Contract analysis

I. Purpose and Overview This memorandum sets forth the comprehensive recruitment plan for the PERM labor certification applications being prepared on behalf of Lumos Analytics Inc. ("Lumos" or "the Company") for four foreign national beneficiaries under the EB-2 (Employment-Based Second Preference — Advanced Degree Professional) classification. Each of the four positions for which labor certification is being sought

II. Summary of Positions, Beneficiaries, and Prevailing Wage Determinations This section provides a detailed overview of each of the four positions for which PERM labor certification applications are being prepared, including the identity and immigration status of each beneficiary, the applicable SOC code, the prevailing wage determination, the offered salary, and the minimum education, experience, and special requir

III. Recruitment Campaign Schedule The four PERM cases will be organized into two staggered recruitment campaigns, as described below. Within each campaign, recruitment steps for two positions will be conducted simultaneously to achieve administrative efficiency and cost savings while maintaining full regulatory compliance. A. Campaign 1 — Mehta & Varga Positions Campaign Commencement Date: October 9, 2023 The follow

IV. Mandatory Recruitment Steps — Professional Occupations Under 20 C.F.R. § 656.17(e) For professional occupations — defined as positions requiring at least a bachelor's degree or higher as a minimum educational credential — the DOL requires the employer to complete three mandatory recruitment steps plus three additional recruitment steps selected from a regulatory menu of ten options listed at 20 C.F.R. § 656.17(e)

V. Three Additional Recruitment Steps — Selected from 20 C.F.R. § 656.17(e)(1)(ii) Menu In addition to the three mandatory recruitment steps described in Section IV above, the regulations at 20 C.F.R. § 656.17(e)(1)(ii) require that employers conducting PERM recruitment for professional occupations select and complete at least three additional recruitment steps from a menu of ten enumerated options. The ten options i

VI. Coordination with Broadgate Compliance Services LLC As noted in Section I above, Broadgate Compliance Services LLC ("Broadgate") has been retained by Lumos Analytics Inc. and will coordinate directly with Calderwood & Harkness on the logistical aspects of the PERM recruitment advertising campaigns. Broadgate's principal, Gerald Fitzmorris, brings extensive experience in PERM recruitment compliance and will serve

1. CalJOBS (SWA) Job Orders: Broadgate will prepare the content for all CalJOBS job order postings and will file them through the CalJOBS portal on behalf of Lumos, in accordance with the filing dates set forth in Section III above.

2. Sunday Newspaper Advertisements: Broadgate will coordinate the placement of all Sunday print advertisements in The Peninsula Gazette with Noreen Caswell, the newspaper's advertising representative. Broadgate will submit advertisement copy (as reviewed and approved by Calderwood & Harkness), confirm publication dates, and obtain tearsheets and/or publisher's affidavits as proof of publication.

3. FinTech Talent Weekly Online Advertisements: Broadgate will coordinate the placement and documentation of all FinTech Talent Weekly professional journal advertisements through Creston Media Group, Inc. Broadgate will obtain confirmation of posting dates, active URLs, and screenshots documenting the postings.

4. Recruitment Report Templates: Broadgate will prepare standardized recruitment report templates for use by Calderwood & Harkness in preparing the final recruitment reports for each position. The recruitment report is a narrative document summarizing all recruitment steps conducted, the number and identity of applicants received, the disposition of each applicant, and the lawful job-related reasons for any rejection

VII. Recruitment Advertising Cost Estimates The table below provides a summary of estimated recruitment advertising costs for all four PERM cases across both campaigns. Notes on Cost Estimates: • The cost estimates for The Peninsula Gazette assume that both positions within each campaign are advertised simultaneously in the same newspaper edition on each Sunday, thereby sharing the cost of a single placement (or two

VIII. Employer Obligations During Recruitment — Instructions to Lumos This section describes Lumos's obligations and responsibilities during the recruitment period. Strict adherence to these guidelines is essential to maintain the integrity of the PERM labor market test and to ensure that the recruitment complies with DOL regulations. Failure to follow these procedures could result in a denial of the PERM application

IX. 30-Day Quiet Period and Recruitment Completion After the conclusion of the last active recruitment step in each campaign, a 30-day "quiet period" must be observed. During the quiet period, Lumos must continue to accept and evaluate any applications or resumes that are received, but no new recruitment activity should be initiated. The purpose of the quiet period is to provide a reasonable window for U.S. workers t

X. Documentation and Record Retention Lumos Analytics Inc. is required under 20 C.F.R. § 656.10(f) to retain all recruitment documentation for a minimum of five (5) years from the date the PERM application is filed or from the date of the recruitment activity, whichever is later. This retention requirement is critically important: in the event that the DOL selects any of the four PERM applications for audit, Lumos mu

1. Copies of All Advertisements: Including tearsheets from The Peninsula Gazette, publisher's affidavits confirming dates and content of publication, and printouts or screenshots of the FinTech Talent Weekly online postings with dates visible.

2. CalJOBS Job Order Confirmations: Confirmation pages or printouts from the CalJOBS system documenting the filing date, content, and duration of each SWA job order.

3. Internal Posting Certifications: Certifications signed by Janelle Kwon (or her designee) confirming the start and end dates of the internal Notice of Filing, the physical location(s) where the notice was posted, and that the notice remained posted for the required 10 consecutive business days.

4. Baxter University Career Center Posting Confirmations: Confirmation emails, screenshots, or letters from the Baxter University Career Center documenting the posting dates and content for each position.

5. Employee Referral Program Posting Evidence: Screenshots of the internal referral notice as posted on the company intranet, copies of the all-company email distribution, and/or screenshots from Meridian Solutions or Teams channels showing the referral posting with dates visible.

6. All Resumes Received: Copies of every resume and application received in response to the recruitment, regardless of whether the applicant was qualified or unqualified, organized by position and source.

7. Applicant Tracking Logs: Completed tracking logs for each position documenting each applicant's name, date of receipt, source, qualifications assessment, and disposition.

8. Interview Notes and Disposition Correspondence: Notes from any interviews conducted, disposition letters or emails sent to rejected applicants, and documentation of the lawful, job-related reasons for each rejection.

9. Prevailing Wage Determinations: Original prevailing wage determination letters from the NPWC for each position.

10. Recruitment Reports: Signed recruitment report narratives for each position.

11. ETA Form 9089 Applications and Supporting Documentation: Copies of the filed ETA Form 9089 applications and all supporting documentation, including any amendments or corrections. Calderwood & Harkness will maintain a parallel set of recruitment documentation in the firm's matter file (Matter No. 1008-00004). However, Lumos's independent obligation to retain these records cannot be delegated to outside counsel. Lu

XI. Timeline Summary Table The following table consolidates all key dates for both recruitment campaigns, presented side by side for easy reference. Note: All dates are approximate and subject to adjustment based on actual posting durations, publication schedules, and the receipt and evaluation of applicati