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Phase D · Module 14 · Operate

Compliance, safety, insurance, and risk

M14 / Franchisee Training Program

Classroom
165 min · 2.75 h
Pre-work
60 min · 1 h
OJT
—
Total
225 min · 3.75 h
Audience
Owner + DBM (both required); franchisee's insurance broker and counsel encouraged to observe
Prereq.
M01–M13
Version
v0.1
Reviewed
2026-05-19
Terms in this module13

Module 14 — Compliance, safety, insurance, and risk

Section 1 · Pre-work (60 minutes)

Required reading

  • Operations Manual §13 (all subsections). 30 minutes.
  • The trainee’s Franchise Agreement §13 (Insurance) and §14 (Indemnification). 20 minutes.
  • The trainee’s current insurance certificate(s) and any recent broker correspondence. 10 minutes.

Pre-session knowledge check

Submitted via Partner Portal at least 24 hours before the session.

  1. Within how many Business Days must the franchisee notify HiON of any compliance event affecting the franchise’s ability to operate?
  2. A regulator arrives at the HiON EV Facility for an unannounced inspection. State the franchisee’s first three actions.
  3. May the franchisee sign an acknowledgment of a regulator’s inspection finding that implicates HiON without HiON’s prior written approval?
  4. What is the franchisee’s exact response when an email “from HiON” instructs the franchisee to update HiON’s banking details for the next ACH?
  5. May a Site Host store its own delivery truck batteries at the HiON EV Facility’s storage area?

Bring to session

  • The trainee’s current insurance certificates and the franchisee’s broker contact
  • The trainee’s current Compliance Register (or working template)
  • The trainee’s Designated Business Manager
  • The trainee’s insurance broker if engaged — encouraged but not required

Section 2 · Learning objectives

By the end of this module, the trainee can:

  1. Operate the §13.1 compliance framework — retain qualified counsel per jurisdiction; maintain the Compliance Register; notify HiON of compliance events within 1 Business Day
  2. Maintain the §13.2 baseline safety program — written safety plan; Emergency Electrical Disconnect; fire extinguishers; contractor safety compliance per §7.4.4 (M07)
  3. Execute the §13.2.2 incident-management procedure — 9 incident categories; 8-step required procedure (immediate safety → SEV 1 ticket within 30 min → preserve scene → Incident Report within 24 hours → notify insurance broker → cooperate with regulators → no public statements → no admission/denial of fault)
  4. Maintain §13.3 ADA accessibility — 2010 Standards (or successor); accessible route obstruction-free; post reach-range; no signage/bollard/landscape that reduces dimensional characteristics
  5. Maintain §13.4 insurance — coverages and limits per FA §13; HiON named as additional insured on primary-non-contributory basis with waiver of subrogation where required; current certificates on Partner Portal; no lapse, cancellation, non-renewal; notify HiON of carrier notices within 3 Business Days
  6. Operate the §13.5 data privacy framework — no driver payment data ever; reasonable safeguards for Personal Information; compliance with state privacy laws; 1-Business-Day notification of security incidents implicating Personal Information or HiON Confidential Information; social-engineering resistance
  7. Comply with §13.6 environmental and hazardous-materials standards — NPDES/SWPPP where triggered; chemical storage per Site Design Manual; spill response with SEV escalation; no battery/accumulator storage outside EV Charging Equipment
  8. Execute §13.7 regulator and law-enforcement interaction discipline — professional, cooperative, ascertain identity/agency/purpose; photographs and notes; no volunteering beyond lawful demand; no signing of any acknowledgment implicating HiON without prior written approval; 1-Business-Day Partner Portal notification

Section 3 · Why this matters

The Manual frames the discipline at §13 Purpose with the unmistakable callout: “You, as Franchisee, are responsible for complying with every applicable federal, state, and local law, regulation, permit condition, utility requirement, AHJ directive, and contractual obligation that governs the operation of your HiON EV Franchise. … We publish standards and frameworks; we do not give you legal advice. You must retain qualified counsel and advisors for the jurisdiction in which your HiON EV Facility operates.” The framework operationalizes that responsibility. The franchisee’s compliance posture is the franchisee’s, not HiON’s. HiON’s role is standards-setting and audit; the franchisee’s role is execution and accountability.

The §13.1 Compliance Register is the central artifact. Every license, every permit, every renewal, every responsible individual — captured, current, producible on audit. The Register is what allows the franchisee to spot a license expiring 90 days out instead of 30 days out instead of after the franchisee discovers it has lapsed. The 1-Business-Day notification standard for compliance events is the franchisee’s signal to HiON when something is going wrong — a permit suspension, an injunction, a regulator investigation, litigation. HiON cannot help with what HiON does not know about.

The §13.2 incident-management procedure is the franchise’s safety spine. The 8-step procedure is non-negotiable and the franchisee internalizes it the way a pilot internalizes the checklist for engine failure. The 30-minute SEV 1 ticket clock, the 24-hour Incident Report deadline, the no-admission-of-fault discipline, the insurance-broker notification — each step protects the franchisee, the System, and (in the case of injury) the injured person.

The §13.3 ADA discipline is one of the §1.2.6 (M02) categorical no-exception territories. The Manual is explicit at §1.2.6: HiON will never grant an exception that compromises ADA accessibility. The franchisee operates accessibility to a standard that is the more demanding of federal and local — never the lesser of the two. Drive-by-litigation in the ADA space is a real and ongoing risk; the Manual’s [RECOMMENDED] in §13.3 is unusually direct: “Many accessibility complaints, and many drive-by-litigation demands, are resolved substantially easier when a defensible inspection record exists.”

The §13.4 insurance framework is where the franchise’s risk transfer to insurance carriers operates. The franchisee maintains every coverage required by FA §13; HiON is named as additional insured on primary-non-contributory basis with waiver of subrogation where required. A coverage lapse is a §13.4 [MANDATORY] violation — and operationally, a lapse exposes the franchisee (and HiON) to losses the insurance was supposed to cover. The 3-Business-Day notice of any carrier cancellation/non-renewal/material change is the franchisee’s signal to HiON before the lapse becomes operational. The cooperation discipline — never settle, admit, or compromise any claim implicating HiON without HiON prior written approval — protects the System’s litigation posture.

The §13.5 data-privacy framework matters because the franchisee holds Personal Information that is not driver-side. Employee HR data; Site Host contact data; lead data with named individuals. State privacy laws (CCPA, CPRA, CTDPA, VCDPA, and others) apply. The franchisee’s reasonable safeguards (role-based access, MFA, encryption, patched OS, reputable endpoint protection, documented incident response) are not optional. Social-engineering resistance — particularly business-email compromise and invoice-fraud — is operationally the most common threat. The [MANDATORY] standard requires verification through an independent channel before complying with any instruction to change banking, release credentials, or execute extraordinary transactions.

The §13.7 regulator and law-enforcement framework is low-frequency but high-consequence. The franchisee’s discipline: professional and cooperative; ascertain identity/agency/purpose; photographs and notes where permitted; do not volunteer information beyond lawful demand; do not sign acknowledgments implicating HiON; notify HiON within 1 Business Day. A regulator at the door is not a moment for unilateral judgment — it is a moment for the Manual’s protocol.

Acknowledged Elephant: sophisticated multi-unit operators are accustomed to compliance frameworks across multiple businesses. The HiON compliance framework imposes specific cooperation and notification disciplines that the franchisee may not have encountered in other systems — particularly the no-admission-of-fault discipline during incidents and the no-signing discipline during regulator interactions. These exist for reasons that are operationally consequential: a single admission of fault by a franchisee’s team member at an incident scene can shape the litigation outcome for the franchisee + HiON + Tesla. The discipline is not about hiding facts; it is about leaving legal characterization to counsel rather than to first responders’ on-scene conversation.

Section 4 · Core content

4.1 — The §13.1 regulatory and legal compliance framework

12 compliance domains the franchisee operates within (Manual lists; specifics vary by jurisdiction):

DomainTypical scope
Federal trade regulationFTC Franchise Rule (Item 19 FPRs); FTC Act; truth-in-advertising
Employment and laborWage and hour, classification, payroll tax, workers’ comp, unemployment, discrimination, harassment, leave, accommodation, I-9/E-Verify, state-specific employment statutes
AccessibilityADA + applicable state and local accessibility law (§13.3)
Building codes and land useBuilding, electrical, signage, zoning, conditional-use (§7 / M06–M07)
Utility regulationTariffs, interconnection rules, metering, PUC/PSC regulation as applicable (§7.3 / M06)
Environmental and stormwaterNPDES/SWPPP where triggered; local stormwater permits; erosion control (§13.6)
Hazardous materialsDe-icing chemicals, landscape chemicals, batteries (any battery onsite outside EV Charging Equipment), spill response (§13.6)
Consumer protectionState consumer-protection statutes; weights and measures (if applicable to EV sales); state lemon-law or consumer-right statutes as applicable
Data privacy and cybersecurityState privacy laws (CCPA, CPRA, CTDPA, VCDPA, etc.); general cybersecurity practice (§13.5). Driver-side data handled by Tesla, not by Franchisee
Licensing and taxBusiness licenses, sales tax, use tax, property tax, electricity excise or gross-receipts tax, state franchise tax
Signage and advertisingLocal sign codes, illumination rules, advertising regulation (§2.4 / M03 + §11 / M08)
Lien, lease, real-propertyMechanic’s-lien compliance during construction (§7 / M06–M07); lease performance (§5 / M05); Collateral Assignment perfection

Three [MANDATORY] §13.1 standards plus one [LOCAL-LAW DEPENDENT]:

  1. Retain qualified counsel licensed in the jurisdiction(s) of the franchise to advise on the compliance domains and handle matters requiring legal representation — regulator contacts, litigation, material contract review
  2. Maintain a Compliance Register at each HiON EV Franchise: each license and permit required by an AHJ; issuance and expiration date; renewal procedure and deadline; individual responsible for renewal. Required audit item.
  3. Notify HiON of any compliance event affecting the franchise’s ability to operate per the FA: loss/suspension/conditional renewal of any required permit or license; injunction, administrative order, or consent decree affecting the HiON EV Facility or franchisee entity; regulator-initiated investigation affecting the HiON EV Facility; litigation naming the franchisee entity, an owner, or the HiON EV Facility. Notification within 1 Business Day of the event.
  4. [LOCAL-LAW DEPENDENT] Several compliance domains (accessibility, stormwater, signage, consumer protection) are heavily jurisdiction-dependent. Do not extrapolate from one HiON EV Facility’s approach to another. Engage local counsel per site.

4.2 — Site safety: baseline (§13.2.1) and incident management (§13.2.2)

Four [MANDATORY] §13.2.1 baseline safety standards:

  1. Maintain a site-safety program appropriate to the HiON EV Facility: written safety plan; designated first-aid and emergency-contact resources; documented lock-out/tag-out procedures for all electrical work; PPE appropriate to tasks; documented employee safety training
  2. Maintain the Emergency Electrical Disconnect in accessible, labeled, operational condition at all times. Ensure the team knows how and when to operate it. Under no circumstance is any team member required to operate the Disconnect in a manner that puts them at personal risk; first responsibility is personal safety and 911 if warranted
  3. Maintain working fire extinguishers at the HiON EV Facility per AHJ requirements; inspect and maintain on the cadence required by the AHJ or the manufacturer (whichever is more stringent)
  4. Ensure contractor compliance with §7.4.4 (M07) OSHA and safety standards and with any site-specific safety protocols the franchisee maintains

Nine §13.2.2 incident categories — events triggering the incident procedure (whether or not they result in injury or damage):

  • Any injury to driver, public, employee, contractor, or Site Host personnel on the HiON EV Facility
  • Any vehicle collision at the HiON EV Facility (with bollards, cabinet, posts, structures, other vehicles)
  • Any fire, smoke, electrical arcing, or thermal event involving EV Charging Equipment or site infrastructure
  • Any spill of petroleum, battery fluid, coolant, or chemical beyond incidental amounts
  • Any near-miss involving high-voltage exposure, trenching, or lifting operations during construction or maintenance
  • Any hostile, threatening, or violent behavior at the HiON EV Facility
  • Any act or threat of vandalism, theft, or tampering with the EV Charging Equipment or site infrastructure
  • Any credible allegation of harassment, discrimination, or misconduct by any person associated with the franchise
  • Any regulator, law-enforcement, or AHJ contact arising out of operations

Required incident procedure — 8 steps:

  1. Ensure immediate safety: 911 if anyone is at risk; evacuate, isolate, or de-energize as §13.2.1 permits and as the situation warrants
  2. Open a SEV 1 ticket through the NOC Hotline (voice) and in the Partner Portal within 30 minutes or as soon as safe (§3.2.2.A / M02)
  3. Preserve the scene and evidence: do not move equipment, modify the area, or discard damaged items; photograph from a safe distance only after the scene is secure
  4. Complete the Incident Report (Appendices form) within 24 hours of the event
  5. Notify the franchisee’s insurance broker per the carrier’s incident-notification requirements and within the carrier’s timeline
  6. Cooperate with any regulator, law-enforcement, or investigator contact. Notify HiON within 1 Business Day of any such contact per §3.2.5 (M02)
  7. No public statements about the incident. Escalate all media inquiries per §11.5.3 (M08) and §3.2.5
  8. Do not admit or deny fault on behalf of the franchisee, HiON, Tesla, the Site Host, or any third party. Factual observations to first responders are appropriate; legal conclusions are not.

[MANDATORY] §13.2.2: retain all incident documentation, photos, statements, correspondence per FA + §15 + insurance carrier requirements — whichever is longest.

4.3 — Accessibility and the ADA (§13.3)

Six [MANDATORY] standards plus one [LOCAL-LAW DEPENDENT]:

  1. Each HiON EV Facility complies with the 2010 ADA Standards for Accessible Design (or successor standards from the U.S. Access Board) and applicable state and local accessibility law as those requirements apply to public-accommodation parking and EV charging
  2. Provide at least the minimum number of accessible charging stalls and accessible access aisles required by the applicable standard, configured per the Site Design Manual
  3. The accessible route from accessible parking to main entrance, and from accessible charging stall to main entrance / Site Host’s venue, must be maintained free of obstruction, debris, snow, ice, or any temporary placement that impairs use. Obstruction is an immediate §9.2 violation (M10) and must be remediated on detection
  4. The charging post serving an accessible stall must allow a driver using a mobility device to reach and operate the connector consistent with the reach-range requirements of the applicable accessibility standard
  5. No signage, bollard placement, landscape treatment, or temporary equipment that reduces a dimensional characteristic of an accessible stall, accessible aisle, or accessible route below the applicable accessibility standard
  6. [LOCAL-LAW DEPENDENT] Several jurisdictions impose stricter requirements than the federal baseline (California Title 24 among them). Comply with the more demanding of federal and local standards.

Ongoing accessibility maintenance:

  • Inspect the accessible stall, aisle, route at every site inspection (§9 / M10); document
  • After snow events, clear the accessible route before ordinary parking areas (§9.2.2)
  • After any striping, paving, or landscape work, re-measure accessible dimensions before closing the work order
  • Review accessibility configuration at every design change, lease amendment, or Site Host operational change

[RECOMMENDED] “Many accessibility complaints, and many drive-by-litigation demands, are resolved substantially easier when a defensible inspection record exists. Invest in the documentation; it saves proportionally.”

4.4 — Insurance and indemnification (§13.4)

Five [MANDATORY] standards plus one [RECOMMENDED]:

  1. Obtain, pay for, maintain in full force and effect every insurance coverage required by FA §13 — at the limits and on the terms required and any Partner Portal updates HiON publishes
  2. Every required policy names HiON Franchise Group, LLC, its affiliates (including HiON IP, LLC as applicable), and the additional insureds specified in the FA — on the primary-non-contributory basis required and with the waiver of subrogation required where the FA requires it
  3. Deliver current, accurate certificates of insurance evidencing every required coverage: before the HiON EV Franchise opens; on every policy renewal; on any mid-term coverage change; promptly on HiON request. Upload to the Partner Portal.
  4. No lapse, cancellation, or non-renewal of any required coverage. Notify HiON of any carrier notice of cancellation, non-renewal, material change, or reduction within 3 Business Days of receipt
  5. Cooperate with HiON, HiON’s insurers, the franchisee’s insurers, any investigator or adjuster in connection with any claim involving the franchise. No settlement, no admission of liability, no compromise of any claim that implicates HiON without HiON prior written approval
  6. [RECOMMENDED] Work with an insurance broker who understands franchise operations, medium-voltage commercial EV charging, and the specific risk profile of a public-access charging site. Generic commercial policies often miss exclusions that matter

Indemnification (§13.4): the franchisee’s indemnification obligations to HiON — and the waivers and releases granted to HiON — are in FA §14. Do not operate as if the franchisee has a contractual basis to look to HiON for indemnity or defense except as that Section expressly provides.

4.5 — Data privacy and cybersecurity (§13.5)

Six [MANDATORY] standards plus one [RECOMMENDED]:

  1. No collection, storage, transmission, processing, or handling of any driver payment card data, payment credential, bank account data, or other payment instrument data at the HiON EV Facility or on any system or device operated by the franchisee (§2.1.3 / M01 + §10.2.1 / M11)
  2. Reasonable administrative, physical, and technical safeguards for any Personal Information the franchisee holds — employee HR data, Site Host contact data, lead data with named individuals. Reasonable safeguards include: role-based access, MFA, encryption of Personal Information at rest and in transit where feasible, patched and supported operating systems, reputable endpoint protection, documented incident-response process
  3. Comply with all applicable federal, state, and local privacy, data-breach-notification, and biometrics laws applicable to the franchisee’s entity and Personal Information held. If a security incident occurs implicating Personal Information or HiON Confidential Information, notify HiON within 1 Business Day of discovery and cooperate with HiON’s response
  4. Protect Partner Portal credentials as Confidential Information per §1.3 (M02). Sharing credentials, storing in shared documents, using credentials from a personal rather than a role-based account is prohibited
  5. No installation of software on devices used for HiON EV Franchise business from untrusted sources. No disabling of security controls (firewall, MFA, endpoint protection) without documented justification and HiON concurrence for sensitive systems
  6. [RECOMMENDED] Maintain a simple written incident-response plan identifying who is notified, in what order, on a suspected cybersecurity event. Test it annually

Social engineering — two standards (§13.5):

  • [MANDATORY] No compliance with any instruction by email/phone/text/social media that: (a) instructs a change to banking or payment details for HiON, Tesla, a contractor, vendor, or any other party; (b) instructs the release of credentials, documents, or Personal Information; or (c) instructs any extraordinary financial transaction — unless verified through an independent channel consistent with HiON security protocols on the Partner Portal
  • [RECOMMENDED] Invoice-fraud and business-email-compromise are the most common threats. Use dual-control for banking changes; verify new bank-account details by calling the vendor back on a number you had before the request; treat urgency as a red flag

4.6 — Environmental, stormwater, and hazardous-materials compliance (§13.6)

Four [MANDATORY] standards plus one [LOCAL-LAW DEPENDENT]:

  1. Comply with all applicable stormwater, erosion-control, site-disturbance requirements during construction (§7 / M06–M07) and ongoing operations — NPDES permit, state SWPPP obligation, local stormwater-management requirement
  2. Store, handle, and dispose of de-icing chemicals, landscape chemicals, paint, fuel (for snow equipment or generators, if any), and other hazardous or regulated materials in accordance with applicable law and in a manner that does not damage EV Charging Equipment or the accessible route. Use only Site Design Manual-compatible products
  3. Respond to any spill of fuel, oil, coolant, battery fluid, or chemical consistent with applicable spill-response requirements. Notify the AHJ as required. Open a SEV 1 ticket (larger or hazardous spills) or SEV 3 (incidental) per §3.2 (M02)
  4. No storage of batteries, accumulators, or energy-storage systems at the HiON EV Facility other than those integral to the EV Charging Equipment HiON supplies. Any proposed exception requires HiON written approval and compliance with applicable storage, fire, and hazardous-materials rules
  5. [LOCAL-LAW DEPENDENT] Stormwater, wetland, chemical-storage rules vary significantly. Follow the local standard; where federal and local both apply, comply with both

4.7 — Regulator and law-enforcement interactions (§13.7)

Three [MANDATORY] standards plus one [RECOMMENDED]:

  1. If any federal, state, or local regulator, inspector, investigator, auditor, or law-enforcement officer arrives or contacts the franchisee’s team in connection with the franchise, the HiON EV Facility, the EV Charging Equipment, or HiON, the franchisee must:
    • (a) Remain professional and cooperative
    • (b) Ascertain identity, agency, and purpose of the visit
    • (c) Take photographs and written notes of what is inspected or asked, to the extent permitted
    • (d) Do not volunteer information or documents beyond what is required by the inspector’s lawful authority
    • (e) Notify HiON through the Partner Portal within 1 Business Day (sooner if material)
  2. No signature on any acknowledgment, consent, stipulation, settlement, order, or finding in connection with any regulator or law-enforcement interaction that implicates HiON, the System, or the Tesla Supercharger network — without HiON prior written approval and, where appropriate, the involvement of HiON’s counsel and/or the franchisee’s
  3. If a subpoena, warrant, civil-investigative demand, or comparable process is served:
    • (a) Accept service as required by the process
    • (b) Decline to produce HiON Confidential Information beyond what the process compels
    • (c) Notify HiON immediately
    • (d) Cooperate with HiON to seek any available protective order
  4. [RECOMMENDED] Preserve voicemails, emails, letters from regulators. The chain of communication often matters

§13 Metrics audit posture:

  • Compliance Register current and producible on audit
  • Current insurance certificates on file for every required coverage; named-insured language verified against FA
  • Incident reports filed within 24 hours for every incident
  • ADA inspection completed at every site inspection; no unresolved accessibility obstruction
  • No unreported regulator or law-enforcement interactions in the audit period
  • No security incident within the audit period without a written response record on file

Section 5 · Decision drills

Drill 5.1 — The unannounced regulator visit

At 10:14am Tuesday, a state Department of Labor inspector arrives at the Parker site for an unannounced inspection. The inspector asks for the franchisee’s payroll records for the past 3 months and asks to interview the Site Operations Lead about overtime practices.

State the franchisee’s first 5 actions in order and the cited basis.

Drill 5.2 — The banking-detail “update” email

The franchisee’s controller receives an email apparently from HiON’s accounting team: “Effective Monday, please update our ACH routing for Royalty payments to [new account]. Old account is being closed. Reply confirming the change by EOD Friday.” The email comes from a domain similar to but not exactly HiON’s.

State the response and the cited basis. State the verification protocol.

Drill 5.3 — The injury during snow event

During an active snow event, a driver slips on the accessible route at the Parker site. The driver hits their hip on a bollard. The franchisee’s contracted snow-removal team cleared the parking lot 90 minutes earlier but was scheduled to return for the bay.

State the next 8 actions per §13.2.2 and the cited basis. State what is documented and where.

Drill 5.4 — The Site Host’s battery proposal

The Site Host proposes installing two small lithium-ion battery storage units in a corner of the parking lot, sold as “behind-the-meter resilience for the property’s general electrical load.” The units would not connect to the HiON EV Charging Equipment.

State the response and the cited basis. State the path the franchisee follows.

Drill 5.5 — The accessible-stall obstruction

The franchisee’s signage vendor temporarily places a 6-foot-tall sign-installation toolbox in the access aisle of the accessible charging stall while installing new wayfinding 30 feet away. The placement will last “about 2 hours.”

State whether this is acceptable and the cited basis. State the corrective action.

Drill 5.6 — The insurance lapse notice

The franchisee receives a non-renewal notice from the carrier for the franchise’s general liability policy. The carrier cites “underwriting changes in EV-charging risk profile.” The non-renewal takes effect in 45 days. The franchisee has not yet identified a replacement carrier.

State the franchisee’s next 3 actions and the cited basis. State the §13.4 notification deadline.

Drill 5.7 — The acknowledgment of finding

An AHJ electrical inspector finds a signage installation that does not meet the local sign permit’s exact specifications. The inspector hands the franchisee a 1-page “Notice of Inspection Finding” and asks the franchisee to sign acknowledging the finding. The signage installation was previously HiON-approved.

State the response and the cited basis. State whether the franchisee signs.

Drill 5.8 — The “minor” data privacy event

A franchisee employee’s laptop containing HR records (employee names, addresses, SSNs) is stolen from the employee’s car overnight. The employee reports it Monday morning. The franchisee’s DBM is uncertain whether this rises to the level of a “security incident.”

State whether this is a §13.5 [MANDATORY] notification event and the cited basis. State the next 3 actions.

Drill 5.9 — The settlement offer to a driver

A driver injured at the franchisee’s site files a small claim ($8,500) for medical expenses related to a slip-and-fall. The driver’s attorney offers to settle for $5,200 within 30 days. The franchisee’s broker is on vacation and the DBM proposes accepting to “make this go away.”

State the response and the cited basis. State the franchisee’s next 2 actions.

Drill 5.10 — The ADA dimensional re-measure

After a re-striping project at the Parker site, the franchisee’s striping vendor delivers an invoice and indicates the work is complete. The franchisee notices the accessible stall’s access aisle appears narrower than before.

State the response and the cited basis. State the franchisee’s next 2 actions.

Section 6 · Common operator errors

6.1 — Compliance Register not maintained

The franchisee operates without a current Compliance Register or treats it as a one-time setup artifact.

  • Consequence: §13.1 [MANDATORY] violation. Audit finding under §13 Metrics. Operational consequence: license or permit lapses surface without lead time for cure.
  • Discipline: the Register is a living document. Each license/permit has an entry with expiration, renewal procedure, responsible individual. Reviewed at minimum quarterly; renewal reminders set 60-90 days before expiration.

6.2 — Compliance event not notified to HiON within 1 BD

A regulator initiates an investigation; a permit is suspended; an injunction issues. The franchisee handles the matter internally without HiON notification.

  • Consequence: §13.1 [MANDATORY] violation (1-Business-Day notification). HiON’s visibility into franchise-level risk is degraded; compounding consequences if the matter escalates without HiON involvement.
  • Discipline: the 1-Business-Day notification is non-negotiable. Open Partner Portal ticket under Compliance and Risk + notify the FBC. HiON cannot help with what HiON does not know about.

6.3 — Admission of fault at an incident scene

The DBM or Site Operations Lead, in the immediate aftermath of an incident, admits or denies fault in conversation with the driver, first responders, the Site Host, or media.

  • Consequence: §13.2.2 step-8 [MANDATORY] violation. Legal/insurance exposure may compound. The admission may be admissible in subsequent litigation against the franchisee and HiON.
  • Discipline: factual observations only (“the driver fell at this location around 2:14pm”); no legal characterization (“we should have cleared that area”). Legal conclusions are for counsel after the fact, not for team members in the moment.

6.4 — Accessible-route obstruction

Snow piles, bollards, signage, planters, or temporary equipment block any portion of the accessible stall, access aisle, or accessible route.

  • Consequence: §13.3 [MANDATORY] + §9.2 (M10) [MANDATORY] + §10.4.3 (M11) [MANDATORY] violation. ADA exposure under federal and (typically) state law. Drive-by-litigation risk.
  • Discipline: the accessible route is sacred. No obstruction, ever, even temporarily. Snow piles go elsewhere; sign-install toolboxes stage outside the access aisle.

6.5 — Insurance lapse without HiON notification

A coverage lapses, cancels, or is non-renewed and the franchisee does not notify HiON within 3 Business Days.

  • Consequence: §13.4 [MANDATORY] violation. Material breach exposure. If a loss occurs during the lapse, the franchisee absorbs the loss + HiON’s potential exposure.
  • Discipline: carrier notices route to HiON immediately. The 3-Business-Day clock is the maximum, not the target — same-day notification is the practice.

6.6 — Settlement, admission, or compromise of a claim implicating HiON

The franchisee, faced with a claim, settles or accepts a finding that implicates HiON’s role, network, or System — without HiON prior written approval.

  • Consequence: §13.4 [MANDATORY] + §13.7 [MANDATORY] violation. Material breach.
  • Discipline: any claim implicating HiON routes through HiON before any commitment. Counsel involvement on both sides where appropriate.

6.7 — Signing a regulator’s acknowledgment without HiON approval

A regulator presents a finding, citation, or order; the franchisee signs acknowledging the finding without HiON prior written approval.

  • Consequence: §13.7 [MANDATORY] violation if the document implicates HiON. May constitute admission for purposes of subsequent enforcement.
  • Discipline: acknowledgments that implicate HiON wait for HiON written approval. If the regulator insists on immediate acknowledgment for a strictly franchisee-only finding (one that does not implicate HiON), the franchisee evaluates carefully — often with counsel — before signing.

6.8 — Compliance with a banking-change instruction without verification

The franchisee, under time pressure or social-engineering pressure, complies with an emailed banking-change instruction or wire-transfer demand without independent verification.

  • Consequence: §13.5 [MANDATORY] violation. Likely financial loss + potential payment-data exposure.
  • Discipline: the verification protocol is non-negotiable. Banking changes verified by callback to a number from prior records; vendor instructions verified through a separate channel; urgency is a red flag.

6.9 — Battery or accumulator storage at the HiON EV Facility

The franchisee stores batteries (golf-cart batteries, backup power batteries, contractor lithium tools, etc.) at the HiON EV Facility outside the EV Charging Equipment.

  • Consequence: §13.6 [MANDATORY] violation. Fire and hazardous-materials exposure.
  • Discipline: no batteries at the HiON EV Facility other than those integral to the EV Charging Equipment HiON supplies. Snow-equipment batteries, contractor tool batteries, Site Host’s battery backups — all stored elsewhere or removed.

6.10 — Incident Report past the 24-hour window

The franchisee, busy with site management, files the Incident Report 36-48 hours after the event.

  • Consequence: §13.2.2 [MANDATORY] violation (24-hour deadline). Insurance carrier notification may also be late, with carrier-level consequences.
  • Discipline: the 24-hour clock starts at the event. The Incident Report is the first office task after the immediate-safety + SEV 1 ticket + scene preservation steps. No exceptions for “busy.”

Section 7 · Competency assessment

Knowledge check (12 questions; 80% pass)

  1. Notification to HiON of any compliance event affecting the franchise’s ability to operate must occur within: (a) 24 hours (b) 1 Business Day (§13.1 [MANDATORY]) (c) 5 Business Days (d) the next FBC touchpoint

  2. The franchisee’s first action when an unannounced regulator arrives: (a) call the franchisee’s counsel before any engagement (b) remain professional and cooperative; ascertain identity, agency, and purpose (§13.7 [MANDATORY]) (c) refuse entry and call HiON (d) request the regulator schedule a return visit

  3. The franchisee receives an email instructing a change to HiON’s ACH banking details. The franchisee must: (a) comply immediately to avoid payment delays (b) reply to confirm and check with FBC later (c) decline to comply until the instruction is verified through an independent channel (§13.5 [MANDATORY]) (d) treat as routine accounting administration

  4. The Incident Report after a §13.2.2 incident must be completed within: (a) 4 hours (b) 24 hours of the event (§13.2.2 [MANDATORY]) (c) 5 Business Days (d) at the franchisee’s discretion

  5. After an incident, the franchisee may: (a) admit fault to first responders to show goodwill (b) deny fault to protect the franchise’s position (c) make factual observations to first responders, but not legal conclusions (§13.2.2 [MANDATORY]) (d) decline to engage with first responders pending counsel

  6. The accessible charging stall and accessible route may be obstructed: (a) temporarily during maintenance (b) during snow events (c) never — §13.3 [MANDATORY] requires no obstruction at any time (also §9.2 / M10 + §10.4.3 / M11) (d) with FBC approval

  7. Notification to HiON of any carrier notice of cancellation, non-renewal, material change, or coverage reduction must occur within: (a) 24 hours (b) 3 Business Days of receipt (§13.4 [MANDATORY]) (c) 10 Business Days (d) the next quarterly compliance review

  8. The franchisee may settle, admit liability, or compromise a claim implicating HiON: (a) with FBC verbal approval (b) for amounts under $10,000 (c) only with HiON prior written approval (§13.4 [MANDATORY]) (d) when the franchisee’s broker recommends settlement

  9. A security incident implicating Personal Information or HiON Confidential Information must be reported to HiON within: (a) 5 Business Days (b) 1 Business Day of discovery (§13.5 [MANDATORY]) (c) at the next monthly commentary (d) only if breach-notification law requires reporting

  10. The franchisee may sign a regulator’s acknowledgment of an inspection finding that implicates HiON: (a) yes, to expedite the inspection (b) yes, if the franchisee disputes the finding in writing (c) no — §13.7 [MANDATORY] prohibits signing acknowledgments implicating HiON without HiON prior written approval (d) yes, with FBC verbal approval

  11. Battery storage at the HiON EV Facility: (a) is acceptable for backup power (b) is acceptable for contractor tools (c) is prohibited other than batteries integral to the EV Charging Equipment HiON supplies; exceptions require HiON written approval (§13.6 [MANDATORY]) (d) is acceptable if the Site Host requests it

  12. After a striping or paving project, the franchisee must: (a) accept the contractor’s confirmation of completion (b) re-measure accessibility only on next site audit (c) re-measure accessible dimensions before closing the work order (§13.3) (d) defer measurement to the engineer

Application demonstration — the compliance day

A 60-minute live exercise. The trainee receives a Compliance Day Pack containing:

  • A regulator arrives at the site for an unannounced inspection (live role-play)
  • An “ACH update” email from a domain similar to HiON’s (with red-flag indicators the trainee identifies)
  • A driver-injury incident from yesterday with a draft Incident Report that exceeds 24 hours
  • A non-renewal notice from the general liability carrier received 2 weeks ago, not yet notified to HiON
  • A Site Host battery-storage proposal
  • An accessibility obstruction discovered during morning inspection (sign-install toolbox in access aisle)
  • A small-claim settlement offer from an injured driver’s attorney
  • An expired permit on the Compliance Register the franchisee has not noticed
  • A stolen-laptop incident from the previous week with no §13.5 notification to HiON

The trainee must:

  1. Execute the regulator interaction per §13.7
  2. Identify and respond correctly to the phishing email
  3. Cure the late Incident Report with documentation of the delay cause
  4. Notify HiON of the non-renewal within the §13.4 window
  5. Respond to the Site Host battery proposal per §13.6
  6. Cure the accessibility obstruction immediately
  7. Decline the settlement offer pending HiON written approval
  8. Address the expired permit with corrective action and Compliance Register update
  9. Notify HiON of the §13.5 security incident with the cited basis

Pass criteria: trainee correctly identifies every violation, executes corrective action, cites the basis. Citation of section numbers preferred but not required if substantive actions are correct.

Section 8 · Job aids

Job Aid 8.1 — Compliance Register template

The §13.1 [MANDATORY] register: every license/permit + AHJ + issuance date + expiration + renewal procedure + renewal deadline + responsible individual + status. Reviewed quarterly with 60-90-day expiration reminders.

File: modules/M14-jobaids/M14-compliance-register.md

Job Aid 8.2 — Incident-response 8-step card

Pocket card with the §13.2.2 8-step procedure in order. Front: immediate safety / SEV 1 ticket / preserve scene / Incident Report / insurance broker / cooperate / no public statements / no admission of fault. Back: §13.2.2 9 incident categories + the verbatim “factual observations, not legal conclusions” rule.

File: modules/M14-jobaids/M14-incident-card.md

Job Aid 8.3 — ADA accessibility daily inspection checklist

The §13.3 standards as a daily checklist: accessible stall striping intact; access aisle clear; route obstruction-free; post reach-range to connector; no signage/bollard/landscape reducing dimensional characteristics. Post-snow priority sequence: accessible route before ordinary parking.

File: modules/M14-jobaids/M14-ada-checklist.md

Job Aid 8.4 — Insurance certificate tracker

Every required FA §13 coverage with: carrier; policy number; effective and expiration dates; named-insured language verified; primary-non-contributory verified; waiver of subrogation verified; renewal reminder 60-90 days out; Partner Portal upload reference.

File: modules/M14-jobaids/M14-insurance-tracker.md

Job Aid 8.5 — Social-engineering response protocol

A flowchart for any incoming instruction to change banking, release credentials, or execute extraordinary transactions. Decision points: identify the apparent source; identify the channel; identify red flags (urgency, similar-but-not-exact domains, after-hours timing); verify through independent channel; document; if verified, proceed with documentation; if not verified, refuse and report.

File: modules/M14-jobaids/M14-social-engineering-protocol.md

Job Aid 8.6 — Regulator visit response card

Pocket card with the §13.7 procedure: remain professional + cooperative; ascertain identity/agency/purpose; photographs and notes; do not volunteer; do not sign acknowledgments implicating HiON; notify HiON within 1 BD. Includes a “questions to ask the regulator” list and the “what to record” template.

File: modules/M14-jobaids/M14-regulator-card.md

Job Aid 8.7 — Cybersecurity baseline

The §13.5 baseline as a checklist: role-based access in place; MFA on every supported account; encryption at rest and in transit where feasible; OS patched and supported; reputable endpoint protection; incident-response plan documented and tested annually.

File: modules/M14-jobaids/M14-cybersecurity-baseline.md

Job Aid 8.8 — Hazardous-materials reference

The §13.6 standards as a quick reference: NPDES/SWPPP triggers; chemical-storage practices; Site Design Manual-compatible products; spill response (SEV 1 for hazardous/large, SEV 3 for incidental); no battery storage outside EV Charging Equipment.

File: modules/M14-jobaids/M14-hazmat-reference.md

Section 9 · Facilitator notes

Pacing — 165 minutes (2h 45min, two 10-minute breaks)

TimeSectionNotes
0:00–0:10Opening — the no-admission-of-fault disciplineRead aloud a redacted case where a team member’s casual admission at an incident scene shaped subsequent litigation. Sets tone for §4.2.
0:10–0:25§4.1 (Regulatory framework + Compliance Register)Walk the 12 compliance domains + 3 [MANDATORY] standards. Distribute Job Aid 8.1.
0:25–1:00§4.2 (Safety + incident management)Heaviest section. Walk the 9 incident categories + 8-step procedure. Distribute Job Aid 8.2. Run Drills 5.3 (injury during snow event) and 5.10 (ADA re-measure).
1:00–1:10BREAK
1:10–1:30§4.3 (ADA accessibility)Walk the 6 [MANDATORY] standards + ongoing maintenance. Distribute Job Aid 8.3. Run Drill 5.5 (accessible-stall obstruction).
1:30–1:50§4.4 (Insurance + indemnification)Walk the 5 [MANDATORY] standards. Distribute Job Aid 8.4. Run Drills 5.6 (insurance lapse) and 5.9 (settlement offer).
1:50–2:00BREAK
2:00–2:20§4.5 (Data privacy + cybersecurity + social engineering)Walk the 6 [MANDATORY] + social-engineering standard. Distribute Job Aids 8.5, 8.7. Run Drills 5.2 (ACH email) and 5.8 (stolen laptop).
2:20–2:35§4.6 (Environmental + hazmat)Walk the 4 [MANDATORY] standards. Distribute Job Aid 8.8. Run Drill 5.4 (Site Host battery proposal).
2:35–2:45§4.7 (Regulator + law-enforcement)Walk the 3 [MANDATORY] standards. Distribute Job Aid 8.6. Run Drills 5.1 (unannounced regulator) and 5.7 (acknowledgment of finding).

SME handoffs

  • §4.1–4.2 (Compliance framework + Safety/incident): Joe Lewis (COO) per the Training Matrix on the compliance framework + safety posture.
  • §4.3 (ADA): Joe Lewis (COO) on the compliance framework; the franchisee’s counsel adds the most operational value on jurisdiction-specific ADA exposure.
  • §4.4 (Insurance): Joe Lewis (COO); the franchisee’s insurance broker observes.
  • §4.5 (Data privacy + cybersecurity): Joe Lewis (COO) + Will Frank (Dev) on the technology stack dimensions.
  • §4.6 (Environmental + hazmat): Joe Frank (Ops) on the operational integration with site-area maintenance.
  • §4.7 (Regulator + law-enforcement): Joe Lewis (COO); franchisee’s counsel observes.

Decision drill — model answers (abbreviated)

Drill 5.1 — Unannounced regulator. First 5 actions per §13.7:

  1. Remain professional and cooperative. Greet the inspector politely
  2. Ascertain identity (badge or ID); agency (state DOL); purpose (overtime practices inquiry)
  3. Take photographs (if permitted by the inspector) and written notes of what the inspector requests, what the inspector inspects, what the inspector says
  4. Provide what the inspector’s lawful authority requires; do not volunteer beyond. For interviews of personnel: the franchisee may request that personnel interviews occur with counsel present or be rescheduled to accommodate counsel availability — depending on the inspector’s authority. For payroll records: provide what the inspector is entitled to inspect; do not provide extraneous documents
  5. Open a Partner Portal ticket under Compliance and Risk within 1 Business Day notifying HiON of the visit. Notify the franchisee’s counsel immediately. Cited basis: §13.7 [MANDATORY]

Drill 5.2 — Banking-update email. Decline to comply. §13.5 [MANDATORY] social-engineering standard. Verification protocol:

  • Identify red flags: domain similar but not exact; urgency (“Reply confirming by EOD Friday”); banking change instruction
  • Verify through independent channel: do not reply to the email; do not call any number listed in the email; locate HiON’s verified accounting contact from prior records (Partner Portal, FA, prior payment confirmations) and call them
  • Document the suspicious email and the verification process
  • If verified by the independent channel: HiON Accounting confirms or denies the request; act accordingly
  • If not verified (likely social engineering): preserve the email; report to HiON Compliance and Risk; report to the franchisee’s IT security The Manual is unambiguous: do not comply without verification.

Drill 5.3 — Injury during snow event. 8 actions per §13.2.2:

  1. Immediate safety: 911 if injury appears beyond minor; help the driver if trained and safe (do not move if back/neck injury possible); de-energize the bay if relevant safety concern (likely not)
  2. SEV 1 ticket via NOC Hotline (voice) and Partner Portal within 30 minutes
  3. Preserve the scene: do not modify the area; photograph from safe distance after scene secure
  4. Incident Report (Appendices form) within 24 hours
  5. Notify insurance broker per carrier’s incident timeline
  6. Cooperate with regulators / law enforcement if they arrive; notify HiON via Partner Portal within 1 Business Day
  7. No public statements about the incident; escalate any media inquiries per §11.5.3 (M08) + §3.2.5 (M02)
  8. No admission or denial of fault. Factual observations to first responders only (“driver fell at the bollard at approximately 11:30am during active snow event”); no legal conclusions (“we should have cleared the route faster”) Documentation: Partner Portal Incident Report; site-inspection log entry; snow-removal contractor service record; photographs; first-responder report number; witness contact info if voluntary.

Drill 5.4 — Site Host battery storage. Decline. §13.6 [MANDATORY] — no battery, accumulator, or energy-storage system at the HiON EV Facility other than those integral to HiON’s EV Charging Equipment. Path: explain to the Site Host that battery storage at the HiON EV Facility requires HiON written approval (default denial in current System posture); offer to escalate via Partner Portal if the Site Host wishes to pursue. The Site Host’s “behind-the-meter for property general electrical” framing does not exempt the proposal — the batteries are at the HiON EV Facility, which is the §13.6 standard’s trigger. Also potentially a §14.5 (M12) interoperability issue if the batteries could affect equipment.

Drill 5.5 — Accessible-stall obstruction. §13.3 + §10.4.3 (M11) [MANDATORY] violation. Corrective: move the toolbox immediately; complete the signage installation from an alternative staging location outside the accessible aisle; document the violation in the customer-interaction log and the §13 incident log if any driver experienced obstruction during the 2-hour period; brief the signage vendor on §13.3 with written acknowledgment per §8.5 (M09). “About 2 hours” is not an exception window.

Drill 5.6 — Insurance non-renewal notice. §13.4 [MANDATORY] requires notification to HiON within 3 Business Days of receipt — the 2-week delay is already a violation; correct it immediately. Next 3 actions:

  1. Notify HiON via Partner Portal under Compliance and Risk + notify the FBC. Document the non-renewal notice, the carrier’s stated reason, the timeline to non-renewal effective date
  2. Engage the franchisee’s broker (or replace if unresponsive) to identify replacement carrier with EV-charging-specific underwriting per §13.4 [RECOMMENDED]. Target replacement coverage in force before the non-renewal effective date
  3. If replacement coverage cannot be secured in time, escalate to HiON for any system-level resources (insurance market intelligence, broker introductions, or temporary endorsements). A lapse cannot be allowed Cited basis: §13.4 [MANDATORY] (no lapse; 3-Business-Day carrier notice notification).

Drill 5.7 — Acknowledgment of finding. Decline to sign without HiON prior written approval. §13.7 [MANDATORY] — no signing acknowledgments implicating HiON. The signage installation was HiON-approved; an acknowledgment of an AHJ finding about that installation implicates HiON. The franchisee politely declines: “I appreciate the finding. I need to route this through our franchisor before signing — that’s our process for findings that touch our system standards. I can have a signed response within 48 hours.” Next: open Partner Portal ticket under Engineering and Design Review + Compliance and Risk; provide the AHJ finding verbatim; await HiON’s direction on the acknowledgment language; engage counsel if the AHJ pushes back on the delay.

Drill 5.8 — Stolen laptop with HR data. Yes, §13.5 [MANDATORY] notification event. The laptop contained Personal Information (employee names, addresses, SSNs); SSNs trigger most state breach-notification laws. Next 3 actions:

  1. Notify HiON via Partner Portal under Compliance and Risk within 1 Business Day of discovery (which is today, since the franchisee just learned of the theft); the delay from Friday-evening theft to Monday-morning discovery is reasonable, but the 1-BD clock starts at discovery
  2. Engage the franchisee’s counsel on state breach-notification law obligations — most states require notification to affected individuals within 30-60 days, with attorney general notification thresholds for breaches above certain sizes
  3. Execute remediation: remote-wipe the laptop if possible; rotate any credentials accessible from the laptop; notify the affected employees; identify root cause; update the §13.5 cybersecurity baseline (laptops with PI should have full-disk encryption + auto-lock + remote-wipe)

Drill 5.9 — Settlement offer. Decline pending HiON written approval. §13.4 [MANDATORY] — no settlement, admission, or compromise of any claim implicating HiON without HiON prior written approval. Even if the claim does not facially implicate HiON, a slip-and-fall at a HiON EV Facility likely does — the conditions implicate the franchise’s §9.2 (M10) compliance + §13.3 (M14) accessibility. Next 2 actions:

  1. Notify HiON via Partner Portal + insurance broker (the broker leads the claim response per §13.4)
  2. Reject the DBM’s “make this go away” framing — the broker, counsel, and HiON are the decision-makers on settlement, not the DBM. Communicate to the driver’s attorney that the franchisee’s insurance carrier is handling the matter and will be in touch.

Drill 5.10 — Striping re-measure. §13.3 ongoing-maintenance requirement: “After any striping, paving, or landscape work, re-measure accessible dimensions before closing the work order.” The franchisee’s observation that the access aisle “appears narrower” is itself a §13.3 [MANDATORY] trigger. Next 2 actions:

  1. Re-measure the access aisle, the accessible stall, and the route. Compare against the applicable accessibility standard (federal 2010 + state/local where stricter). Document with photos and measurements
  2. If the re-measurement confirms a dimensional deficiency: do not close the work order; require the striping vendor to remediate; re-measure; close when in compliance. Document the cycle. If the deficiency is borderline, engage an accessibility consultant to verify. The audit posture is: if the franchisee cannot produce the post-work re-measurement record, the work was not closed properly.
  • A real (redacted) Compliance Register from the existing portfolio during §4.1
  • A real (redacted) Incident Report during §4.2
  • The 6 [MANDATORY] §13.3 ADA standards projected during §4.3
  • A real (redacted) phishing email during §4.5 — distribute to small groups to identify red flags

Section 10 · Cross-references

Modules

  • M01–M13 — every prior module touches §13 in some respect: voice (§13 confidentiality/IP); operations cadence (§9 maintenance + §10 customer experience integrate with §13.2 + §13.3); financial discipline (§12 Audit Fee + §13 cooperation); vendor onboarding (§14.2 cybersecurity + §13.5 social engineering)
  • M15 (Lifecycle) — records retention per §13 + §15.6; insurance certificates and incident reports retained for the longer of FA / §15 / carrier requirements

External documents

  • Operations Manual §13 (Compliance, Safety, Accessibility, Insurance, Risk — all subsections)
  • Franchise Agreement §13 (Insurance), §14 (Indemnification)
  • 2010 ADA Standards for Accessible Design + applicable state and local accessibility law
  • State data-breach-notification laws (CCPA, CPRA, CTDPA, VCDPA, etc.)
  • HiON Site Design Manual (chemical compatibility)
  • HiON Partner Portal — Compliance and Risk channel + security protocols
  • Operations Manual Appendices — Incident Report form

Section 11 · Source verification log

ClaimManual referenceStatus
12 compliance domains§13.1verified
3 [MANDATORY] §13.1 standards (counsel; Compliance Register; 1-BD notification)§13.1verified
4 [MANDATORY] §13.2.1 baseline safety standards§13.2.1verified
9 §13.2.2 incident categories§13.2.2verified
8-step incident procedure§13.2.2verified
24-hour Incident Report deadline§13.2.2 [MANDATORY]verified
No admission or denial of fault§13.2.2 [MANDATORY]verified
6 [MANDATORY] + 1 [LOCAL-LAW DEPENDENT] §13.3 ADA standards§13.3verified
2010 ADA Standards (or successor)§13.3 [MANDATORY]verified
Accessible-route obstruction prohibition§13.3 [MANDATORY]verified
Post-snow accessible route cleared before ordinary parking§13.3 ongoing maintenanceverified
5 [MANDATORY] §13.4 insurance standards§13.4verified
HiON named additional insured on primary-non-contributory basis with waiver of subrogation§13.4 [MANDATORY]verified
3-BD notification of carrier cancellation/non-renewal/material change§13.4 [MANDATORY]verified
No settlement/admission/compromise implicating HiON without HiON written approval§13.4 [MANDATORY]verified
6 [MANDATORY] + 1 [RECOMMENDED] §13.5 data privacy standards§13.5verified
1-BD notification of security incidents implicating Personal Information or HiON Confidential Information§13.5 [MANDATORY]verified
Social-engineering [MANDATORY] standard§13.5verified
4 [MANDATORY] + 1 [LOCAL-LAW DEPENDENT] §13.6 environmental/hazmat standards§13.6verified
No battery/accumulator storage other than integral to EV Charging Equipment§13.6 [MANDATORY]verified
3 [MANDATORY] §13.7 regulator/law-enforcement standards§13.7verified
No signing of acknowledgments implicating HiON without HiON written approval§13.7 [MANDATORY]verified
1-BD Partner Portal notification of regulator visits§13.7 [MANDATORY]verified
§13 Metrics audit posture§13.7 Metricsverified

Outstanding unverified items

#ClaimPrimary sourceResolver
M14.OUT.01FA §13 specific coverage requirements, limits, named-insured languageFA primaryJim Frank / counsel
M14.OUT.02FA §14 indemnification provisionsFA primaryJim Frank / counsel
M14.OUT.03HiON Site Design Manual chemical-compatibility listPartner PortalTony Cuomo / Eng & Design Review
M14.OUT.04Partner Portal security protocols for verificationPartner PortalJoe Lewis / Will Frank
M14.OUT.05Operations Manual Appendices — Incident Report formManual AppendicesJoe Lewis

Section 12 · Change log

VersionDateAuthorChanges
v0.12026-05-19Claude (draft)Initial draft against Operations Manual v1.0 Working Draft. All Manual citations verified. Five outstanding items defer to FA / Partner Portal / Manual Appendices primary. Closes Phase D (Operate). The §13.2.2 8-step incident procedure + §13.7 regulator-interaction discipline + §13.5 social-engineering resistance are the three highest-stakes pedagogical emphases.