Is this plan design a "safe harbor" 401(k) plan?

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A calendar year plan sponsor starts a new safe harbor 401(k)plan on 10/01/00, having given timely notice, with an effective date of 01/01/00 (mostly for p/s purposes). 100% of deferrals up to 4% of comp is the safe harbor contribution. Deferrals begin 10/01. Employees can do normal deferrals and also elect to defer up to 100% of bonuses received in December. The employer bonuses everyone at least 4% of annual comp, which they defer. Employer deposits the safe harbor match of 4% of comp. Does this arrangement qualify as a safe harbor plan?