Attendance at lectures, meetings, training programs and similar activities need not be counted as working time if the following four criteria are met:

1. (a) Attendance is outside of the employee's regular working hours;
2. (b) Attendance is in fact voluntary;
3. (c) The course, lecture, or meeting is not directly related to the employee's job; and
4. (d) The employee does not perform any productive work during such attendance.