hours after being returned before they are placed on the
shelf for resale.
o Place receipt directly in the bag to avoid touching the customer.
• Dressing rooms could no longer be available for guest use.
• If the venue is offering customer pickup:
o Reserve parking spaces near the front door for curbside pickup only;
o Avoid direct hand-off, when possible;
o Display a door or sidewalk sign with the services available, instructions for pickup, and hours of
operation; and
o Encourage customers to pay ahead of time by phone or online, if feasible.

TOUR OPERATIONS
• Consider having tickets only available using the Print at Home feature or the emailed version of the ticket.
• Tickets can be redeemed by scanning the ticket, but the worker will not touch the guest’s ticket or phone.
o To avoid scanning problems, have the guest adjust the brightness of the phone screen and/or the size
of the ticket.
• Encourage tour guides to wear gloves as an added protection.
• Assess the tour spaces to determine a tour group size that will better allow for physical distancing
recommendations and better avoid equipment in the venue.
o Consider expanding the time between tours to accommodate hand washing breaks for the tour guides.
• All items that a guest uses during the tour and/or after-tour activity should be cleaned and disinfected
regularly.

SHUTTLE OPERATIONS
• Limit the number of employees on each shuttle to maintain as much physical distancing as possible. Consider
the additional shuttle and staffing requirements.

OFFICE AREAS
When preparing to re-open the office, first determine who should return to the office space before determining the when
and how elements of the re-opening. By phasing employees back into the office using a four (4) phase outline – Phase 1:
Essential Staff Only, Phase 2: Staff with Private Office, Phase 3: Limited Staff using Rotation, and Phase 4: Full Staff;
adjustments can be made more easily and quickly.

• Have a town hall conference call for the office staff. On that call, discuss the phases of reopening the office
space, review these SOPs, and answer questions from the staff.
• Employees could continue to work from home unless the employee is identified as an employee who is able to
go into the office.
o Divide the office team into two or three groups depending on the size of the team. Only allow the
members of the group go into the office on their respective and designated days.
o Stagger arrival times of employees in order to avoid peak congestion times.
• Establish a station so that when an employee arrives, the employee can use hand sanitizer, collect PPE, and
dispose of any waste, such as towelettes used to clean high touch objects when entering the building.
• Non-essential visitors are not recommended, and any visitor can be approved by the office’s leadership team.
• Implement dedicated seating and workstations with proper social spacing.
• Encourage workers to bring their own meals to work from home so they can avoid going out for food during
the day.

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 • Break areas are not recommended to be used, but if they are, they must be sanitized after each use.
o If break areas and/or conference rooms must be used, consider removing chairs from the space to
allow for better physical distancing.

CONTINGENCY PLANNING
In case of a decrease in staffing due to workers having or being exposed to COVID-19, managers must develop contingency
plans. These plans should also address the possible decrease in specialized roles, such as managers, chefs, warehouse
workers, commercial drivers, and screen printers.

• Cross training workers helps to alleviate operational problems if a worker is not available for a period of time. Have
workers know how to complete other workers’ tasks so that if one worker is not available, another worker can still
perform the necessary functions. Start with more experienced supervisors to begin cross training. Depending on
the role the worker will be asked to perform, consider
o Introducing the client to the back-up managers,
o Printing and labeling pictures of the client’s key people,
o Writing down the details of opening and closing the venue and getting as granular as possible,
o Listing contact phone numbers, and
o Placing recipes in areas where they can be accessed by the team, such as binders in the kitchen or folders
on hotboxes that have checklists on what needs to be done when depositing a hotbox on site.
• Managers must consider what are important elements of their business and at what times are those duties critical.
Shift workers to those important duties when needed.
• Research alternatives for
o prepared food sources, such as local restaurants and US Foods’ Grab and Go collection in case the culinary
team is not available; and
o workers, and confirm that temporary agencies are available and that Legends has a written agreement
(reviewed and approved by the Legal department) with those agencies.
• Section workers into groups with a back-up group available, if possible. These groups should check into work
together, work in the same space, and leave at the same time. The groups should not be changed once created,
since the change could result in negatively impacting that group by possibly impacting multiple groups.
• If there is a decrease in staff, consider adjusting the hours of operations based on customer levels and sales
activity.

TRAVEL
• While traveling, federal standards must be followed. Masks must be worn at airports and on commercial aircraft;
public transit; public vessels, including ferries; and trains.
• If a person is traveling with co-worker, everyone in the vehicle must wear their mask unless everyone in the vehicle
is vaccinated and everyone agrees that it is ok to not wear a mask.
o For Legends’ vehicles, confirm that the vehicles’ fresh air vents and blowers are working properly.
o Before getting into a Legends’ vehicle or a vehicle rented for work, clean and disinfect frequently touched
surfaces (door handles, steering wheel, seat belt and buckle, arm and head rest, seat cover, turn signal,
wiper controls, dashboard, air ducts, radio, temperature controls, etc.).
• Try to avoid traveling in large groups when dining.
• Non-essential business travel must be approved by the business lead.

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TRAINING
All Legends workers must participate in mandatory trainings to understand the company’s policies and procedures as it
relates to subjects such as personal safety, food safety, and COVID-19 protection. Trainings will be distributed online,
classroom settings, videos, and pre-shift/departmental meetings. Communications about this plan and other programs
related to COVID-19 safety and prevention will be distributed according to the COVID-19 work groups’ plans.

AUDITING
To confirm that workers are following all of Legends’ policies and procedures that they affirmed and were trained to
complete, managers and designated Legends employees will monitor and verify workers’ activities, including but not
limited to completing The Blue Ribbon Club Audit, which specifically covers COVID-19 safety performance. If corrective
action is needed, these managers and designated employees will correct, re-train, and if necessary, discipline. The
Customer Service team will develop and implement surveys to get feedback from workers to determine that the elements
of this plan are effective. The feedback will be used to adapt, communicate, and enhance this plan. Workers and their
authorized representatives are encouraged to participate in the identification and evaluation of COVID-19 hazards by
reporting issues to their managers, their venue safety committee members, and/or [email protected].

COVID-19 hazards that are not already addressed in these SOPs and are newly identified will be assessed by venue
management and/or Risk Management. A person or persons will be selected to oversee the correction being implemented
in a timely manner based on the frequency and severity of the hazard. The local venue safety committee and/or the
corporate personal safety committee will follow up on the corrections to confirm the hazard was handled in a safe manner.
Managers will also continue to monitor the health of the workers in case a worker has COVID-19 symptoms develop during
his/her time at the venue. Employees and their authorized employees’ representatives are encouraged to participate in
the identification and evaluation of COVID-19 hazards by talking to the venue safety committee and/or emailing
[email protected].

Last Review Date: 6/1/2021 Created Date: 3/11/2020

Dates of Revision: 3/11/2020, 5/4/2020, 5/15/2020, Created By: Health Support Team and
8/12/2020, 10/22/2020, 12/14/2020, 3/11/2021, Personal Safety Committee
6/1/2021, 1/10/2022, 1/14/2022

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 CALIFORNIA ADDENDUM

MULTIPLE COVID-19 INFECTIONS AND COVID-19 OUTBREAKS

This addendum is in effect until there are no new COVID-19 cases detected in the exposed group for a 14-day period.

COVID-19 testing

Legends will provide COVID-19 testing at no cost to all employees, during paid time, in our exposed group
except for:
• Employees who were not present during the relevant 14-day period.
• COVID-19 cases who did not develop symptoms after returning to work pursuant to our return-to- work
criteria, no testing is required for 90 days after the initial onset of symptoms or, for COVID-19cases who never
developed symptoms, 90 days after the first positive test.
COVID-19 testing consists of the following:
• All employees in our exposed group are immediately tested and then again one week later. Negative COVID-19
test results of employees with COVID-19 exposure will not impact the duration of any quarantine, isolation, or
exclusion period required by, or orders issued by, the local health department.
• After the first two COVID-19 tests, we continue to provide COVID-19 testing once a week of employees in the
exposed group who remain at the workplace, or more frequently if recommendedby the local health
department, until there are no new COVID-19 cases detected in our workplace for a 14-day period.
• Legends will provide additional testing when deemed necessary by Cal/OSHA.

COVID-19 investigation, review, and hazard correction

Legends will immediately perform a review of potentially relevant COVID-19 policies, procedures, and controls and
implement changes as needed to prevent further spread of COVID-19.

The investigation and review is documented and includes:

• Investigation of new or unabated COVID-19 hazards including:

○ Leave policies and practices and whether employees are discouraged from remaining homewhen sick.
○ COVID-19 testing policies.
○ Insufficient outdoor air.
○ Insufficient air filtration.
○ Lack of physical distancing.
• Updating the review:
○ Every thirty days that the outbreak continues.
○ In response to new information or to new or previously unrecognized COVID-19 hazards.
○ When otherwise necessary.
• Implementing changes to reduce the transmission of COVID-19 based on the investigation and review, which
includes but is not limited to:
○ Moving indoor tasks outdoors or having them performed remotely.
○ Increasing outdoor air supply when work is done indoors.
○ Improving air filtration.
○ Increasing physical distancing as much as feasible.
○ Requiring respiratory protection in compliance with section 5144.

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 Buildings or structures with mechanical ventilation

Legends will work with the client and the building owner to filter recirculated air with Minimum Efficiency
Reporting Value (MERV) 13 or higher efficiency filters, if compatible with the ventilation system. If MERV-13 or
higher filters are not compatible, then the highest compatible filtering efficiency will be used. There will also be an
evaluation of whether portable or mounted High Efficiency Particulate Air (HEPA) filtration units or other air
cleaning systems would reduce the risk oftransmission and, if so, implement their use to the degree feasible.

MAJOR COVID-19 OUTBREAKS

This section should be in place when 20 or more employee COVID-19 cases in an exposed group visit the workplace
during the high-risk exposure within a 30 day period. This addendum will stay in effect until there are fewer than
three COVID-19 cases detected in our exposedgroup for a 14-day period.

Legends will continue to comply with the Multiple COVID-19 Infections and COVID-19 Outbreaks section, exceptthat
the COVID-19 testing, regardless of vaccination status, is made available to all employees in the exposed group twice
a week, or more frequently if recommended by the local health department.

• Provide employees in the exposed group with respirators for voluntary use in compliance with section
5144(c)(2) and determine the need for a respiratory protection program or changes to an existing respiratory
protection program under section 5144 to address COVID-19 hazards.
• Separate by six feet (except where we can demonstrate that six feet of separation is not feasible and there is
momentary exposure while persons are in movement) any employees in the exposed group who are not
wearing respirators required by us and used in compliance with section 5144. When it is not feasible to
maintain a distance of at least six feet, individuals are as far apart as feasible.
• Install cleanable solid partitions that effectively reduce transmission between the employee and other persons
at workstations where an employee in the exposed group is assigned to work for an extended period, such as
cash registers, desks, and production line stations, and where the physical distancing requirement (described
above) is not always maintained.
• Evaluate whether to halt some or all operations at the workplace until COVID-19 hazards have been
corrected.
• Implement any other control measures deemed necessary by Cal/OSHA.

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