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HomeMy WebLinkAboutContract 58678ST A TE OF TEXAS § CT S~CRETARY. c. J, :rR1\CT NO. -~'l.R , COUNTYOFTARRANT § TAX ABATEMENT AGREEMENT This TAX ABATEMENT AGREEMENT ("Agreement") is entered into by and between the CITY OF FORT WORTH, TEXAS ("City"), a home-rule municipality organized under the laws of the State of Texas ; PR CARTER DISTRIBUTION CENTER BUILDING F, LP, a Delaware limited partnership ("Carter") and RSI NORTH AMERICA, INC. a Delaware corporation ("Company"). RECITALS A. On January 29 , 2019, the City Council adopted Resolution No . 5337-01-2021, stating that the City elects to be eligible to participate in tax abatement and setting forth guidelines and criteria governing tax abatement agreements entered into between the City and various parties , entitled "General Tax Abatement Policy" ("Policy"), which is incorporated herein by reference and hereby made a part of this Agreement for all purposes . B. The Policy contains appropriate guidelines and criteria governing tax abatement agreements to be entered into by the City as contemplated by Chapter 312 of the Texas Tax Code, as amended ("Code"). C. On November 30 , 2021 , the City Council adopted Ordinance No . 25217-11-2021 ("Ordinance") establishing Tax Abatement Reinvestment Zone No . 102 , City of Fort Worth, Texas ("Zone"). D. Carter owns property located at 1501 Joel East Road , which is located within the Zone and is more specifically described in Exhibit "A" ("Land"), attached hereto and hereby made a part of this Agreement for all purposes . Contingent upon Company 's receipt of the tax abatement herein , Carter will lease the Land to Company on terms and conditions that permit the development of a manufacturing facility of at least 391 ,000 square feet (more specifically defined herein as the "Real Property Improvements") to support Company's business operations, and in which Company will install certain taxable business personal property on the Land, all as more specifically set forth in this Agreement. The lease of the Land between Carter and Company ("Lease") will contain terms and conditions consistent with those outlined in Exhibit "B", attached hereto and hereby made a part of this Agreement for all purposes. E. Under the Lease, Company is required to pay real property taxes on the Land and all improvements thereon , including the Real Property Improvements . In order for the full tax abatement necessary to provide incentive for this project to be undertaken , the City has been requested to grant an abatement on real prope11y taxes on improvements to the Land as well as an abatement on taxes on New Taxable Tangible Personal Property (as defined in Section 2) located on the Land . Section 312.204(a) of the Texas Tax Code permits the City to enter into an agreement with the owner of the Land to abate taxes on the value of improvements located on the Land, or of tangible personal property located on the Land, or both . Because Company must meet certain employment and spending commitments in order for the City to grant the full amount of abatement available hereunder on improvements to the Land , and because Company-wi ll.J1 h W R Tax Abat ement Ag ree men t betwee n C ity o f Fort Wo rth , PR Carter Di stribution Cent e r Building F, LP and RSI No rth Ame ric a Page I of 40 OFFICIAL RECORD CITY SECRETARY FT. WORTH, TX lessee of New Taxable Tangible Personal Property that is subject to abatement hereunder, it is necessary that both Carter and Company be parties to this Agreement. F. As of September 16 , 2021, one or more applications for tax abatement ( whether one or more , "Applications") to the City concerning plans for development of the Land, including construction of the Real Property Improvements, and taxes payable by Carter and Company, which Applications are attached hereto as Exhibit "C" and hereby made a part of this Agreement for all purposes . G. The contemplated use of the Land and the terms of this Agreement are consistent with encouraging development of the Zone and generating economic development and increased employment opportunities in the City, in accordance with the purposes for creation of the Zone, and are in compliance with the Policy, the Ordinance and other applicable laws , ordinances, rules and regulations . H. Under this Agreement, Company is committed to invest a total of at least $55 million as follows : at least $2.5 million in Construction Costs for the Real Property Improvements and at least $52.5 million in New Taxable Tangible Personal Property to be installed on the Land in connection with manufacturing business operations within the Real Property Improvements. Company is also committing to provide new Full-time Jobs whose average annual Salaries will equal at least $65,800.00. Therefore, the provisions of this Agreement, as well as the proposed use of the Land and nature of the proposed Real Property Improvements , as defined herein , satisfy the eligibility criteria for commercial/industrial tax abatement pursuant to Section 4 of the Policy . I. Written notice that the City intends to enter into this Agreement, along with a copy of this Agreement, have been furnished in the manner prescribed by the Code to the presiding officers of the governing bodies of each of the taxing units that have jurisdiction over the Land . NOW, THEREFORE, in consideration of the mutual benefits and promises contained herein and for other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the parties agree as follows: AGREEMENT 1. INCORPORATION OF RECITALS. The City Council has found, and the City, Carter, and Company agree, that the recitals set forth above are true and correct and form the basis upon which the parties have entered into this Agreement. 2. DEFINITIONS. In addition to terms defined in the body of this Agreement, the following terms have the definitions ascribed to them as follows : Abatement means the abatement of a percentage (not to exceed forty percent ( 40%) in any year of the Abatement Term) of the City's incremental ad valorem real property taxes on any improvements located on the Land (but not on the Land itself, which taxes will not be subject to Abatement hereunder) and of the City's incremental ad valorem taxes on New Taxable Tangible Personal Property, all calculated in accordance with this Agreement. Tax Abatemen t Agreement between City of Fon Worth , PR Caner Distribution Center Building F, LP and RSI North America Page 2 of 40 Abatement Term means the term of five (5) consecuti ve years , commencing on January I of the Second Operating Year and expiring on D ecember 3 1 of the fifth (5t h) year thereafter, in whi ch Carter and Company will receive the Abatement in accordance with this Agreement. Affiliate means a ll entities, incorporated or otherwise, under common control with , controlled by, or controlling Company . For purposes of this definition , "contro l" means fifty percent (50 %) or more of the ownership determined by either va lu e or vote . Annual Salary Commitment has the meaning ascribed to it in Section 4 .6.1. Annual Salary Percentage has the meaning ascribed to it in Section 6 .5. Applications has the meaning ascr ib ed to it in Recital F. Business Equity Firm{s) {"BEFs") has the meaning assigned to it in the City of Fort Worth 's Business Eq uity Ordinance, as amended (Chapter 20, Artic le X of the City Code). BEF Construction Commitment has the meaning ascribed to it in Section 4.4 . BEF Construction Percentage has the meaning ascribed to it in Section 6.3 . Certificate of Completion h as the meaning ascribed to it in Section 5 . Code has the meaning ascribed to it in Recital B. Completion Date means the date as of which all occupiable space within the Real Property Imp rovements have received a permanent certificate of occupancy. Completion Deadline means June 30, 2026. Compliance Auditing Term means the term of five (5) consecutive years , commenci ng on January I of the First Operating Year an d expirin g on December 3 1 of the fifth (5 th ) year thereafter, in which the City wil l verify a nd audit Carter's an d Company's comp li ance with the various commitments set fort h in Section 4 that form the basis for calcul at ion of the amount of each annual Abateme nt percentage hereunder. Construction Costs means the fo ll owing costs expended directly for the Real Property Improvements: actua l site development and construction costs , including directly-related contractor fees , plus costs of supp li es and materials, engineering fees , architectural and design fees, and permit fees. Construction Costs specifically excludes a ny real property acquisition costs or rent payments or other costs required by the Lease. Director means the director of the City's Economic Development Department. Effective Date has the meaning ascribed to it in Section 3. Event of Default means a breach of this Agreement by a party , either by act or omission , as more specifically set forth in Section 7 of this Agreement. Tax Aba tement Agreement be tween C ity of Fort Worth , PR Ca rter Di stributio n Center Building F, LP and RSI North America Pag e 3 of 40 First Operating Year means the first full calendar year following the year in which the Completion Date occurred. Full-time Job means a job provi ded to one ( 1) individual by Company on the Land for at least forty ( 40) hours per week. Land has the meaning ascribed to it in Recital D . Legal Requirements means federal, state and local laws , ordinances , rules and regulations , including , but not limited to, all provisions of the City 's charter and ordinances, as amended. New Job has the meaning ascribed to it in Section 4 .5.2 . New Taxable Tangible Personal Property means any personal property other than inventory or supplies that (i) is subject to ad valorem taxation by the City; (ii) is located on the Land; (iii) is owned or leased by Company and used by Company for the business purposes outlined in this Agreement; and (iv) was not located in the City prior to the period covered by this Agreement. 4 .2. Ordinance has the meaning ascribed to it in Recital C. Overall Employment Commitment has the meaning ascribed to it in Section 4.5. l. Overall Employment Percentage has the meaning ascribed to it in Section 6.4. Overall Improvement Percentage has the meaning ascribed to it in Section 6 .2 . Personal Property Improvement Commitment has the meaning ascribed to it in Section Policy has the meaning ascribed to it in Recital A. Real Property Improvement Commitment has the meaning ascribed to it in Section 4.1 . Real Property Improvements means a manufacturing facility constructed on the Land consisting of at least 391,000 square feet, as verified in the Certificate of Completion issued by the Director in accordance with this Agreement. Records has the meaning ascribed to it in Section 4.9 . Salary means the cash payment or remuneration made to a person holding a Full-time Job, including paid time off, commissions, and non-discretionary bonuses . A Salary does not include any benefits , suc h as health insurance or retirement contributions , reimbursements for employee expenses , or any discretionary bonuses . Second Operating Year means the second full calendar year following the year in which the Completion Date occurred . Term has the meaning ascribed to it in Section 3. Tax Abatement Agreem en t between C ity of Fort Worth , PR Carter Di stribution Center Building F, LP and RSI North America Page 4 of 40 Zone has the meaning ascribed to it in Recital C . 3. TERM. The effective date of this Agreement is December I , 2021 ("Effective Date") and, unless terminated earlier in accordance with it s terms and conditions, expires si multaneous ly upon expiration of the Abatement Term ("Term"). 4. OBLIGATIONS AND COMMITMENTS RELATED TO ABATEMENT. 4. 1. Real Property Improvements. 4.1.1 Carter and Company must expend or cause to be expended at least Two Million, Five Hundred Thousand Dollars and Zero Cents ($2,500,000.00) in Construction Costs for the Real Property Improvements by the Completion Date, and the Compl etio n Date for the Real Property Improvements must occur on or before the Completion Deadline ("Real Property Improvement Commitment"). Carter may perform this obligation in full by permitting Company to make or cause to be made the Real Property Improvements pursuant to the Lease . Failure to meet the afore mentioned obligation co nstitutes an Event of Default. 4.2. Personal Property Improvements. 4.2.1. New Taxable Tangible Personal Property having a value of at least Fifty- Two Million, Five Hundred Thousand Dollars and Zero Cents ($52 ,500,000.00) ("Personal Property Improvement Commitment") must be in place on the Land by January I , 2027 . Failure to meet the meet this obligation constitutes an Event of Default. 4.2.2. The Personal Property Improvement Commitment is an obligation of the Company only, and Carter does not have any responsibility to ensure that the Personal Property Improvement Commitment is met. 4.2.3. Th e value of the New Taxable Tangible Perso n Property is determined solely by the appraisal district having jurisdiction over the Land at the tim e and reflected in the certified appraisal roll recei ved by the City from such appraisal district in such year. 4.4. Construction Spending Commitment for BEFs. By the Completion Date, Company must expend or caused to be expended at least fifteen percent ( 15 %) of all Construction Costs for the Real Property Improvements with BEFs, regardless of the total amount of such Construction Costs ("BEF Construction Commitment"). 4.5. Employment Commitment. 4.5. 1. Company must employ and retain a minimum of 250 Full-Time Jobs on the Land by December 31, 2026 and retain suc h jobs for the Term of this Agreement ("Overall Employment Commitment"). The Overall Employment Commitment is an obligation of the Company only, and Carter does not have any Tax Abatement Ag ree me nt betwee n City of Fort Worth, PR Carter Di stribut ion Center Building F, LP and RSI North America Page 5 of 40 4.6 responsibility to ensure that the Overall Employment Commitment is met in any given year. 4.5.2 Company must retain at least 250 Full-Time Jobs on the Land for the Term of this Agreement (each a "New Job"). A Full-Time Job will be considered new if the individual was hired on or after November 30 , 2021 . 4.5.3 Determination each year of complian ce with the following Employment Commitment will be based on the employment data provided by Company to the City for the year under evaluation. Average Annual Salary. 4.6.1 In each year of the Compliance Auditing Term, the average annual Salary, measured on a calendar year basis , for at least 250 Full-Time Jobs provided and filled on the Land, regardless of the total number of such Full-time Jobs, must equal at least Sixty-five Thousand Eight Hundred Dollars and Zero Cents ($65 ,800.00) ("Annual Salary Commitment"). The Annual Salary Commitment is an obligation of the Company only, and Carter does not have any responsibility to ensure that the Annual Salary Commitment is met in any given year. 4.6.2. Determination each year of compliance with the following Annual Salary Commitment will be based on the employment data provided by Company to the City for the year under evaluation. 4.7. Reports and Filings. 4.7.1. Final Construction Report. Within sixty (60) calendar days following the Completion Date , in order for the City to assess whether Carter and Company expended or caused to be expended at least Two Million , Five Hundred Thousand Dollars and Zero Cents ($2,500,000 .00) in Construction Costs for the Real Property Improvements, and the extent to which the BEF Construction Commitment was met, Carter and Company must provide the Director with a report in a form reasonably acceptable to the City that specifically outlines the total Construction Costs expended for the Real Property Improvements and the total Construction Costs expended with BEFs for the Real Property Improvements, together with supporting invoices and other documents necessary to demonstrate that such amounts were actually paid, including, without limitation , final lien waivers signed by the general contractor for the Real Property Improvements. 4.7.2. Annual Employment Report. On or before February l of the Second Operating Year, and of each year thereafter for the remainder of the Compliance Auditing Term, in order for the City to assess the d e gree to which Company met in the previous year the Overall Employment Commitment and the Annual Salary Commitment, Company must provide the Director with a report in a form reasonably acceptable to the City that Tax Abatem ent Agreement be tween C ity of Fort Wo rth , PR Ca rt e r Di stributi on Cente r Bu ildin g F, LP and RSI Nort h America Page 6 of 40 sets forth the total number of individuals who held Full-Time Jobs on the Land , as well as the Sal ary of each , all as of December 31 ( or such other date requested by Company and reasonably acceptab le to the C it y) of the previous ca lendar year, together with reasonable supporting documentation. 4.7.3. General. Company will supply any additional information reasonably requeste d by the City that is pertinent to the City's evaluation of compliance with each of the terms and conditions of this Agreement. 4.8. Inspections of Land and Improvements 4.8 .1. At any time during Company 's normal business hours throughout the Term, the City will have the right to inspect and evaluate the Land, and any improvements thereon, and Company will provide full access to the same, in order for the City to monitor compliance with the terms and conditions of this Agreement. Company will use reasonable efforts to cooperate fully with the City during any such inspection and evaluation. City shall provide reasonable notice, being no less than 24 hours, to Company prior to visiting the Land for the purposes under this paragraph. City and Company shall work in good faith to coordinate such visits at a time and in a manner that minimizes disruption to the Company's operation. 4.8.2. Notwithstanding the foregoing, Company may require that any representative of the City be escorted by a Company representative or security personnel during any such inspection and evaluation and abide by any site policies and protocols regarding hea lth , safety, and treatment of Company's confidential information. ln addition, upon request of the City at any tim e during the Term and the year following the Term, and following rea so nable advance notice . 4.9. Audits. The City has the right throughout the Term to audit the financial and business records of Company that relate to the Real Property improvements, Personal Property, and the Land and any other documents necessary to evaluate Company's compliance with this Agreement or with the commitments set forth in this Agreement, including, but not limited to construction documents and invoices (collectively, "Records"). Company must make all Records available to the City on the Land or at another location in the City acceptable to both parties following prior notice and will otherwise use reasonable efforts to cooperate fully with the City during any audit. 4.10. Use of Land. The Land and any improvements thereon , including, but not limited to , the Real Property Improvements , must be used at all times during the Term of this Agreement for Company 's lawfu l business operations , a s se t forth in this Agreement, and otherwise in a manner that is consistent with the general purposes of encouraging development or redevelopment of the Zone . 4.11. Abatement Application Fee. Tax Abatement Agreement between C ity of Fort Worth , PR Carter Di stribution Center Buildin g F, LP a nd RSI North Americ a Page 7 of 40 4.11.1. The City acknowledges receipt from Company of the required Application fee of Five Thousand Dollars ($5,000.00). Of such amount, Two Thousand Dollars ($2,000 .00) is strictly nonrefundable and will be use d by the City for the purposes set forth in the Policy . 4.11.2. If construction work on the Real Property Improvements begins within one (I) year from the later date of the Applications, the remaining Three Thousand Dollars ($3,000 .00) of such fee will be credited to Company's benefit against any permit , impact , inspection or other lawful fee required by the City in connection with the Real Property Improvements. 4.11.3. If construction work for the Real Property Improvements does not begin within one (1) year from the later date of the Applications, Company will not receive a credit or refund of any portion of the fee . 4.11.4 If there is a balance of any of the remaining Application fee funds after the date on which the Director issues a Certificate of Completion in accordance with Section 5, Company will be entitled to a refund of such remaining Application fee funds , but only if Company submits a letter to the Director requesting such refund within ninety (90) calendar days following the date of issuance of the Certificate of Completion. 5. CERTIFICATE OF COMPLETION. Within ninety (90) calendar days following receipt by the City of the final construction spending report for the Real Property Improvements submitted in accordance with this Agreement, and assessment by the City of the information contained therein, if the City is able to verify that Construction Costs of at least Two Million, Five Hundred Thousand Dollars and Zero Cents ($2,500,000.00) were expended for Real Property Improvements by the Completion Date and that the Completion Date occurred on or before Completion Deadline, the Director will issue Carter and Company a certificate stating the amount of Construction Costs expended for the Real Property Improvements, as well as the amount of Construction Costs expended for the Real Property Improvements specifically with BEFs ("Certificate of Completion"). The Certificate of Completion will serve as the basis for determining whether the BEF Construction Commitment was met. 6. TAX ABATEMENT. 6.1. Generally. 6.1.2. Subject to the terms and conditions of this Agreement, provided that the Real Property Improvement Commitment and Personal Property Improvement Commitment have been met, then the City will grant an Abatement in each year of the Abatement Term. 6.1.3. The amount of each Abatement that the City grants during such years will be a percentage of the City's ad valorem taxes on any improvements located on the Land (but not on the Land itself, which taxes will not be subject to Abatement hereunder) and on New Taxable Tangible Personal Property attributable to increases in the value of such Tax Abatement Agreement between City of Fort Worth, PR Carter Distribution Center Building F, LP a nd RSI North America Page 8 of 40 improvements and New Taxable Tangible Personal Property, which percentage will equal the sum of the Overall Improv ement Percentage, the BEF Construction Percentage, the Overall Employment Percentage, and the Annual Salary Percentage, as set forth below (not to exceed forty percent (40%)). 6.2. Real Property Improvement and Personal Property Commitments (20%). City will grant an abatement to Company equal to twenty percent (20%) of the overall Abatement ("Overall Improvement Percentage") if Company meets both the Real Property Improvement Commitment and Personal Property Commitment. 6.3. BEF Construction Cost Spending (10%). A percentage of the Abatement will be based on the whether the Company met the BEF Construction Commitment ("BEF Construction Percentage"). If Company meets the BEF Construction Commitment, the BEF Construction Percentage for each Abatement hereunder will be ten percent (10%). If the Company does not meet the BEF Construction Commitment, the BEF Construction Percentage for each Abatement hereunder will be zero percent (0%). 6.4. Overall Employment (Up to 5%). 6.4.1. A percentage of the Abatement will be based on the extent to which the Company meets the Overall Employment Commitment ("Overall Employment Percentage"). The Overall Employment Percentage in a given year will equal the product of five percent (5%) multiplied by the percentage by which the Company met the Overall Employment Commitment in the previous calendar year, which will be calculated by dividing the actual number of Full-Time Jobs provided on the Land in the previous year by the number of Full-Time Jobs constituting the Overall Employment Commitment for that year. 6.4.2. For example, if Company only employed 200 individuals with Full-Time Jobs on the Land in 2028 instead of the required 250, the Overall Employment Percentage for the following year would be 4 % instead of5 % (or .05 x [200/250]), or .05 x .80, or .04. If the Overall Employment Commitment is met or exceeded in any given year, the Overall Employment Percentage for the Abatement in the following year will be five percent (5 %). 6.5. Annual Salary (5%). A percentage of the Abatement will be based on whether Company meets the Annual Salary Commitment ("Annual Salary Percentage"). If Company met the Annual Salary Commitment in a given year, the Annual Salary Percentage for the Abatement in the following year will be five percent (5%). If Company does not meet the Annual Salary Commitment in a given year, Company and Carter will forfeit the entire Abatement to which they would otherwi s e have been entitled in the following year. 6.6. Abatement Limitations. Tax Abatem ent Agree me nt be tw ee n C it y of Fo rt Worth , PR Carter Di stribution C ent er Building F, LP a nd RSI North Am eri ca Page 9 o f 40 6.6.1. In accordance with Section 15.5 of the Policy and notwithstanding anything to the contrary herein, the Abatement granted in any given year of the Abatement Term will be based on the following : 6.6.1.1 On the increase in the real property value of improvements on the Land over their value as of December 31 , 2022 , if any , up to a maximum increase of Two Million Fi ve Hundred Thousand Dollars and Zero Cents ($2 ,500 ,000.00); and 6.6.1.2 On the increase in the value of New Taxable Tangible Personal Property located on the Land since January I , 2022 , if any , up to a maximum increase of Fifty-Two Million Five Hundred Thousand Do ll ars a nd Zero Cents ($52 ,500 ,000 .00). 6.6.2. ln other words , with regard to the real property tax Abatement, in any year in which the taxable value of improvements on the Land exceeds (i) any value of improvements on the Land as of December 31, 2022 , if any , plus (ii) $2 ,500 ,000 .00 , the real property tax Abatement granted for that tax year will be capped and calculated as if the increase in the value of improvements on the Land since December 31 , 2022 had only been $2 ,500 ,000 .00. 6.6.2.1 By way of example only, ifin a given year of the Abatement Term the value of improvements on the Land is $3 ,000 ,000.00 over their va lu e as of December 31 , 2022 , the maximum real property tax Abatement that could be granted wou ld be forty percent (40 %) of $2 ,500 ,000.00 in valuation for that year and would pay full taxes on the $500 ,000.00 difference over the cap . Along the same lines , if the value of New Taxable Tangible Personal Property located on the Land in a given year of the Abatement Term is $60 ,000 ,000.00 over the value of that Property as of January 1, 2022, the maximum Abatement on New Taxable Tangible Personal Property that could be granted wo uld be forty percent (40%) of $52 ,500 ,000 .00 in va lu ation for that year and would pay full taxes on the $7,500,000.00 difference over the cap . 7. DEFAULT, TERMlNA TION AND FAILURE TO MEET VARIOUS DEADLINES AND COMMITMENTS. 7.1. Failure to Meet Real Property Improve ment and Pe rsonal Propertv Commitments. Notwith standing anything to the contrary herein, if the Company does not meet both the Real Property Improvement Commitment and Personal Property Commitment, an Eve nt of Default will occur and the City w ill have the right to terminate this Agreement, effective immediately, by providing writte n notice to Carter and Company without further obligation to Carter or Company hereunder. 7.2 Failure to Meet BEF Construction Commitment. If the Company does not meet the BEF Construction Commitment, or the Overall Employment Commitment in any given year, such event will not constitute an Event of T ax A batem ent A greement be tween C ity of Fo rt W orth , PR Ca rter D is tribution Center Building F, LP and RSI North America Pa ge 10 o f 40 Default hereunder or provide the City with the right to terminate this Agreement, but, rather, will only cause the percentage or amount of Abatement av ailable pursuant to this Agreement to be reduced in accordance with this Agreement. 7.3 Forfeiture for Failure to Meet Overall Employment or Annual Salary Commitments. Notwithstanding anything to the contrary herein , if the Company fail s to meet the Annual Salary Commitments in an y year of the Compliance Auditing Term , an Event of Default will not occur, but Carter and Company will forfeit the entirety of the Abatement that would otherwise have been granted in the following year. In this event, an Abatement will be deemed to have been granted in that year for purposes of calculating the remaining number of years in the Abatement Term and the number of future Abatements that Carter and Company will be entitled to receive . 7.4. Knowing Employment of Undocumented Workers. Company acknowledges that effective September 1, 2007 , the City is required to comply with Chapter 2264 of the Texas Government Code, enacted by House Bill 1196 (80th Texas Legislature), which relates to restrictions on the use of ce1tain public subsidies . Company hereby certifies that Company, and any branches, divisions, or departments of Company, does not and will not knowingly employ an undocumented worker, as that term is defined by Section 2264.001(4) of the Texas Government Code. In the event that Company, or any branch, division, or department of Company, is convicted of a violation under 8 U.S. C. Section J 324a(j) (relating to federal criminal penalties and injunctions for a pattern or practice of employing unauthorized aliens) and such violation occurs during the Term of this Agreement: • if such conviction occurs during the Term of this Agreement, this Agreement will terminate contemporaneously upon such conviction (subject to any appellate rights that may lawfully be available to and exercised by Company) and Company must repay, within one hundred twenty (120) calendar days following receipt of written demand from the City, the aggregate amount of Abatement received by Company hereunder, if any, plus Simple Interest at a rate of two percent (2%) per annum based on the amount of Abatement received in each previous year as of December 31 of the tax year for which the Abatement was received; or • if such conviction occurs after expiration or termination of this Agreement, subject to any appellate rights that may lawfully be available to and exercised by Company, Company must repay, within one hundred twenty (] 20) calendar days following receipt of written demand from the City, the aggregate amount of Abatement received by Company hereunder, if any, plus Simple Interest at a rate of two percent (2%) per annum based on the amount of Abatement received in each previous year as of December 31 of the tax year for which the Abatement was received. For the purposes of this Section 7 .6, "Simple Interest" is defined as a rate of interest applied only to an original value, in this case the aggregate amount of Abatement. This rate of interest can be applied each year, but will only apply to the aggregate amount of Abatement and is Tax Abate men t Agreement be twee n C ity of Fort Wo rth , PR Carte r Dis tributi o n Cente r Building F, LP and RSI No rth America Page 11 o f 40 not applied to interest calculated . For example , if the aggregate amount of Abatement is $10,000 and it is required to be paid back with two percent (2 %) interest five years later, the total amount would be $10 ,000 + [5 x ($10,000 x 0 .02)], which is $11 ,000 . Thi s Section 7 .6 does not apply to convictions of any subsidiary or affiliate entity of Company, by any franchisees of Company, or by a person or entity with whom Company contracts . Notwithstanding anything to the contrary herein , the parties agree that the Abatement is a "public subsidy" (a s that term is defined in Section 2264.00 I , Texas Government Code) for the benefit of Company and that , accordingly, this Section 7.6 does not apply to Carter. This Section 7 .6 will survi ve the expiration or termination of this Agreement. 7.5. Foreclosure on Land or Real Property Improvements. Subject to Section 11 , the City will have the right to terminate thi s Agreement immediately upon provision of written notice to Carter and Company of any of the following events: (i) the conveyance of the Land or the Real Property Improvements pursuant to an action to foreclose or otherwise enforce a lien, mortgage or deed of trust on the Land or the Real Property Improvements ; (ii) the involuntary conveyance to a third party of the Land or the Real Property Improvements; (iii) execution of any assignment of the Land or Real Property Improvements or deed in lieu of foreclosure to the Land or Real Property Improvements; or (iv) appointment of a trustee or receiver for the Land or Real Property Improvements and such appointment is not terminated within one hundred twenty ( 120) calendar days after the appointment occurs. 7.6. Failure to Pay Taxes or Non-Compliance with Other Legal Requirements. An Event of Default will occur if any ad valorem taxes owed to the City by Company become delinquent and Company does not timely and properly follow the legal procedures for protest or contest of any such ad valorem taxes, or Company is in violation of any material Legal Requirement due to any act or omission connected with Company 's operations on the Land; provided, however, that an Event of Default will not exist under this provision unless Company fails to cure the applicable failure or violation within thirty (30) calendar days ( or such additional time as may be reasonably required) after Company receives written notice of such failure or violation. 7.7. General Breach. ln addition to Sections 7. I -7 .6 and subject to Section 7 .4 , an Event of Default under this Agreement will occur if either party breaches any term or condition of this Agreement, in which case the non-defaulting party must provide the defaulting party with written notice specifying the nature of the Default. Subject to Sections 7.1 , 7.2 , and 7 .3 , in the event that any Event of Default hereunder remains uncured after thirty (30) calendar days following receipt of such written notice (or, if the defaulting party has diligently and continuously attempted to cure following receipt of such written notice but reasonably requires more than thirty (30) calendar days to cure, then such additional amount of time as is reasonably necessary to effect cure , as determined by both parties mutually and in good faith), the non- defaulting party will have the right to terminate this Agreement, effective immediately , by providing written notice to the defaulting patty. 7 .11. Statutory Damages. Tax Abate ment Agree ment between C ity o f Fo rt Wo rth , PR Cart e r Dis tribu tio n Cente r Buildi ng F, LP and RS I No rth Am eri ca Page 12 of 40 7.11. I Company acknowledges and agrees that termination of this Agreement due to an Event of Default by Company will (i) harm the City's economic development and redevelopment efforts on the Land and in the vicinity of the Land; (ii) req uire unplanned and expensive additional admi ni strative oversight and involvement by the City; and (iii) be detrimental to the City's general economic de ve lopment program s, both in the eyes of the genera l public and by other business entities and corporate relocation professionals , and Company agrees that the exact amounts of actual damages sustained by the City therefrom will be difficult or impossible to ascertain. 7.11.2 Therefore , upon termination of this Agreement for any Event of Default, and as authorized by Section 3 12.205(6 )( 6) of the Code, Company must pay the City, as damages authorized by the Code, an amount equal to all taxes that were abated in accordance with this Agreement for each year in which an Event of Default existed and which otherwise would have been paid to the City in the absence of this Agreement. 7.11.3 The City and Company agree that the above-stated amount is a reasonable approximation of actua l damages that the City will incur as a result of an uncured Event of Default and that this Section 7.11 is intended to provide the City with compensation for actual damages, as authorized by the Code, and is not a penalty . 7.11.4 The above-stated amount may be recovered by the City through adjustments made to Company's ad va lorem property tax appraisal by the appraisal district that has jurisdiction over the Land and over any taxable tangible personal property located thereon. Otherwise, this amount will be due, owing, and paid to the City within sixty (60) calendar days following the effective date of termination of this Agreement. 7.11.5 In the event that a ll or an y portion of this amount is not paid to the City within sixty (60) days following the effective date of termination of this Agreement, Company will a lso be liable for all penalties and interest on any outstanding amount at the statutory rate for delinquent taxes, as determined by the Code at the time of the payment of such penalties and interest ( currently, Section 33 .01 of the Code). 8. IN DEPENDENT CONTRACTOR. It is expressly understood and agreed that Carter and Company will operate as independent contractors in each and every respect hereunder and not as agents, representatives or emp lo yees of the City. As to the City, Carter and Company will have the exc lusive right to control all details and day-to-day operations relative to the Land and any improvements thereon and wi ll be solely responsible for the acts and omissions of their officers , agents, servants, emp lo yees, contractors, subco nt ractors, licensees and invitees . Carter a nd Company acknowledge that the doctrine of respondeat superior will not apply as between the C it y and Caiter or Company, their officers, agents, servants, emp loyees, contractors , subcontractors, licensees , and invitees. Carter and Company further agree that nothing in this Agreement will be construed as the creation of a partnership or joint enterprise between the City and Carter or Company . 9 . INDEMNIFICATION . Tax Abatement Agreement between City of Fort Worth , PR Carter Di stribut io n Center Building F, LP and RSI North America Page 13 of 40 9.1 COMPANY, AT NO COST TO THE CITY, AGREES TO DEFEND, INDEMNIFY AND HOLD THE CITY, AND ITS RESPECTIVE OFFICERS, AGENTS SERVANTS, REPRESENTATIVES, AND EMPLOYEES, HARMLESS AGAINST ANY AND ALL CLAIMS, LAWSUITS, ACTIONS, COSTS AND EXPENSES OF ANY KIND, IN CLUDING, BUT NOT LIMITED TO, THOSE FOR PROPERTY DAMAGE OR LOSS (INCLUDING ALLEGED DAMAGE OR LOSS TO COMPANY'S BUSINESS AND ANY RESULTING LOST PROFITS) AND PERSONAL INJURY, INCLUDIN G DEATH, THAT MAY RELATE TO, ARISE OUT OF OR BE OCCASIONED BY (i) COMPANY'S OR CARTER'S BREACH OF ANY OF THE TERMS OR PROVISIONS OF THIS AGREEMENT OR (ii) ANY NE GLIGENT ACT OR OMISSION OR INTENTIONAL MISCONDUCT OF CARTER OR COMPANY, ITS OFFICERS, AGENTS, ASSOCIATES, EMPLOYEES, CONTRACTORS (OTHER THA N THE CITY) OR SUBCON TRACTORS, RELATED TO THE REAL PROPERTY IMPROVEMENTS; THE LAND AND ANY OPERATIONS AND ACTIVITIES THEREON; OR THE PERFORMANCE OR NON-PERFORMANCE OF THIS A GREEM ENT OTHERWISE. THIS SECTION WILL SUR VIVE ANY TERM/NA TION OR EXPIRATION OF THIS AGREEMENT. 9.2 COMPANY HEREBY RELEASES CARTER FROM, AND COMPANY, AT NO COST TO CARTER, AGREES TO DEFEND, INDEMNIFY AND HOLD CARTER, AND ITS RESPECTIVE OFFICERS, AGENTS SERVANTS, REPRESENTATIVES, AND EMPLOYEES, HARMLESS AGAINST, ANY AND ALL CLAIMS, LAWSUITS, ACTIONS, COSTS AND EXPENSES OF ANY KIND, INCLUDING, BUT NOT LIMITED TO, THOSE FOR PROPERTY DAMAGE OR LOSS (INCLUDING ALLEGED DAMAGE OR LOSS TO COMPANY'S BUSINESS AND ANY RESULTING LOST PROFITS) AND PERSONAL I NJURY, INCLUDIN G DEATH, THAT MAY RELATE TO, ARISE OUT OF OR BE OCCASIONED BY COMPANY'S BREACH OF ANY OF THE TERMS OR PROVISIONS OF THIS AGREEMENT OR BY COMPA NY'S OR THE CITY'S PERFORMANCE OR NON- PERFORMANCE OF THIS AGREEMENT. THIS SECTION WILL SURVIVE ANY TERMINA TION OR EXPIRATION OF THIS AGREEMENT. 10. NOTICES. A ll written notices called for or required by this Agreement must be addressed to the following , or such other party or address as e ither party designates in writing, by certified mail , postage prepaid, or by hand delivery: City : City of Fort Worth Attn: City Manager 200 Texas Street F01t Worth , Texas 76102 With copies to : Company : RSI North America lnc. Attn : Mark Roe-Scott Address : 1024 Winters Parkway Dayton, NV 89403 City Attorney at the same address and the With copies to: Director at: City of Fort Worth Tax Abatement Agreement between PR Carter Di strib ution Center Building F, LP Attn : Dan Kane , Vice Presi dent City of Fort Worth , PR Carter Di st ributio n Center Building F, LP and RSI North America Page 14 of 40 Attn: Director Eco nomic Development 1150 South Freeway Fort Worth , Texas 76104 Address: 180 N. Stetson Ave., Suite 5400 Chicago, IL 6060 I 11. EFFECT OF SALE OF LAND AND/OR REAL PROPERTY IMPROVEMENTS; ASSIGNMENT AND SUCCESSORS. 11.1. Carter may assign this Agreement without the consent of the City Council, provided that Carter gives written notice to the City of the name and contact information for Carter assignee or successor in interest. Any lawful assignee or successor in interest of Carter of its rights under this Agreement will be deemed "Carter" for all purposes under this Agreement, and any such lawful assignee or successor will assume, and without further action by any party, Carter will be released from, all future liability and responsibility , if any , of "Carter" under this Agreement that accrues from and after the effective date of such assignment. 11.2 Company may assign this Agreement, and all or any of the benefits provided hereunder, without the consent of the City Council to (a) an Affiliate that leases, owns or takes title to the Land and owns or leases any New Taxable Tangible Personal Property or (b) a successor to Company by merger or consolidation only if (i) prior to or contemporaneously with the effectiveness of such assignment, Company provides the City with written notice of such assignment , which notice mu st include the name of the Affiliate and a contact name, address and telephone number for the Affiliate, and (ii) the Affiliate agrees in writing to assume all terms and conditions of Company under this Agreement. 11.3 Otherwise, Company may not assign , transfer or otherwise convey any of its rights or obligations under this Agreement to any other person or entity without the prior consent of the City Council, which consent will not be unreasonably withheld, conditioned on (i) the proposed assignee or successor agrees and proceeds to lease or take title to the Land and any New Taxable Tangible Personal Property ; (ii) the proposed assignee or successor is financially capable of meeting the terms and conditions of this Agreement; and (iii) prior execution by the proposed assignee or successor of a written agreement with the City under which the proposed assignee or successor agrees to assume and be bound by all covenants and obligations of Company under this Agreement. Any attempted assignment without the City Council's prior consent constitutes an Event of Default under this Agreement. Any lawful assignee or successor in interest of Company of all rights under this Agreement will be deemed "Company" for all purposes under this Agreement. 12. COMPLIANCE WITH LAWS. ORDINANCES. RULES AND REGULATIONS. This Agreement is subject to all applicable Legal Requirement s. 13. GOVERNMENT AL POWERS. It is understood that by execution of this Agreement, the City does not waive or surrender any of its governmental powers or immunities. 14. SEVERABILITY. Tax Abatement Agreement between City of Fon Wo rth , PR Caner Di stribut ion Center Building F, LP and RSI North America Page 15 of 40 If any provision of this Agreement is held to be invalid, illegal or unenforceable, the validity, legality and enforceability of the remaining provisions will not in any way be affected or impaired . 15. NO WA IVER. The failure of either party to insist upon the performance of any term or provision of this Agreement or to exercise any right granted hereunder will not constitute a waiver of that party's right to insist upon appropriate performance or to assert any such right on any future occasion. 16. VENUE AND CHOICE OF LAW. If any action, whether real or asserted , at law or in equity, arises on the basis of any provision of this Agreement, venue for such action will lie in state courts located in Tarrant County, Texas or the United States District Court for the Northern District of Texas -Fort Worth Division. This Agreement will be construed in accordance with the laws of the State of Texas. 17. NO THIRD PARTY RIGHTS. The provisions and conditions of this Agreement are solely for the benefit of the City, Carter, and Company, and any lawful assign or successor of Cai1er or Company, and are not intended to create any rights , contractual or otherwise , to any other persons or entities . 18. FORCE MAJEURE. It is expressly understood and agreed by the parties to this Agreement that if the performance of any obligations hereunder is delayed by reason of war, government action or inaction , orders of the government, epidemics, pandemics , civil commotion, acts of God, strike, inclement weather, shortages or unavailability oflabor or materials, unreasonable delays by the City (based on the then- current workload of the City department(s) responsible for undertaking the activity in question) in issuing any permits , consents, or certificates of occupancy or conducting any inspections of or with respect to the Land and Project Improvements, or other circumstances which are reasonably beyond the control of the party obligated or permitted under the terms of this Agreement to do or perform the same, regardless of whether any such circumstance is similar to any of those enumerated or not, the party so obligated or permitted will be excused from doing or performing the same during such period of delay , so that the time period applicable to such design or construction requirement and the Completion Deadline will be extended for a period of time equal to the period such party was delayed. Notwithstanding anything to the contrary herein, it is specifically understood and agreed that any failure to obtain adequate financing necessary to meet the Real Property Improvement Commitment or the Personal Property Commitment will not be deemed to be an event of force majeure and that this Section 18 will not operate to extend the Completion Deadline in such an event. 19. INTERPRETATION. In the event of any dispute over the meaning or application of any provision of this Agreement, this Agreement will be interpreted fairly and reasonably , and neither more strongly for or against any party, regardless of the actual drafter of this Agreement. In the event of any conflict between the body of this Agreement and the Applications , the body of this Agreement will control. Tax Abate ment Agreement between C ity ofFort Wo rth , PR Carte r Di stribut io n Center Building F, LP and RS! No rth America Pa ge 16 o f 40 20. CAPTIONS. Captions and headings used in this Agreement are for reference purpo se s only and will not be deemed a part of thi s Agreement. 21. ELECTRONIC SIGNATURES. This Agreement may be executed by electronic signature , which will be considered as an original signature for all purposes and have the same force and effect as an original signature . For these purposes , "electronic signature" means electronically scanned and transmitted versions (e .g . via pdf file or facsimile transmission) of an original signature, or signatures electronically inserted via software such as Adobe Sign . 22. COUNTERPARTS. This Agreement may be executed in multiple counterparts , each of which will be considered an original , but all of which will constitute one instrument. 23. BONDHOLDER RIGHTS. The Real Property Improvements will not be financed by tax increment bonds. This Agreement is subject to the rights of holders of outstanding bonds of the City . 24. CO FLICTS OF INTEREST. Neither the Land nor any improvements thereon are owned or leased by any member of the City Council, any member of the City Plan or Zoning Commission or any member of the governing body of any taxing unit with jurisdiction in the Zone . 25. NO LIAIBLITY TO CARTER Carter is consenting to the provisions of this Agreement as an accommodation to , and at the request of, Company. Accordingly, notwithstanding anything to the contrary contained herein , in no event will Carter be responsible for any damages , clawbacks , fees , penalties, interest, or increase in ad valorem taxes as a result of any default under this Agreement. Tax Ab at ement Agreemen t be tween City of Fon Wo nh , PR Caner Di stributio n Cente r Building F, LP and RSI onh Am erica Page 17 o f 40 26. ENTIRETY OF AGREEMENT. This Agreement, including any exhibits attached hereto and any documents incorporated herein by reference , contain s the entire understanding and agreement as between (i) the City , and (ii) Carter, and Company (together with any lawful assign and successor of Carter or Company), as to the matters contained herein. Any prior or contemporaneous oral or written agreement between (i) the City (on one hand), and (ii) Carter and Company (on the other hand), is hereby declared null and void to the extent in conflict with any provision of this Agreement. Notwithstanding anything to the contrary herein , this Agreement will not be amended by the City, and no amendm ent shall be binding on the City , unless executed in writing by both parties and approved by the City Council of the City in an open meeting held in accordance with Chapter 551 of the Texas Government Code . Notwithstanding the foregoing , as between Carter and Company, this Agreement shall not affect the Lease or any other agreement between or binding Carter and Company. EXECUTED as of the last date indicated below: [SIGN A TURES IMMEDIATELY FOLLOW ON NEXT THREE (3) PAGES] CITY: By: Date : T ( Tax Aba te men t Agreement between RSI NORTH AMERICA, INC., A Delaware corporation By fd Name: ~ ~"' -fC<. -i 1' Title : c."""' ------------ Date: C ity of Fo rt W o rth , PR Carter Di stribut io n Center Bui lding F, LP and RSI No rt h Ame ri ca Page 18 o f 40 PR CARTER DISTRIBUTION CENTER BUILDING F, LP, A Delaware limited partnership By : PR Carter Distribution Center Building F GP, LLC, A Delaware limited liability company and its general partner ~ ~ By ~~ Na;ne: ~£,. l(,M/2. Title: t/ Date: FOR CITY OF FORT WORTH rNTERNAL PROCESSES: Contract Compliance Manager: By signing, I acknowledge that I am the person responsible for the monitoring and JA..!:l----Ji;-"'=:::::::::::::::::::----~=1-m.i.t:l. istration of this contract, including By: Name: Title : Director, Economic Development Approved as to Form and Legality: By: Name: Tyler F. Wallach Title: Assistant City Attorney Contract Authorization: M&C: 21-0880 Form 1295 : 2021-816800 and 2021-803282 T ax Aba te me nt Agre e ment between ensuring all performance and reporting requirements. By : ~./1 .~ Name: Kellyaggett Title: Innovation Coordinator City Secretary: By: Name: Title: . C ity of Fort Worth , PR Carter Di stri buti on Center Building F, LP a nd RS I No rth America Page 19 o f 40 OFFICUAL RECORD CITY SECRETARY FT. WORTH, TX STATE OF TEXAS § COUNTY OF TARRANT § BEFO RE ME, the undersigned authority, on this day personally appeared William Johnson , Assistant City Manager of the CITY OF FORT WORTH , a municipal corporation organized under the laws of the State of Texas, known to me to be the person and officer whose name is sub sc ribed to the foregoing in strument, and acknowledged to me that the same was the act of the CITY OF FORT WORTH , that he was duly authorized to perform the sa me by appropriate re so lution of the City Council of the City of Fort Worth and that he executed the same as the act of the CITY OF FORT WORTH for the purposes and consideration therein expressed and in the capacity therein stated. GIVEN UNDER MY HAND AND SEAL OF OFFICE this l.1tt._day of '.bM.tM~ , 2022. C:?3rofi~~ the SJate of Texas 1 \ , [' Lt no..~ W\. r-n rr t t\ ~e Y' Notary's Printe d Name RSI NORTH AMERICA, INC. a Delaware corporation: STATE OF \t°'it\ <; § COUNTY OF .\Q..\f'((A,'(\ Y § • e@· Linda M . ~ir~ln;er - , My Commission Expires ◄ · * 2/2/2026 Notary ID 4 124144746 I BEFORE ME, the undersigned authority, on thi s day personally appeared N\O\~¼. a.oe-SGo-t'-\-- t.,. ~O of RSI NORTH AMERICA, INC., a Delaware corporation, known to me to be the person whose name is subscribed to the foregoing instrument, and acknowledged to me thats/he executed the sa me for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of RSI NORTH AMERICA, INC. \. 1 GIVEN UNDER MY HAND AND SEAL OF OFFICE this ___ '2._r ____ day of N t)\1e_,,'M B,e, '( , 2022. Nornry Pu&#&~ lr-~~~~~!!!!!!~!!:!!!l!:!.!!!!!!=!~~::f the State of :tf-'l<C\ S /:►':J:~~-;,,,. Lisa Brown f::*ti~ N · ~•• ••~ otary Public, State of Texas \•.:.. •'J Comm. Expires 11/14/2026 •,~~ ;t -<'fl' '"""'"""" Notary ID 1340564,-3 Notary's Printed Name Tax Abatem ent Agreement between C ity of Fon Worth , PR Caner Di stribution Center Building F, LP and RSI North America Pa ge 20 of 40 OFFICIAL RECORD Cl1Y SECRETARY FT. WORTH, TX ST A TE OF__,_\-'--"\ \i'--r\.0--=--\_J ___ § COUNTY OF (,00~ § -f/~ ~ BEFO~E, the undecsigned authority, on thi s day pecsonally appeared D..i-t-t' /: I,, ~'--~~ _____ of PR Carter Distribution Center Building F GP, LLC, a Delaware limited liability company, known to me to be the person whose name is subscribed to the foregoing in strument, and acknowledged to me that s/he executed the same for the purposes and consideration therein expressed , in the capacity therein stated and as the act and deed of PR Carter Distribution Center Building F GP, LLC. GIVEN UNDER MY HAND AND SEAL OF OFFICE this -~-Vl.d ______ day of 0 {l{;(V\~Y--'2022. ~~~' NotafyPiic in andfor the State of IL------ Tax Aba tement Agree ment between MEGHAN COOMEY Official Seal Notary Public -State of Illinois My Commission Expires Feb 16, 2025 City of Fo rt Worth , PR Carter Di stribution Center Building F, LP and RSI North America Page 2 1 of 40 EXHIBIT A DESCRIPTION AND MAP DEPICTING THE LAND BEING Lot I , Block A, Carter Distribution, an addition to the City of Fort Worth , Tarrant County , Texas , according to the plat thereof recorded in In strument Number 0219111864 , Plat Records of Tarrant County, Texas . ... I • Tax Abatement Agreement between i I ~ ,1501 Jee! ~a s1 d F::ir No ·,. TX 7b1 4 0 City of Fon Wonh, PR Caner Di stribu tion Center Building F, LP an d RSI Nonh America Page 22 of 40 Property Add ress: Property Owner: Tenant : Comm e ncemC'nl Date : Expiration Date : Ren table Area : Lease Term : Reliponsible Party: Landlord 's Notic e Address: Tenant's Notice A ddress: Tax Abatemenl Agreemenl belween EXHIBIT B LEASE TERMS LEASE ABSTRACT I SO I Joe l Easl Road Fort Worth, TX 76 134 PR Carler Dis tributi on Cenler Building F, LP RSI No rth Ameri ca Inc. May I. 2022 July 3 I. 2029 391.540 s quare feel 87 montl~~ NNN Property Taxes (Tenanl ) Property Ins urance (Tenanl) CAt\1 (Te nanl ) PGLvl, In c. Attn : Dan Kane, Vice Presidenl 18 0 N . Slelson Ave., S uile 5400 Chicago, n, 6060 1 RSI North America Inc . Alln : Mark Roe-Scoll , CFO 1024 Winlers Parkway Dayt on. NV 89403 City of Fort Worlh, PR Carter Di stribution Center Building F, LP and RSI North America Page 23 of 40 EXHIBITC TAX ABATEME NT APPLIC A TIO NS FORT WORTH ~ Economic Development Incentive Application Economic Development Department 1150 South Freeway Tax Abatem ent Agreement between Fort Worth , Texas 76104 (817) 871-6021 City of Fort Worth, PR Carter Distribution Center Building F, LP and RS I North America Page 24 of 40 Incentive Application L APPLICANT INFORMATlON Company Name . RSI North America , Inc. Company Address: 1024 Winters Parkway C ity Da on Sate NV ------ Date Sep 15, 2021 Zip 89403 Contact Person. Jacob Everett Title/Position: Consultant -Site Selection & Incentives ------------------ Telephone Number ------------------------------------ Mobi le Te lephone Number _7_65_-4--'2_5-_92-'-9_1 __________ Fax N umber· ____________ _ E-Ma il Address jeverett@mcguiresponsel com 1. If the applicant represents a Company: (If a Developer and not a Company, proceed to #2.) A. Company Ownership (chec k one)· 1 P ub licly Traded Stock f7 Privately Held B. Form of Business (choose one): _C_o~rpo_ra_t_io_n ___________ _ C How long has the company been in operation (Years)? Parent 14 years, US entity 2 years D. Company lndustry ._M_a_n_uf_a_ct_u_r_in~g ______________________________ _ E. Describe the Company's principal business: SmartCap is the world's first modular stainless steel truck cap system. From its 5--p iece modular design, to its seamlessly integrated accessones, SmartCap lets customers build and organize their truck beds to meet their exact needs. F Describe the Company's in ternat ional presence, ~ any Company 1s curre ntly headquartered and products are ma nufactured 1n South Africa . Items current ly sold in North Ameri ca are imported and sold through distributors. G Describe the Company's corporate citizenship practices. The company takes $15 from the sa le of every SmartCap and SmartCap Flat Bed and invests in early childhood development programs 1n disadvantaged communities. By better preparing child re n with the tools they need to succeed 1n school , the company 1s helping transform the individual lives of each of these kids. And that transforms their communities . 2. If the applicant represents II Developer: A. Describe the Developer's experience and background . Please include similar projects that you have constructed inclu<i ng the proJect type and location (attach add rti onal sheets as necessary): B. Deve lopment Partners (Arch itect , Engineering Team, Interior Design, General Contrac~ etc.) Page 2 of 6 Tax Abatement Agreement between C ity of Fort Worth , PR Carter Distributio n Center Build ing F, LP and RSI North Ameri ca Page 25 of 4 0 IL PROJECT INFORMATION Please include below the project descript ion, project benefits and how the proj ect positively impacts the community Any ince ntives given by the City should be considered only "gap' financing and should not be considered a substitute for debt and equity However , the City is under no obligation to provide gap financi ng just because a gap exists In order fo r a Company or Developer to be e ligible to receive incentives fo r a proJec~ the Company/Developer· A Must complete and submit this applicat ion and the appl ication fee to the City ; B. Company/Developer or Company/Developer's pri nci pals must not be delinquent in paying property taxes for any property owned in Fort Worth; C . Company/Developer or Company/Developer's princt pals must not have ever been su bject to the City of Fort Worth's Bu ilding Standard s Commission's Review , D Company/Developer or Company/Developer's prin ci pals must not have any City of Fort Worth hens filed agai nst any other property owned by the applica nt property owner/developer "Liens• includ es, but is not lim ited to, weed liens, demolition li ens, board-up/open structure liens and pav ing li ens. 1. Pro1ect Description (attach additio nal sheets as necessary): Company is looking to add a US manufacturing facility to serve North America (all products are curren~y imported from South Africa) The chosen location will become the North America n headquarters. Product design and prototyping will also happen in this fac ility 2. In what way will the project benefrt t he surrounding area or serve as a catalyst for add1t1onal development and/or business opportunities for the local economy (i.e . attra ct suppliers or customers)? The company will be establi shing a new s u pply cha in to feed this facility. T his wi ll create potentia l opportunities in the loca l area . 3. Desc ribe how the project positively impacts the co mmunity This project 1s esti mated to support 387 additiona l Jobs in the area in addit ion to the 250 employed in the facility (2 .55 mult1pl1er). II. PROJECT DETAILS 1. Proposed Proj ect Site Address . 1501 Joel East Road, Bu ilding F, Fort Worth , TX 76134 2. Proposed P roject Site Land Size (Acres):_2_1 _1_73 ________________________ _ 3. Will environmental remediation be required? _N_o _________________________ _ 4 Is this an ex isting fa cility or w ill a new facil ity be co nstructed? r New 17 Ex isting A If new, what is the construction Anticipated Start Date: ______ Anticipated Completion Date : _____ _ B. If ex1st 1ng , 1s this an adapt ive reuse?_N_o ___________________________ _ 5 Type of Project (choose one): Commercialllndustria l 6. Bu ild ing Area (Square Feet) Requ irements : (a ) Office _15_000 ___ _ (b) Manufacturin g (c) Warehouse (d) Showroom/Retail (e) Other 376000 Tota l Area (a+b+c+d+e): _39_1_00_0 ___ SF 7. Will this facility be LEED certified, and if so, at what level? _no _____________________ _ 8. Public o pen space included w ithin the proposed project s ite _Ncco _________________ SF/Acres Page 3 of 6 Tax Aba tement Agreement between City of fort Wo rt h , PR Carter Di stribut ion Center Building F, LP and RSI North America Page 26 of 40 II. PROJECT DETAILS (Continued) 9. If the applicant represents a Company: (If a OtNe/oper and not a Company. proceed to #10.) A. Is the Company expanding ,ts exIstIng loca l opera tions or relocating its operations from somewhere e lse to our area? r Expansion 17 Relocation B If a re location, where Is the company currently loca ted? South Africa This w ill be the first North American footprint C Does the com pany plan to lease or awn the facility in Fo rt Worth? 17 Lease I Own 0 . If the company is planning to lease space in Fort Worth, what ,s the lease term? 7 Years E. Describe the specific ope rat ions and services to be prov ided or products to be manufactured at the proposed Fort Worth fa cility (atta ch additi onal sheets as necessary) Company will manufacture truck cap systems ,n this facility These products convert truck beds into customized, v aluable tools for recreational or commerc ia l uses. Product design and prototyping will also happen In th is fa cility 10. Development requests that w ill be sought for the project (select all th at apply)· 1 Replat 1 Rezoning 1 Vari ances Current Zoning: ______ Requested Zoning : _____ _ If y es, please describe ____________________________ _ r Oowntawn Design Review Board r L andmark Commission r Public Infrastructure Assistance 11 Real Estate Investment A. Current Assessed Valuation of Land $_1,'-3_83-'''--45_3 _____ Improvements $_22-'-,1_08--'-,94_7 _________ _ B. T otal Construction Costs· $2.5 million --------------------------------- C . Hard Construction Costs: $ ---------------------------------12. Business Persona l P roperty and Inventory A. Business Personal Property Total investment on equipment, machinery, furnishing, etc. $ _________ r Lease 17 Purchase 'Estimated tax a ble v a lue of equipment, machinery, furrnshIng, etc : $ -'-5""2 "'.5-'m=111-',o-'-n ____________ _ "ThiJ is the val~ that wilt be on the tax rol/J which lnc/uMJ aH tang~ ~rty. B. Inventory and Supplies Value of Inventory $_T_B_O __________ Value of Supplies: $ ______________ _ Percent of inventory eligible fo r Freeport Exemption (inventory, exported from Texa s within 175 days) 13 Total Capita l Investment (Rea l Estate and Business Personal P roperty)·$ $55 million (202 1 _ 2026) IV. EMPLOYMENT AND JOB CREATION On the PrQject Site 1. Haw many persons are currently employed? _□ _________________________ _ 2. What percent of current employees above are Fort Worth residents? ____ % 3. What percent of current employees above are Central City residents? % Page4of 6 Tax Abatement Agree me nt between City of Fort Worth , PR Carter Distribution Center Building F. LP an d RSI North America Page 27 of 40 IV. EMPLOYMENT AND JOB CREATION (Continued} 4. Please complete the following table for new jobs to be created from direct hire by applicant. CurTently At Completion Estl!Mladly Estlmatad By Fifth YNr TenthYNr lllbilned Jobs nl• New Jobs to be Created 2S0 Total Jab&at Ploject 51111 250 % of Net Jobs to be fl ll ed by TBD Fort Worth Residents ""'Net Jabs to be fled Ii, TBD C8nlrll Clty resldenls 5. Please attach a description of the jobs to be created , tasks to be performed for each and wage rate for each classification. 6. Does the applicant pr011ide the following benefits · 17 Retirement 17 Health 17 Dental 17 Domestic Partner 7 Average wage paid to employees to be located at the project s ite : $ -'-65-'-'-'-8-'-00-'------------------ 8. Describe the Company's talent recruitment efforts: Ukely to Irdude a combination of local vocational schools, community colleges/universities, and NTEA & SEMA websites V. INCENTIVES REQUEST lncentIve(s) Requested: 17 Tax Abatement r Chapter 380 Economic Development Program Grant Do you intend to pursue abatement of County taxes? f7 Yes r No If requesting a Tax Abatement, please refer to the Ta x Abatement Policy for a comprehensive e xplanation of ehglbihty requ,rements . VI. LOCAL COMMITMENTS Pu rjn g Constructi on 1. What percent of the tota l construction costs described in Section Ill, Question 11 w ill be committed to A. Fort Worth businesses? % B. Fort Wort h Ce rt ified Minority and Women Business Enterp rises?_15 __ % For A nnua l Supp l)' and Serv ice Need s Regarding discretionary s~ lill.d .se!Y!Qe ~ (i.e landscaping, office or manufacturing supplies, Janttoria l services, etc., excluding utilities). 2. What Is the ann ual a mount of discretionary supply and service expenses? $ _T_B_D _____________ _ 3 What percentage will be committed to Fort V\brth businesses? ____________________ _ 4 What percentage will be committed to Fort V\brth Certified M inority and Women Business Enterprises? ______ _ VII. DISQ.OSURES Is any person or firm rece1Ving any form of compensation, commission or ot her monetary benefit based on the level of incent1Ve attained by the applicant from the City of Fort Worth? If yes, please explain and/or attach detail s Page 5 of 6 Tax Abatement Agree ment be tween City of Fort Wo rth , PR Cart e r Distribution Cente r Buil d ing F, L P a nd RS I North Ame ri ca Page 28 of 40 VIII . ADOmONAL INFORMATION rro BE ATTACHED) These documents must be submitted with the appl ication , otherwise the application will be deemed incomplete and will not be reviewed : a.) Attach a site plan of the project . b ) Explain why incentives are necessary fo r the success of this project. Include a business pro-forma or other documentat ion to substantiate your request. c.) Describe any environmental impacts associated w ith this project. d .) Describe the infrastructure improvements (water, sewer, streets , etc .) that w ill be constructed as part of this project. e.) Attach a talent recruitment plan , if applicable . f.) Attach a legal description or surveyor's certified metes and bounds description . g .) Attach a copy of the most recent property tax statement from the appropriate appra isal district for all parcels involved in the project . h .) Attach a brief descri ption of the employee benefit package{s) offered (i .e . health insurance . ret irement , public transportation assistance , day care prov isions , etc .) includ ing portion pa id by employee and employer respectively . i.) Attach a plan for the utilization of Fort Worth Certifi ed M/WBE companies . j .) Attach a listing of the ap plicant's Bo ard of Director's , if applicable . k.) Attach a copy of Incorporat ion Papers noting all principals , partners , and agents and all Fort Worth pro perties owned by each . I.) Attach the purchasi ng representative's compa ny contact information if known. The company is responsible for paying $5,000 as an application fee . If the appli cation is withd rawn before the proJec t Is presented to City Council in Executive Session , the fee is refunded Upon presentation to City Counci l in Open Session $2 ,000 is non-refundable and is applied to offset costs incurred by the Economic Development Department. Upon approval by City Council , the balance of $3,000 can be cred ited towards required bu il d ing perm its, inspections fees , replatt1ng fees. and other costs of doing business with the City related to ihe development Any unused cred it balance upon comp letion of the project wi ll be ref unded upon request from the company IX. CERTIFICATION On behalf of the appl icant, I certify the information contained in this application, includ ing all attachments to be true and correct. I further certify that, on behalf of the appl icant , I have read the current Incentive Pol icy and all other pertinent City of Fort Worth policies and I agree with the guidelines and criteria state therein . Printed Name: Dan Beaulaurier Title: Vice President Date: Sep 16 , 2021 Signature: °"' v Tax Aba temen t Agreement between City of Fon Worth, PR Caner Distribution Center Building F, LP and RSI North America Page 29 of 40 Proj ect Rugged Projected Stilffing Pl a n Headcount projections at calendar ye ar end : o 2022: 100 o 2023: 125 o 202 4 : 150 o 2025: 200 o 2026: 250 Pia nned positions: o Professional , Skilled, and Production : 242 jo bs o Acco untant o Accounting Clerk o Assembly o Bending o Deco iling + Laser o Factory Shift Manager o Finance Manage r o HR Clerk o HR Manager o IT Support o Logis t ics Manager o Paint o Prepping o Purchasing Mana ge r o Regional Sales Associate o Sales Support o Team Leaders o Warehouse Assistant o Warranty As sociate o Warranty Mana ge r o Welding o Corporate : 8 o average annual pay across the operation is expected to be $65,800 Tax Abatement Agreement between City of Fort Worth, PR Carter Distribution Center Bu ilding F, LP and RSI North America Page 30 of 40 Site Plan I BUILDING F l Tax Abatemen1 Agreement belween City of Fort Worth, PR Carter Di stribution Center Building F, LP and RS I No rth Americ a Page 31 of 40 • • Incentive Requirement The company is evaluating mult iple location options. Eva luation includes real estate, direct and indirect tax , incentives, and labor fa ctors across location options. The fact that Texas taxes personal property and inventory (unlike many other locations), especially given the significant amount of planned investment in equipment for this project, would have a significant negative impact on the operation's profitability . This issue is important to investo rs in the project when determining where to put their capital to work . Recent inflation is driving material, equipment, construction, and other costs to historical hig hs . Th is is putting significant pressure on cash flow in the years following capital projects and making the capital allocation process more competitive than ever. The tax phase in will help address some of these issues by allowing the operation to better adjust to rising costs while scaling up and reaching profitability requ ir ements over time . Tax Abatement Agreement between City of Fon Worth , PR Caner Distribution Center Building F, LP a nd RSI North Americ a Page 32 of 40 LEGAL DESCRIPTION OF REAL PROPERTY Building F Tract I: (FEE SIMPLE) BEING Lot 1, Block A, Carter Distribution, an addition to the City of Fort Worth, Tarrant County, Texas , according to the plat thereof recorded in Instrument Number 0219111864, Plat Records ofTarrant Co unty, Texas . Tract 2 : (E ASEMENT ESTATE) Easement appurtenant to and for the benefit ofTract I, over and across the land described therein : Non-excl usive easements as created by that certain Decl ar ation of Covenants, Conditions and Restrictions Applicable to Carter Distribution Center Phase 1, dated June 17, 2014, executed by Amon G. Carter Foundation, a Texas non-profit corporation, filed of record June 20, 2014 and recorded under Clerk's File No. 0214129686, Real Property Records, Tarrant County, Texas; As affected by Supplemental Declaration for Carter Distribution Center Phase I, filed of record March 24 , 2017 and recorded under Clerk 's File No. 0 217065523, Real Property Records, Tarrant County, Texas , as affected by Second Supplemental Declaration for Carter Distribution Center Phase I, f iled June 21 , 2019, recorded under Oerk's File No. 0 219134435, Real Property Records Tarrant County, Texas . Tax Abatem ent Agreement between City of Fort Worth, PR Carter Di stribution Center Building F, LP and RSI North America Pa ge 33 of 40 @ 2021 PROPERTY VALUE NOTICE 05-14-2021 TARRANT APPRAISAL DIS T RICT 2500 HANDLEY-EDERVILLE ROAD FORT WORTH , TX 76118 * ACCOUNT NUMBER: 42549424 * o file a protest and see add itional value , xemption and sales information , go to : www.TAD .org f Ori 7 GI RALDA FARMS FLOOR MA DISON NJ 07940 I 1111111111111111 111111111111111 IIIII IIIII IIII IIII JUNE 14, 2021 15 YOUR PROTEST DEADLINE 2020 Market Value For Questio ns Ptease Call: 2021 Market Va l ue 202 1 Apprai sed Val ue Messages l , 383 ,453 Values (817) 284-2025 2020 Appraised Value Address (817) 284--4063 l , 383 ,453 Exemotioos (817) 284--4063 l , 3 83 ,4 53 LAND 22 ,10 8 ,947 IMPR 23 ,492 ,4 0 0 TOTAL 23 ,492 ,4 00TOTAL For estimated taxes and rate Information go to: www.TarrantTaxlnfo.com IF YOU ARE THE CURRENT OWNER OF THIS PROPERTY OR THE AUTHORIZED AGENT YOU MAY VIEW A COMPLETE COPY OF THIS VALUE NOTICE ONLINE. TO DO SO , PLEASE LOGIN TO YOUR EXISTING ONLINE ACCOUNT TO VIEW THIS AND OTHER DOCUMENTS ON 'MY DASHBOARD'. FOR ASSISTANCE PLEASE GO HERE AND I OR CALL THE PHONE NUMBER ABOVE ON THIS NOT ICE . tt yoo di5a-i,oe w,th the proposed value. conloct the TARRANT APPRAISAL OISTRICT (TAD) al (817) 284-2025 . tt the APPRAISAL DISTRirT cannot resoiv<, the ~-yoo h""' the nghl lo ai,peal lo the APPRAISAL REVIEW BOARD (ARB). IN ORDER TD APPEAi. YOU !aJST Fl£ A WRITTEN PROTEST WITH Tl£ ARB NO LA"!El THAN JU NE 14, 202 1. Please relef ., the enclosad 111Slructioos lor delails oo how lo file a valid protest. A protest form lor the ,object property has been pfinted oo the ,..,.,.. side ol lhis notice The ARB heanngs begin June 1, 2021 al 2500 Handley-EdeMlle Road a:id will continue untl mt vahd protests have been hearo tt yoo lie a protest you wil rece,ye notice ol yoor heamg dale a:id llme al least 15 days befo<o lhe heanng TAD phone hnes are ve,y busy dunog the tm> Value NotJCes are produced . Please koep trymg , Tax Aba tement Agreement between City of Fon Wort h , PR Caner D istribution Center Building F, LP and RS I North America Page 34 of 40 Employee Benefits Package Specifics are still being d evelo pe d at this ti me , but there will like ly be med ica l, dental, visio n, 401k , vacation and PTO. Marr ied Domestic Pa rtne rs are expected to be covered by the benefits. Tax Abatement Agreement between City of Fort Worth, PR Carter Distribution Center Bui ld ing F, LP and RS I North America Page 35 of 40 Fort Worth Bus i ness Equ ity Firm Uti litz;ition Once a genera l co ntractor is selected for the Real Property Im provements -if the general contractor itself is not a Business Equity Firm -the company will work with t he genera l contractor to expend at least 15% of the construction costs with Cert ified Business Eq uity Firms . Tax Abatement Agreement between City of Fort Worth, PR Carter Di stributi o n Center Building F, LP and RSI North America Page 36 of 40 Delaware The First State I , JEFFREY r.r . BULLOCK , SECRETARY OF STATE OF THE STATE OF DELAWARE , DO HEREBY CER.TIFY THE ATTACHED IS A TRUE AND CORRECT COPY OF THE RESTATED CERTIFICATE OF "RSI NORTH AMERICA, INC .", FILED IN THIS OFFICE ON THE TtiENTY-NINTH DAY OF SEPTEMBER., A .D . 2020 , AT 2 :46 O 'CLOCK P .M. Page 1 7471720 8100 SR# 20207542699 Auth ent i catio n : 2037663 22 Date: 09-30-20 You may veri f y t his cer t ific ate online at corp.del awar-e.g ov/authver.sh tml Tax Abatement Agreemen t between City of Fort Worth , PR Carter Distribution Center Building F, LP and RS I North America Pa ge 37 of 40 Stllf or Otu11r1rr SfmlU) or S111, OM, .. , of Corpora 1lo11 Odl.-.ml 02:l4 P.11 0,12' 2020 FlllO 02 :~6 ~r 09r1M020 R l0.!0 754!699 • Filo ;';umbtr m 20 RESTATED CERTIFICATE m· 1 CORPORATION OF RSI NORTH AMERICA, INC. (Pursuant to Sections 242 and 245 of the Gem:ral Corpordtion Law of the State of Delaware) RSI orth America. Inc .. a corporation organized and existing under and by virt ue of the provisions of the General Corporation Law of the State of Delaware (the uDGCL j. DOES HEREBY CERTIFY: I . That the name of this corporation is RSI North America, Inc ., and that this corporation was originally incorporated pursuant to the DGCL on June 17 2019 under the name RSI orth America, lnc . 2. That the Bo ard of Directors dul y adop ted resolutions proposing to further amend and restate the Certificate of Incorporation of this corporation, declaring said amendment and restatement to be advisable and in the best interests of this corporation and its stockholders, and authorizing the appropriate officers of this corporation to solicit the consent of the stockholders therefor. which resolution setting forth the proposed amendment and restatement is as follows : RESOLVED , that the Certificate of Incorporation of this corporation be furt her amended and restated in its entirety to read as follows: FIRST : T he name of the corporation is: RSI North America, Inc. (the ··Corporation"). SECOND : Its registered office in the State of Delaware is located at 16192 Coastal Highway, Lewes, Delaware 19958, County of"Sussex. The registered agent in charge thereof is Harvard Business Services, Inc . THIRD : TI1c purpose of the corporatio n is to engage in any lawful activity for , hich corporations may be organized under the Geueml Corporation Law of Delaware. FO RTH : The total number of shares of stock which the corporation is authorized to issue is 150.000 shares having a par vaJue of $0.0 I 00000 per share. No dividend shall be declared or paid until all claims against the Corporation by any stockholder for amounts credited to suc h stockholder's loan account witb the Corpor.ition have been repaid in full. Thereafter. the board of directors of the Corporation (the '·Boartf') ma y declare and pa _ dividends upon the o ut standing shares of stock of the corporation from time lo time and to such extent as they deem advisable. in the manner and upon the tenns and conditions provided by the DGCL and the Bylaws of the Corporation. FIFTH : The business and affairs of the corporation shall be managed by or under the direction of the Board , and the directors of the Corporation need not be elected by ballot unless required by the by laws of the corporation. Tax Abatement Agreement between City o f Fort Worth, PR Carter Di stributi on Center Buildin g F, LP and RSI North America Page 38 of 40 SIXTH : The Corporation shall be perpetual unless otherwise decided by a majority of the Board . SEVENTH : In funherance and not in limitation of the powers conferred by the laws of Delaware. the Board is authorized to amend or repeal the bylaws. EIGHTH : The Corporation reserves lhe right lo amend or repeal any provision in this Cenificate of Incorporation in the manner prescribed by the laws of Delaware . NINTH: The incorporator is Ilarvard Business Services. Inc .. whose mailing address is 16192 Coastal Highway. Lewes. DE 19958. TENTH : To the fullest extent permitted by the DGCL a director of this corporation shall not be liable to the corporation or its stockholders for monetary damages for breach of fiduciary duty as a director. I. the undersign.:d. do make and file thi s r.:stated certificate . and do certify that the facts herein stated arc true; and have accordingly signed below this August ·, 2020. Signed and Alll .. -slcd 10 by: Tax Abatement Agreement between 2 Name: Michael Voss Title: President City of Fort Worth, PR Carter Di stribution Center Building F, LP and RSI North America Page 39 of 40