EMPLOYEE HANDBOOK · month, the Company’s Human Resources Department will run reports to identify licenses due to expire ... reference checks. This process is conducted for security

EMPLOYEE HANDBOOK

NaphCare, Inc. January 1, 2020 Page 2 of 33

TABLE OF CONTENTS

Table of Contents ............................................................................................................... 2 A Welcome Message from Our Chairman of the Board ....................................................... 4 About Your Job .................................................................................................................. 5

Employee Categories .......................................................................................................... 5 Introductory Period ............................................................................................................ 5 License and Credentialing ................................................................................................... 5 Security Checks and Background Checks .............................................................................. 6 On The Job Training ........................................................................................................... 6 Continuing Education Program ............................................................................................. 6 Working Hours .................................................................................................................. 7 Overtime .......................................................................................................................... 7 Lunch and Breaks .............................................................................................................. 7 Payroll Information ............................................................................................................ 7 Time Cards ....................................................................................................................... 7 Resignation ....................................................................................................................... 8 Rehires ............................................................................................................................. 8 Employment of Relatives .................................................................................................... 8 Consensual Romantic Relationships ...................................................................................... 8 Business Mileage Reimbursement ........................................................................................ 9 Business Travel ................................................................................................................. 9 Expense Reimbursement .................................................................................................... 9

Your Employee Benefits ................................................................................................... 10 About Your Benefits ..........................................................................................................10 Eligibility for Benefits.........................................................................................................10 Health, Prescription,Dental and Vision Insurance ..................................................................11 Company Paid Life Insurance .............................................................................................11 Voluntary Benefits ............................................................................................................11 COBRA ............................................................................................................................11 401(k) Plan ......................................................................................................................12 Education/Tuition Reimbursement .......................................................................................12 Referral Bonus ..................................................................................................................12 Provider Referral Bonus .....................................................................................................12 Workers’ Compensation .....................................................................................................13 Unemployment Compensation ............................................................................................13 Employee Assistance Program ............................................................................................13

Time Off From Work ......................................................................................................... 14 Paid Time Off ...................................................................................................................14 PTO Rollover Policy ...........................................................................................................14 PTO Payout ......................................................................................................................14 Extended Sick Bank ..........................................................................................................14 Generosity Clause .............................................................................................................15 Holidays ..........................................................................................................................15 Jury Duty .........................................................................................................................15 Family and Medical Leave Act (“FMLA”) Leave ......................................................................15 Employee Military Leave ....................................................................................................18 Bereavement Leave ..........................................................................................................18 Inclement Weather Procedures ...........................................................................................18 Voting .............................................................................................................................18

Your Career Development ................................................................................................ 19 Performance Appraisals .....................................................................................................19 Job Bidding and Promotions ...............................................................................................19 Internal Transfers to Different Departments or Sites .............................................................19

What We Expect From You ............................................................................................... 20 Understand the Need for Constructive Counseling .................................................................20 Give Us Quality Work ........................................................................................................20 Be Health and Safety Conscious ..........................................................................................20 Be Alert to Security and Abide by Facility Rules ....................................................................20 If You are Barred from Facility ............................................................................................21 Observe Our Rules on Workplace Smoking ...........................................................................21


Restrict Personal Phone Calls ..............................................................................................21 Use of Personal Cell Phones/Electronic Devices .....................................................................21 Keep Us Up-To-Date .........................................................................................................22 Keep Compensation Confidential .........................................................................................22 Remember Courtesy..........................................................................................................22 Be Aware of Your Personal Appearance ................................................................................22 Respect Confidential Information ........................................................................................23 Protect Company Information .............................................................................................23 Keep Personal Visitors Away ...............................................................................................23 Respect Our Policies on E-mail, Computers, and Other Company Provided Equipment ...............23 Mobile Devices .................................................................................................................24 Restrict Conflicting Outside Activities ...................................................................................25 Obey Our Solicitation and Distribution Rules .........................................................................25 Follow Common Sense Standards of Conduct to Avoid major Offenses .....................................25 Comply With Our Standards of Attendance ...........................................................................26 Maintain a Drug and Alcohol Free Workplace ........................................................................27 Problem Resolution Procedure ............................................................................................27 Corporate Compliance Program ..........................................................................................28 Workplace Violence ...........................................................................................................28 No Harassment .................................................................................................................28

The Company’s Responsibilities ....................................................................................... 29 Management Rights ..........................................................................................................29 Affirmative Action/Equal Opportunity Employment ................................................................29 Guidelines for this Handbook ..............................................................................................29 Employees Subject to Collective Bargaining Agreement .........................................................30


A WELCOME MESSAGE FROM OUR CHAIRMAN OF THE BOARD Welcome to NaphCare—we’re glad to have you on our team. Having started nearly three decades ago, we continue to build upon a successful track record of client satisfaction, financial stability and growth, and employees with a workplace that breeds excellence. NaphCare takes great pride in continually improving quality performance and service, while earning our clients’ respect. We continue to recruit and retain the most qualified employees, the driving force behind our success. We are constantly focused on maintaining our strengths to earn our clients’ respect, partner with our customers and value our greatest asset – our employees. Thank you for your commitment to NaphCare and I look forward to you becoming a valuable member of our team. Sincerely, James S. McLane Chairman of the Board


ABOUT YOUR JOB Employee Categories All employees are classified as either “exempt” or “non-exempt” for purposes of determining entitlement of overtime pay.

• Exempt employees are generally paid a salary and meet the requirements for one of the

exemptions under the Fair Labor Standards Act (FLSA). Exempt employees are not eligible for overtime pay.

• Non-exempt employees are generally paid hourly and do not qualify for an exemption under the FLSA. Non-exempt employees are eligible for overtime pay as described in the “Overtime” section of this Handbook.

All NaphCare employees are classified as full-time, part-time, PRN, or temporary. This status is determined and agreed upon hire. Actual hours worked are not the determinant for an employee’s status. An employee’s classification of status determines eligibility of benefits that are discussed in the Employment Benefits section of this Handbook. A change in status must be agreed upon in writing with updated employment paperwork submitted to the NaphCare corporate office. Definitions for each classification are as follows:

• Full-Time employees are those employees hired to fulfill one contracted full-time position according to specific facility contractual obligations. In most facility contracts this is a forty (40) hour a week position.

• Part-Time employees are those employees hired to fulfill contracted hour requirements making up less than one contractually obligated full-time position, but regularly scheduled in an established position.

• PRN or “Pro Re Nata” employees are those employees that are not regularly on the schedule and do not make up an established position. These employees are hired to fill vacancies in the schedule when necessary.

• Temporary employees are employees hired for a limited period of time. Introductory Period All employees accepting a new position with the Company are subject to a ninety (90) day Introductory Period or Probationary Period. During this time employees will be oriented on company policies and procedures, specific job functions, facility rules and regulations, and the employment standards the Company requires. This Period gives the Company an opportunity to assess your performance and to predict your continued success. It also allows the employee time to evaluate NaphCare and the position in which they have been hired. All employees are required to meet and maintain Company standards for performance and behavior at all times during employment. Due to the nature of our business it is important that both the Company and the employee evaluate their position throughout the Introductory Period to determine future success. Excessive absence, poor performance, misconduct, or other failure to meet Company standards is grounds for discipline, up to and including termination, both prior to the conclusion of the Introductory Period and at any time thereafter. During the ninety (90) day Introductory Period and thereafter, you are an employee at-will and may be terminated for any reason with or without cause. Your successful completion of the Introductory Period does not alter your status as an at-will employee or afford you any additional rights or guarantees to continued employment. License and Credentialing NaphCare understands the significance in granting privileges to health care staff and takes pride in our staff’s representation of the Company as a whole. Our system for privileging licensed and certified health care professionals goes beyond the essential basics for safe offender care by not only ensuring that all health care personnel meet the minimum facility requirements for licensing, certification, and/or


registration but also the minimum NaphCare requirements. NaphCare goes above industry standards by requiring all health care staff to not only hold valid licenses and certificates, but that those credentials are also without restrictions. NaphCare requires that anyone employed with the Company maintain the licenses and certifications required by his or her position (to include any agreements required by a state board of nursing or medicine for collaborative practice purposes). All licenses will be verified using primary source verification and a copy of the verification will be maintained in the employee’s personnel file. Every month, the Company’s Human Resources Department will run reports to identify licenses due to expire and notify each employee’s manager. Occupational licenses are a requirement to be able to work any shift, including orientation. If an employee’s occupational or CPR license expires, he or she will immediately be taken off the schedule, and suspended without pay. The suspension without pay shall continue until the employee presents their manager with a current, valid license. This absence may affect an employee’s benefits and employment status with the Company. If the employee is unable to present a current, valid license within five (5) days of the suspension, employee may be subject to disciplinary action, up to and including, termination. Security Checks and Background Checks NaphCare conducts and/or uses a third party administrator to conduct background checks on all job candidates once a contingency offer has been made. The type of information collected includes, but is not limited to, a criminal background check, education, employment history, credit checks, drug testing, professional license history, and professional and personal reference checks. This process is conducted for security measures and to verify the accuracy of the information provided by the candidate. Due to the nature of our business, candidates that knowingly provide false information of any kind may not be considered suitable for employment. The Company also reserves the right to make the sole determination for employment or any employment decision based on the results of the background check. All candidates are required to sign NaphCare’s Investigation Consent Form authorizing the completion of the background check. Your employment is contingent upon initial and continued security clearance as defined by Company and facility policies. The Company will ensure that all background checks are held in compliance with applicable federal and state statutes. On The Job Training NaphCare ensures that all new personnel are properly cleared for entry into the facility, and that they are provided with orientation and appropriate training regarding on-site medical practices and security. All newly hired, full-time health care personnel will receive 40 hours of pre-service training and orientation within the first 30 days of employment. The training we provide meets the recommendations and guidelines mandated by Federal, State, and local guidelines (OSHA, JCAHO, NCCHC, and ACA). As an added service, all employees receive monthly, quarterly, and annual education and training assignments as reminders. These reminders ensure compliance with education and training requirements. Job-specific education programs are also assigned to job categories in order to maximize each employee’s training experience. Employees also receive security-related training, confidentiality training, and access to classes through online training. Continuing Education Program NaphCare wants to invest in our employees. We recognize the value of educated and well-informed health care professionals, and want our employees to reach their full potential within the Company. Therefore, we provide our health care professionals with 12 hours of comprehensive, correctional-specific education that complies with NCCHC and ACA education standards for certification. NaphCare also provides pertinent monthly in-service education programs based on issues identified by


our Continuous Quality Improvement (CQI) program. Working Hours NaphCare maintains working hours to meet the needs of our individual clients and facilities and are compliant with each contract. Standard hours of work for all full-time employees consist of forty (40) hours a week. This may vary depending on contract requirements. However, all full-time employees are required to prioritize NaphCare as their primary employer and any outside employment responsibilities, including education, is secondary to their position with NaphCare. Schedules and shift hours are subject to change to meet the needs of patient care and facility contracts. The Company is not required to account for outside activities secondary to NaphCare employment obligations. Your supervisor will inform you of any changes. All employees are expected to be at their assigned workstation, ready to work, at the beginning of their shift. Just as you take into account traffic during your commute, each facility has different security measures that are required before entering and should be taken into account in order to reach your workstation at the start of your shift. Overtime Non-exempt employees will be paid one and-a-half times their regular rate of pay for all hours worked in excess of forty (40) hours per week. Overtime will be based only on actual hours worked. PTO cannot contribute to overtime. Overtime is calculated when an employee works in excess of forty (40) hours a week or as specified by state law. Exempt employees are not entitled to overtime pay. All overtime, including time accrued during the thirty (30) minute meal period, must be approved in advance by your supervisor. An employee’s failure to obtain approval may be subject to disciplinary action up to and including termination. Lunch and Breaks Employees working for periods of four (4) consecutive hours or more not already broken by a meal period are permitted by law to take a fifteen (15) minute break period when practical. Employees that choose to forego these break periods are not permitted to save breaks for the end of a shift to leave early and break periods cannot be combine with other breaks to extend break times. Employees that choose to take break periods are required to be punctual and are not permitted to leave the premises during that time. Employees are required to take a thirty (30) minute meal break during any shift of six (6) or more hours. Meal periods are unpaid and should be taken in one consecutive timeframe. A second meal period is permitted for shifts of thirteen (13) hours or more. Employees must follow facility policies with regards to leaving the premises during a meal period. Working through a meal break must be pre-approved by your supervisor. Payroll Information NaphCare employees are paid bi-weekly, every other Friday, with twenty-six (26) pay periods a year. For all non-corporate employees the workweek begins on Sunday at 12:01 a.m. and ends on the following Saturday at 12:00 a.m. (Midnight). If a payday falls on a recognized Company Holiday, you will be paid on the last standard business day prior to the Holiday. Time Cards All employees are required to clock in and out for each shift and each meal period. Any corrections to hours worked should be reported to your supervisor for review and approval. Any approved changes must


be submitted to the payroll department no later than 12:00 p.m. central standard time on the Monday preceding payday to ensure timely processing. Any corrections made after payroll has been processed will be reflected on the next pay period. At no time are employees permitted to clock in or out for another employee. Missed punches can only be submitted to an employee’s manager for correction. The intentional falsification of time for you or another employee is considered a serious offense and will result in discipline up to and including termination. Under no circumstances should you ever work off the clock, even if requested to do so by your supervisor. Any employee who is requested to work off the clock or who suspects that his or her hours have been inaccurately reported should contact the Legal Department. Resignation All NaphCare employees impact the health care services the Company is contracted to provide. It is therefore, the expectation of the Company that employees provide adequate notice in writing to an immediate supervisor prior to employment resignation. There are certain employees whose job functions are key to the health care services provided and impact the medical care provided by the Company. These are employees who occupy positions in which there is either no departmental back up or PRN support staff to step in should the employee resign. For these employees NaphCare requires a one month written notice to an immediate supervisor prior to resignation from employment. Persons employed in a management or supervisor role including but not limited to Physicians, Dentists, Psychiatrists, Nurse Practitioners, Physician Assistants, Health Service Administrators, Directors of Nursing, and Nursing Supervisors, are also required to provide a one month written notice to their immediate supervisor prior to resignation from employment. In the event the employee has entered into a separate written Employment Agreement with the Company, the employee shall adhere to the resignation and/or termination provisions specified within the Employment Agreement. Said Employment Agreement shall supersede the provisions outlined within this Employee Handbook. For all other Company employees a two (2) week written notice to an immediate supervisor is required prior to resignation from employment. Unless prior written agreement dictates otherwise, failure to comply with the proper notice requirements will forfeit your rights to PTO payout and may impact future employment with the Company. During the notice period, no PTO time may be requested and any previously approved PTO requests are subject to reevaluation to ensure proper coverage is met during the transitional period. Rehires You may be considered for re-employment provided you were in good standing at the time of separation. Former employees will not be given preferential consideration for open positions and may be subject to the same interview process as those candidates that have not previously worked for the Company. Rehired employees will be subject to the same three (3) month Introductory Period as a new employee. Employment of Relatives Members of the same family are generally not permitted to work in the same department or where a family member holds a supervisory position over another. Supervisors or managers shall not date employees who work for, or report to, them. This helps to ensure a professional and unbiased work environment. Consensual Romantic Relationships NaphCare, Inc. strongly believes that a work environment where employees maintain clear boundaries between employee personal and business interactions is necessary for effective business operations. Individuals in supervisory or managerial roles, and those with authority over others’ terms and conditions of employment, or in a decision-making role with clients or prospective clients should not be involved in a consensual romantic relationship with subordinates, supervisors, clients or prospective clients.


This policy does not preclude or interfere with the rights of employees protected by the National Labor Relations Act or any other applicable statute concerning the employment relationship. The provisions of this policy apply regardless of the sexual orientation of the parties involved. Any violation of this policy may lead to disciplinary action, as permitted by NaphCare policy and/or law, up to and including termination of employment. For more information regarding the procedures of this policy, please refer to the full policy located on NaphCare Online and NaphCare University. Business Mileage Reimbursement If you use your personal vehicle for Company business, you will be compensated for mileage based on the current rate allowed by the Internal Revenue Service. You are to complete Mileage Reimbursement forms and have your supervisor sign the form and submit the form to the corporate office within thirty (30) days of the travel. Payment will be made by direct deposit or check within fifteen (15) days. Business Travel NaphCare employees traveling for approved company business will be reimbursed for any authorized expenses incurred. Employees are responsible for providing documentation and/or receipts for any requested reimbursements. Travel expenses must be submitted to your supervisor within thirty (30) days of the date of travel. For a detailed description of NaphCare’s Travel Policy and approved expenses, please see your immediate supervisor. Expense Reimbursement Employees that incur an expense on behalf of the Company must have prior authorization from their supervisor. To be reimbursed for authorized expenses, the employee must submit an expense report with receipts attached for all charges to their supervisor. The supervisor will sign and approve the report and submit it to the corporate office for reimbursement.

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YOUR EMPLOYEE BENEFITS About Your Benefits In addition to the regular paycheck you receive for working at NaphCare, we offer numerous benefits, services, and conveniences to help provide protection and assistance for you and your family. The Value you receive from these benefits and services is really a “hidden paycheck” provided by our Company, with a value of over one-third of your base pay. Our insurance, 401(k) and other plan benefits are discussed in more detail in separate booklets, and in the formal contracts and other plan documents. In the event there is any question or conflict in language or interpretation between those booklets and documents in relation to the provisions of this Handbook, the terms of the actual contracts and other plan documents will control over the summaries in this Handbook. It is further understood that nothing in any of the benefit plan summaries summarized in this section will be considered a waiver of the Company’s Standards of Attendance. Following are some of the highlights of the Company’s employee benefits program, and a number of other services and conveniences our Company offers you in recognition of your value to the Company. Eligibility for Benefits

Type of Benefit

Full-time Exempt & Non-

Exempt Employees

Part-time Employees

PRN or Temporary Employees

Paid Time Off Yes No No

Medical Insurance and Prescriptions Yes Over 30 hours According to ACA rules

Dental Insurance Yes Over 30 hours No

Vision Insurance Yes Over 30 hours No

Company Paid Life & AD&D Insurance Yes No No

Voluntary Life & AD&D Insurance Yes No No

Short Term Disability Insurance Yes No No

Long Term Disability Insurance Yes No No

401(k) Plan Yes Yes No

Employee Assistance Program Yes Yes Yes

Worker’s Compensation Yes Yes Yes

Unemployment Compensation Yes Yes Yes

Social Security Yes Yes Yes


Health, Prescription,Dental and Vision Insurance

NaphCare offers a health, prescription, dental care and vision insurance plans to all full-time and part-time over 30 hours employees and their dependents. If eligible, you may enroll in benefits on the first day of your employment and the benefits will be effective on the first day of the following month. Employees that decline coverage will have the opportunity to enroll again each year during annual enrollment. Coverage for those employees will go into effect January 1st. Employees are also eligible to enroll within thirty (30) days of certain life changing events. For employees transferring to NaphCare from another company during a contract takeover, coverage begins immediately.

NaphCare assists employees by paying a large percentage of the monthly premium amount. To offset the cost that you pay, NaphCare has implemented a Premium-only Cafeteria Plan. Please contact your immediate supervisor or Human Resources with questions regarding qualifying life changing events or COBRA. Company Paid Life Insurance NaphCare provides term life insurance coverage for all full-time and part-time over 30 hours employees at no cost to the employee. We understand that sometimes the expense of other life activities get prioritized above purchasing life insurance and we want to make sure your family has help if something were to happen to you. NaphCare provides life insurance coverage and accidental death and dismemberment coverage equal to your annual salary up to a maximum of $50,000. Voluntary Benefits NaphCare offers an array of voluntary benefits to employees looking for additional coverage. The following benefits are offered to employees at negotiated group rates: Voluntary Life Insurance - In addition to the Company-provided life insurance, employees may elect to have additional coverage with nominal fees deducted from each paycheck. You may purchase up to seven times your annual salary for up to a maximum of $250,000 on yourself, and up to 50% of that elected coverage on your spouse. In addition, you may select up to $10,000 on each of your children. Please see the Voluntary Life benefit plan summary for details and eligibility questions. Short-Term Disability Insurance - Employees may elect to purchase short-term disability insurance with nominal fees deducted from each paycheck. The coverage provides up to sixty percent (60%) of your weekly earnings, up to a maximum of $600 weekly. Please see the Short-Term Disability benefit plan summary for details and eligibility questions. Long-Term Disability Insurance - Employees may elect to purchase long-term disability insurance with nominal fees deducted from each paycheck. Disability can be taken after missing ninety (90) days of work. Please see the Long-Term Disability benefit plan summary for details and eligibility questions. Vision Insurance - Employees may elect to purchase vision insurance on themselves and their dependents. Coverage begins on the first day of the month following your hire date. COBRA In the event that your full-time status with NaphCare changes, whether by separation from the company or changing to part-time or PRN status, you and your covered dependents may be eligible to continue health, prescription, dental, vision, and/or Medical FSA insurance coverage or convert your voluntary benefits coverage to a portable benefit plan. Information on continuation of health and dental coverage will be mailed to your home address within


thirty (30) days of your change in status. You are encouraged to contact Human Resources for additional questions regarding COBRA or conversion information on voluntary benefit plans. 401(k) Plan All full-time and part-time employees, age twenty-one (21) and over with six months of continuous employment, are eligible to participate in the 401(k) Plan. All eligible employees will be auto-enrolled on the first day of the month following six months of continuous employment. Eligible employees may contribute up to eighty percent (80%) of compensation before taxes, and the Company will match twenty-five percent (25%) for every dollar contributed up to six percent (6%). For additional information, please refer to 401(k) Plan information available on NaphCare Online. Education/Tuition Reimbursement NaphCare embraces our employee’s personal and professional growth and offers partial Tuition Reimbursement for academic courses directly related to enhancing a full-time employee’s current position or advancement within the company. Approved courses must be offered through a US Department of Education accredited institution and provide academic credit.

Employees seeking Tuition Reimbursement must submit an Educational Assistance Request form to their immediate supervisor for corporate approval prior to the start date of the course. Contact your immediate supervisor or the NaphCare corporate office for additional information regarding the Company’s Educational Assistance policy including, maximum reimbursement amounts, minimum grade requirements, factors considered to determine approval and additional employee responsibilities for reimbursement. If an employee resigns or is terminated within one (1) year of completing the approved course, the employee must repay the reimbursed amount in full. Employees who

separate from the Company for any reason prior to the completion of the approved course are ineligible for reimbursement. The Educational Assistance Program is not an employee benefit, right or entitlement. It is a management program for workforce development. Please see the Education/Tuition Reimbursement Policy for details and eligibility questions. Referral Bonus NaphCare is always seeking top talent! Employees that recruit their friends and colleagues to work for NaphCare are eligible for a referral bonus! Any employee who successfully recruits a full-time or part-time employee to come to work for NaphCare will receive a $500 referral bonus after that employee completes six (6) months service with the Company. If you supervise the position, in any way, in which the referred candidate has applied, you are not eligible for the bonus. Referred candidates must be new NaphCare employees and must indicate the referring employee's name on the employment application or in writing prior to the hiring manager extending an offer to the candidate. Both referred and referring employee must be active employees at the time of payment. Provider Referral Bonus In addition, any employee (with the exception of Executives/Vice-Presidents/Recruiters) who successfully recruits a full-time or part-time provider, such as a Physician, Dentist, Nurse Practitioner, or Physician Assistant, will receive a referral bonus in the following amount:


• $5,000 for the referral of a full-time provider to be paid in four payments of $1,250 as the

referred employee completes each quarter of employment (completion of three months, six months, nine months and twelve months)

• $2,500 for the referral of a part-time provider to be paid in four payments of $625 as the referred employee completes each quarter of employment (completion of three months, six months, nine months and twelve months)

• There will be no referral bonus for a PRN or “Pro Re Nata” provider. In the event of a status change from a PRN provider to part-time or full-time status provider, the referring employee would not be eligible for a bonus at the time of the status change as the provider must be in a part-time or full-time status when initially hired.

If you supervise the position, in any way, in which the referred candidate has applied, you are not eligible for the bonus. Referred candidates must be new NaphCare employees and must indicate the referring employee's name on the employment application or in writing prior to the hiring manager extending an offer to the candidate. Both referred and referring employee must be active employees at the time of payment. Workers’ Compensation NaphCare provides insurance that pays benefits to you if you are injured at work. In the event of an injury at work, you should immediately notify your supervisor. The injury must arise out of and in the course of employment with NaphCare. A written report must be submitted to Human Resources within 24 hours of the job related injury and include the following information:

• Your name • Where and when you were injured • What you were doing when you were injured • Who was supervising you at the time of the injury • The nature of the injury • Any witnesses to the incident

Unemployment Compensation Our Company contributes to insurance funds that may provide you with income in the event that you are laid off and unemployed through no fault of your own. Employee Assistance Program As an added benefit to our employees, NaphCare offers you and your qualified family members Employee Assistance Program (EAP) services through American Behavioral. American Behavioral is a full-service behavioral health care organization that provides convenient, confidential and free assistance with a variety of work/life issues including family and marital, mental health and substance abuse assessment and referral to all NaphCare employees and their eligible dependents by phone, in person or online. This benefit is available to you and your family 24 hours a day, 7 days a week, 365 days a year. For additional information on the benefits available to you, please visit NaphCare Online or contact the Human Resources Department.



TIME OFF FROM WORK Paid Time Off Paid Time Off (PTO) is an accumulation of hours that all active full-time employees receive to use for personal leave. These hours are for employees to use for both vacation and sick leave. Accrual - PTO accrual begins accruing during your first full pay period worked. Employees can begin using their PTO immediately. In the first five (5) years of service employees accrue twenty (20) days of PTO each year and employees with more than five (5) years of service accrue twenty-five (25) days of PTO each year. To accrue PTO an employee must be in active pay status (not “on leave”). Taking PTO – Employees are encouraged to take at least 5 days of PTO per year as time away from work. To take PTO, employees should submit a request to their immediate supervisor for approval at least 48 hours prior to the requested leave date. There may be times when an illness, injury or other emergency situation prevents an employee from being able to have PTO pre-approved. In those instances, verification of the circumstances which made pre-approval impossible may be required by the Company (i.e. doctor’s excuse). Any time off not specifically provided for in another provision of this Handbook in excess of an employee’s accrued PTO time will be without pay and may result in a change of employee status. Excessive time off is grounds for termination. Employees are not permitted to take PTO during their resignation notice period as described in this Handbook. For exempt employees, a “day” in this section refers to an eight (8) hour day. For non-exempt employees, PTO will be used by the hour to fulfill the requirements of the employee’s position held. Your designated facility may have a separate operating policy/procedure regarding PTO based on clinical needs within the facility. Said procedure/policy shall supersede this provision of the Employee Handbook. PTO Rollover Policy At the end of each calendar year some employees have a remaining PTO balance in their PTO bank. NaphCare automatically rolls up to 60 hours of unused PTO into the next year’s PTO bank. Any remaining PTO balance beyond the 60 hour threshold will automatically roll into the employee’s Extended Sick Bank at the end of each calendar year.1 NaphCare strongly encourages our Employees to use their PTO throughout the year, rather than waiting until the end of the year. If one wishes to use PTO toward the end of the calendar year, we remind them to be mindful to remember to follow the proper procedure for requesting time away from work in advance. PTO Payout When an employee separates from the Company, whether by resignation, or the loss of a contract, they will be eligible for payment of up to 40 hours of unused PTO time and up to 40 hours of unused extended sick bank time. To be eligible for payment the employee must give proper written notice as described in the resignation section in this Handbook and all Company and facility property must be returned. Extended Sick Bank

1 To the extent any applicable state law conflicts with NaphCare’s PTO rollover policy, said state law shall control the PTO provisions set forth hereinabove.


An employee’s Extended Sick Bank may be utilized after an employee has exhausted his or her PTO time and is in need of additional time off due to illness, injury, or FMLA. Employees wishing to utilize time within their Extended Sick Bank must provide the Company with a physician office note or letter of medical necessity at the time of the request for Extended Sick Bank usage. Generosity Clause Employees may donate the equivalent of up to two hundred and fifty ($250) dollars of their accumulated PTO time to a co-worker experiencing extreme misfortunate circumstances such as a health related illness. Time can be donated in the equivalent of fifty ($50) dollar increments up to the two hundred and fifty ($250) dollar maximum. An employee can only donate one time per year to the same employee. Holidays Full-time employees working for NaphCare are eligible to receive holiday pay for company recognized holidays. NaphCare recognizes the following Holidays:

(1) New Year’s Day (2) Martin Luther King, Jr. Day (3) Memorial Day (4) Independence Day (5) Labor Day (6) Thanksgiving Day (7) Day After Thanksgiving (8) Christmas Day

Non-exempt employees working on a Holiday will receive one-and-a-half times their hourly rate for each hour worked on that Holiday. Full-time non-exempt employees who fail to report to a scheduled shift either the day before a scheduled Holiday, the day of a scheduled Holiday or the day after a scheduled Holiday will forfeit pay for the Holiday unless the absence is part of scheduled leave. Holidays cannot be banked and used at a different time. If on a paid leave of absence (i.e. you are using your PTO and/or extended sick bank during your absence), and a holiday falls during that period, you will be paid for the holiday. However, if you are on an unpaid leave of absence, you will not be paid for holidays that occur during the leave. If the Holiday falls on a day you are not scheduled to work, the full-time non-exempt employee will receive eight (8) hours of Holiday pay. If the Holiday falls on a Saturday or Sunday the Company will designate which weekday will be recognized as the Holiday for exempt employees. Your designated facility may have a separate operating policy/procedure regarding holidays based on clinical needs within the facility. Said policy/procedure shall supersede this provision of the Employee Handbook. Jury Duty Time off for jury duty will be granted to all employees in accordance with applicable law. When you receive a notice to report for jury duty, you must notify your supervisor immediately. If you are required to be absent from work in order to report for jury duty, you must provide your supervisor with a copy of the subpoena, summons, or court order prior to the absence and again upon your return to work. Time off for jury duty will be paid. Family and Medical Leave Act (“FMLA”) Leave Pursuant to the mandates of the Family and Medical Leave Act of 1993 (“FMLA”), the Company will grant periods of leave up to twelve (12) weeks in a twelve-month period to qualifying employees. The general guidelines used in administering this Policy are described below. To the extent any conflict exists between the Company’s Policy and the actual statute, the statute controls. Questions regarding FMLA


should be directed to NaphCare’s Human Resources Department. Covered Employees - To be eligible for FMLA Leave, you must have been employed by the Company for at least twelve months, whether consecutive or intermittent, and worked at least 1,250 hours during the twelve-month period preceding the leave. Reasons for Leave - To be eligible for FMLA Leave due to a serious health condition, to care for a spouse, child, or parent with a serious health condition, or for the birth of a child or placement of a child with you for adoption or foster care.

• Serious Health Condition - A serious health condition is an illness, injury, impairment, or physical or mental condition that involves either inpatient care or continuing treatment by a health care provider. Leave taken because of your own serious health condition or to care for a family member with a serious health condition may be taken intermittently or on a reduced schedule when medically necessary and supported by certification from your doctor or other health care professional. In this situation, you may be transferred to a position which, in the Company’s discretion, better accommodates the leave schedule, but is equivalent in pay and benefits to the position held prior to the leave.

• Medical Certification - If FMLA Leave is taken because of a serious health condition, whether your own or that of a family member, you will be required to provide a medical certification from a health care provider supporting the need for leave. When leave is taken because of your own serious health condition, certification of your ability to return to work may also be required. The Company will provide the medical certification form(s).

• Birth of a Child/Adoption or Foster Care - FMLA Leave taken for the birth of a child, or for the placement of a child for adoption or foster care, shall be taken consecutively. Eligibility for such leave ends twelve (12) months after the date of birth or placement. Furthermore, certain states have specific laws regarding pregnancy leave rights that may provide more options and protection than the FMLA. Please refer to the labor law posted at your specific work location or contact Human Resources for more information regarding your state specific provisions.

• Notice of Leave Request in Writing - FMLA Leave must be requested in writing at least thirty (30) days prior to the commencement of the leave period, if the need for leave is foreseeable. If the need for leave is not foreseeable, the request for leave may be submitted verbally, within three (3) days of the employee’s learning of the need for the leave, followed by a written notice. A “Request for Leave of Absence” form can be obtained from the Human Resources Department.

Length of Leave - FMLA Leave is limited to a total of twelve (12) weeks during a rolling twelve-month period. This means that the amount of leave you have available will date back for twelve months preceding the date leave is to be taken. If you are taking leave for your own serious health condition or because of the serious health condition of a family member, you may take FMLA leave in 12 consecutive weeks, or under certain circumstances, use the leave intermittently by taking a day periodically when needed over the 12-month period. In all cases, the leave may not exceed a total of 12 weeks over a 12-month period. Pay Status During Leave - Your pay status during FMLA Leave will depend on the reasons for the leave, the length of the leave and the amount of PTO you have available at the time of the leave. If on FMLA Leave, you will be required to exhaust your available PTO and time within your Extended Leave account. You will receive full pay until this time is exhausted. When your PTO is exhausted, you will be on unpaid status for the remainder of the leave. PTO does not accrue while on consecutive FMLA. PTO may accrue while on Intermittent FMLA, but is calculated only for the number of hours actually worked. Military Family Leave Entitlements - Eligible employees with a spouse, son, daughter, or parent on active duty or call to active duty status in the National Guard or Reserves in support of a contingency operation may use their 12-week leave entitlement to address certain qualifying exigencies. Qualifying exigencies may include:


• Short-notice deployment: leave to address any issue that arises from an impending call or order to active duty in support of a contingency operation seven days or less prior to the date of deployment;

• Military events and related activities: leave to attend any military ceremony, program, or event related to the active duty or call to active duty status or to attend certain family support or assistance programs and informational briefings;

• Childcare and school activities: leave to arrange or provide for childcare or school-related activities;

• Financial and legal arrangements: leave to make or update various financial or legal arrangements;

• Counseling: leave to attend counseling (by someone other than a health care provider) when necessary as a result of the active duty or call to active duty status;

• Rest and recuperation: leave to spend time with a covered military member who is on short-term, temporary, rest-and-recuperation leave during the period of deployment (up to five days);

• Post-deployment activities: leave to attend arrival ceremonies (including funeral or memorial services), reintegration briefings and events, and any other official ceremony or program sponsored by the military for a period of 90 days following active duty status; and

• Additional activities: leave to address other events arising from military duty agreed upon between employer and employee.

FMLA also includes a special leave entitlement that permits eligible employees to take up to 26 weeks of leave to care for a covered service-member during a single 12-month period. A covered service-member is a current member of the Armed Forces, including a member of the National Guard or Reserves, who has a serious injury or illness incurred in the line of duty on active duty that may render the service-member medically unfit to perform his or her duties for which the service-member is undergoing medical treatment, recuperation, or therapy; or is in outpatient status; or is on the temporary disability retired list. Effect on Benefits - During any period which you are on Leave, you will continue to receive coverage under the Company’s group health plan at no additional expense to you. However, you will be required to continue paying your portion of the premium for your own and any dependent coverage should you wish to keep such coverage in effect. All other benefits and insurances available to you prior to the leave will continue or discontinue in accordance with the governing Plan document. Return from Leave - Upon returning to work from FMLA Leave, you will be placed in the same position you held prior to leave, or if that position is no longer available, you will be placed in a position which is equivalent in pay, benefits, and other terms and conditions of employment, to the position held prior to the leave. Exemption for Highly Compensated Employees - Salaried employees in the highest paid ten percent (10%) of the Company’s workforce are not guaranteed job restoration if returning such employees to work would cause substantial and grievous economic injury to the Company. The Company will notify employees in writing at the time leave is requested or upon its determination that an employee qualifies for this exemption. If the leave has already begun, the employee will be given the option of returning to work in lieu of continuing the leave. State Paid Family Leave – Employees in California, New Jersey, New York and Washington may be entitled to other state entitled leave. Please contact Human Resources for additional information. Workers’ Compensation - If you are absent from work due to a work-related illness or injury, this absence will be covered under the guidelines of the Family and Medical Leave Act, for a period of up to twelve (12) weeks. If you are unable to return to work after twelve (12) weeks, additional leave may be available under the Workers’ Compensation laws of the state in which you are working. Leave taken pursuant to Workers’ Compensation is not paid by the Company, and you will be responsible for paying your portion of the medical insurance premium while you are receiving Workers’ Compensation benefits should you wish to keep such coverage in effect. In the event that you are away from work for a continuous period of six (6) months, your employment with the Company will be terminated unless you have additional leave provided for by state or federal law.


Employee Military Leave If you are a member of the Armed Forces Reserves or National Guard and are required to report for military duty, you must immediately give notice to your supervisor and you will be given the full time off. You are encouraged to the extent possible to schedule your Guard training in a manner that does not conflict with your work schedule at NaphCare. For Military Leave of less than one (1) month in duration, you will be entitled to use your PTO time if you wish to continue receiving compensation while on Military Leave. If you choose not to use your PTO time, you will not receive compensation from the Company. If you have elected benefits, you are responsible for continuing your contributions for the total cost of your elections should you wish to keep such coverage in effect.

For Military Leave of more than one (1) month in duration, you will be placed on unpaid leave. If you go on active duty you will be separated from your employment, but you will have reinstatement rights as guaranteed by federal law if you return to work or apply to return to work in a timely manner upon completion of your active duty. If you have elected benefits, you are responsible for continuing your contributions for the total cost of your elections should you wish to keep such coverage in effect. Employees do not accrue PTO while on military leave status. Bereavement Leave All full-time employees are eligible for Bereavement Leave. Bereavement Leave may be taken at the time of death and/or burial. The amount of leave time is determined as follows:

• Three (3) consecutive paid days for immediate family and your spouse’s immediate family including: spouse, mother, father, step-parent, sister, brother, child, step-child, step-brother, step-sister, grandparent, great-grandparent, and grandchild;

• One (1) paid day off for close relatives to include: an aunt, uncle, cousin, niece or nephew. NaphCare reserves the right to request dated documentation indicating the deceased and your relationship to the deceased. While NaphCare understands that some close friends are equally as important in our lives as immediate family members, Bereavement Leave can only be taken for the immediate family member(s) listed above. PTO must be used for bereavement of any non-relative or for any non-immediate family member not listed above. Any employee determined to be abusing Bereavement Leave will be subjected to discipline up to and including termination. Inclement Weather Procedures You should assume that NaphCare and each of its facilities will be open for business unless you are notified otherwise by management. In the event of an office or facility closing, information will be made available to you by telephone if possible. If you have a question about an office or facility closing, you should contact the facility or the corporate office for instructions. If non-essential employees are mandated by the authorities to remain home, they will not have to utilize PTO. If you are a NaphCare employee, exempt or non-exempt, and do not report to work due to weather conditions, and the Company is open for business, you will be charged PTO time. Voting NaphCare encourages you to exercise your right to vote. Voting hours are long enough that you should be able to vote before or after work so that a disruption to working hours is not necessary. If you have a special situation that may require time off to vote consult with your supervisor prior to Election Day. In instances where state law mandates time off for you to vote outside of the guidelines listed above, the state law controls.



YOUR CAREER DEVELOPMENT Performance Appraisals NaphCare supervisors review job performance on an on-going basis to ensure we are providing the highest quality health care at all times. Upon completion of your training and orientation provided during your ninety (90) day probationary period, your supervisor will continue to evaluate the quality and quantity of your work in order to monitor your progress throughout your employment with NaphCare. Employee Evaluations/Performance Appraisals may be scheduled at your supervisor’s discretion at the end of your 90-day Introductory Period and thereafter on an annual basis based on your anniversary date, contract date or collective bargaining agreement or as needed. Evaluations assess all areas of your employment with the Company, including but not limited to, overall job knowledge, quality, quantity and efficiency of work, attitude, compliance with company policies and codes of conduct, relationships with coworkers and initiative. All full-time and part-time employees are eligible for an annual merit increase. Employee compensation is reviewed annually as part of Employee Evaluations. NaphCare is not obligated to provide a merit increase and holds the right to decline a merit increase. Job Bidding and Promotions NaphCare recognizes the value of promoting qualified employees to fill vacancies within the Company. It is the Company’s desire to promote from within whenever possible. However, if the Company determines that there is not a qualified and/or diverse candidate pool within the Company, the Company will proceed with an external search. The Company’s policy of “promoting from within” is not intended to and shall in no way limit the Company’s right to fill any position from any available source. When a vacancy exists, the Company may post notice of such opening. If you desire to be considered for a job opening, you must submit an online application for the desired position. The Company will make its selection in compliance with its EEO policies and based on the relative skill, experience, and qualifications of the candidates, in addition to any other lawful factors that the Company determines are relevant to the successful performance of the job. Internal Transfers to Different Departments or Sites NaphCare understands that staff motivation, productivity, and retention are dependent upon employees working in jobs that are well suited to them. Therefore, they offer and encourage transfer opportunities for current employees. Likewise, supervisors should be supportive of employees who have the desire to pursue different responsibilities internally. To be eligible for a transfer, an employee must be in their current position for at least six (6) months and be in good standing. Exceptions made to the six month waiting period can be reviewed on an individual basis and must be approved by all managers involved to include the Vice President over the sites. In all cases, the employee’s work record, including but not limited to performance, attendance, and related behavior will be used as valid criteria for determining suitability for a position. Employees that are interested in transferring must submit an online application in order to be considered. If chosen for the open position, the employee should notify the current supervisor. An adequate notice must be given to allow a smooth transition from the current position.



WHAT WE EXPECT FROM YOU Understand the Need for Constructive Counseling In any working environment there must be standards of conduct and attendance for common guidance and efficiency. It is impossible to define in detail every standard for every circumstance. We hope that your common sense will guide you as to the proper things to do in most cases and this section is to be used as a guideline for our expectations and standards. This section is not intended to encompass every action, expectation, standard or offense. If you have any questions regarding standards of conduct, attendance or what to do in a situation, please contact your supervisor. When employee misconduct occurs, measures must be taken to correct the situation. NaphCare’s disciplinary actions may vary depending on the gravity of the offense, the surrounding circumstances, the employee’s job duties, length of service, and overall work record, including prior disciplines. Discipline may take one of the following forms:

(a) Verbal Counseling; (b) Written Reprimand; (c) Suspension with or without pay pending an

investigation; or (d) Termination

Please be advised, although the Company will adhere to progressive discipline where it deems appropriate, the Company does not guarantee progressive discipline under any circumstances. Any and all of the above disciplinary actions may be omitted or taken as the Company deems appropriate depending on the circumstances of a particular situation. By establishing a disciplinary procedure, the Company is in no way relinquishing or limiting its managerial rights to terminate an employee for any reason, with or without cause or notice. The disciplinary procedure is not intended to and does not alter the at-will relationship. To the extent progressive discipline is available or used by the Company, it does not create a contract of employment. Give Us Quality Work Our Company prides itself on being a leader in its field. One principle is enforced without exception: top quality performance. This philosophy has motivated the continued growth and success of Our Company. Your continued employment is dependent upon living up to this high standard in your job. Be Health and Safety Conscious NaphCare is vitally interested in the health and safety of each employee. Each employee should observe and obey our safety rules. Report promptly to your supervisor any condition which you believe is unsafe or unhealthy, and any on-the-job or work-related injury. Safety practices which the Company expects you to follow include but are not limited to the following:

(a) Wear safety glasses, safety gloves, safety shoes, ear protection and other protective clothing or devices as directed by your supervisor.

(b) Learn how to lift properly. Bend your knees and keep your back erect. Get help for heavy loads. (c) Follow Hazard Communication guidelines for handling any hazardous substances in the

workplace. (d) Follow universal precautions at all times.

Be Alert to Security and Abide by Facility Rules As a health care provider in correctional institutions, NaphCare strictly forbids contraband, drugs, alcohol, weapons, or other unauthorized or illegal substances or materials to enter our job sites. In addition, equipment, tools, files, and other Company property should not be removed from job sites


without a legitimate business reason and prior authorization from a supervisor or authorized Company official. In order to maintain the safety and security of our facilities, NaphCare reserves the right to question, inspect, and/or search any employee or other person before entering or leaving the facility. Desks, lockers, storage devices, vehicles, containers, packages, briefcases, handbags or other parcels, or personal property on or around Company or facility premises used by or thought to be used by Company employees may be searched at any time. Employees are required to follow the security regulations of the facility in which the employee works in addition to these security rules. In the event that NaphCare rules contradict any of the institution’s security regulations, the institution’s rules and regulations control. For safety and security reasons, your supervisor must be notified in the event you receive knowledge that a friend, acquaintance or relative is booked into the facility in which you work. NaphCare takes the safety of its employees, patients, and clients seriously. These policies are necessary to ensure the safety, health, and security of all persons. Failure to adhere to these policies may result in disciplinary action, up to, and including termination. If You are Barred from Facility The clients that NaphCare contracts with have the discretion and authority to forbid NaphCare employees from entering their facilities. This decision is within the full discretion of the client and NaphCare will abide by its client’s instructions regarding barring an individual from the client’s facility. In the event a NaphCare employee is barred from a facility, thereby preventing that employee from performing his or her job responsibilities, that employee will be terminated immediately. If an Employee is temporarily barred from a facility, pending an investigation, the Employee may be suspended with or without pay, depending upon the circumstances surrounding the investigation. In the event of a suspension with pay, the length of time the pay will continue may depend upon the circumstances surrounding the investigation; however, in no case will the pay continue for longer than a maximum of ten (10) days, absent a written exception granted by NaphCare for extenuating circumstances. Observe Our Rules on Workplace Smoking NaphCare does not allow the use of tobacco products including cigarettes, electronic cigarettes and “spit tobacco” inside its facilities at any time. Smoking or tobacco use shall be permitted only in designated outdoor smoking areas in accordance with facility regulations, should such regulations exist. Restrict Personal Phone Calls Phones are to be used for Company business calls and not for personal use. If it is absolutely necessary to make or receive a personal call, it should be very brief. Employees should refrain from making personal long distance calls on Company phones. Provided there is a legitimate need for a personal long distance call to be made, employees are responsible for reimbursing the Company for that expense. Use of Personal Cell Phones/Electronic Devices While at work, employees are expected to exercise the same discretion in using personal cellphones and/or electronic devices as is expected for the use of company phones. Excessive personal calls and/or text messages during the workday, regardless of the phone used, can interfere with employee productivity and be distracting to others. Employees are encouraged to make any personal calls and/or text messages on non-work time when possible and to ensure that friends and family members are aware of NaphCare’s policy. The use of camera phones or other audio/video recording-capable and/or audio/video playing devices within the company may constitute an invasion of employees’ personal privacy and may breach the confidentiality of NaphCare trade secrets or other protected information. Therefore, the use of camera


or other video recording-capable devices and/or audio/video playing devices on company premises (to include Employee using at his/her desk or other workspace) is prohibited without the express prior permission of management and of the person(s) present at the time. NaphCare will not be liable for the loss of personal cellphones or electronic devices brought into the workplace. Keep Us Up-To-Date It is your responsibility to promptly notify the Company of any changes to your name, address, telephone number, marital status, number of dependents, beneficiary designation, or any other factor that would affect your employee benefits or the Company’s ability to contact you. Employee records and files are the property of NaphCare and are maintained by Human Resources at the NaphCare corporate office. You may request to inspect your personnel file in the presence of an appointed Human Resources representative at a mutually agreed upon time. An employee’s right to inspect his or her personnel file may be limited where such inspection may be disruptive to the workplace or where other circumstances warrant restricted access to the file. Employees will not be provided with actual copies of their personnel files absent a subpoena or Court Order unless state law dictates otherwise. Keep Compensation Confidential NaphCare performs a thorough market analysis for comparable positions in the local area to determine salary structure. We ensure that our salaries are competitive with those of local community hospitals when determining salary ranges in order to recruit and retain the most qualified and experienced staff. Other factors taken into consideration are credentials, education, years of experience, and the uniqueness of the position. Your compensation as a NaphCare employee should be kept confidential. This request is not intended to deter employees from engaging in a legally protected activity. Remember Courtesy We view service to our customers and business family as one of our most important responsibilities. You are expected to help us carry out this policy by extending every courtesy and all assistance necessary, not only to customers and your fellow employees, but to any callers or business visitors to the Company. Be Aware of Your Personal Appearance Your appearance is an important part of the Company’s image, and every employee has a responsibility to be dressed professionally and appropriately at all times. Individual facility compliance must be followed at all times. In addition, your common sense should lead you to practice good personal hygiene and to wear clean and neat clothing. The following is a list of unacceptable dress and appearance standards intended to serve as a guideline. This list is not all inclusive and is not intended to encompass all unacceptable dress standards.

• Denim, shorts, t-shirts, camouflage, sweat suits, jogging suits, flip flops, miniskirts, low cut shirts, revealing shirts, shirts showing your stomach or see-through clothing of any kind.

• Employees are also asked to cover visible tattoos, and refrain from wearing body piercings, other than in the ear.

• Employees should note that in a medical environment, sanitation is of upmost importance and therefore employees must refrain from wearing fake nails and keep jewelry to a minimum.

You are expected to practice good personal hygiene and to wear clean and neat professional attire as suited to your position. Due to other employees’ potential allergies please refrain from using any cologne or perfume or fragrant lotions.


To the extent you work in a correctional facility, you are encouraged to pay particular attention to your appearance and demeanor, and are advised to dress as conservatively as possible. If you have any questions regarding the appropriate attire for your position, consult your immediate supervisor or the NaphCare corporate office. Respect Confidential Information NaphCare employees are trained and oriented on Company policies and business methods that are independent of our competitors. Our policies and business methods have been developed and maintained by Company employees while employed by the Company and any information concerning the business of the Company is to be kept confidential. NaphCare’s success depends on our employee’s drive towards advancing the Company’s technology, methods, sales and customer satisfaction and therefore must require confidentiality. It is because of this that NaphCare requires any information concerning the business of the Company, its customers, suppliers, sub-contractors, providers (hospitals and physicians), dealers, trade secrets, proprietary information, employees or personnel associated with the Company be kept confidential. You may not reveal any such information except under the direction of your supervisor or other Company manager with prior approval. If you are not sure as to whether information is confidential, you are directed to contact your supervisor or the Legal Department. This confidentiality requirement also applies to medical and protected health information (PHI) concerning inmates in accordance with the mandates of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Employees who have access to PHI as part of their job duties will be required to complete the Company’s HIPAA training course. In the event of employment separation by termination, resignation or from a facility contract terminating, all confidential documentation and/or information, shall not be disclosed to other parties and is to be returned to the company upon the employee’s last day of employment. Protect Company Information NaphCare is committed to protecting its own intellectual property, such as information, processes, and technology, from infringement by others. NaphCare’s informational tools are available at our disposal because of significant investments of time and Company funds. If our intellectual property is not properly protected, it becomes available to others who have not made similar investments. This would cause us to lose our competitive advantage and compromise our ability to provide unique services to our customers. NaphCare’s intellectual property includes processes, confidential business information, trade secret technology (such as computer software and systems and knowhow related to them), patented inventions, trademarks and service marks, trade dress, and copyrighted works. It is the responsibility of every NaphCare employee to help protect intellectual property. Should you be contacted by an outside party to conduct surveys about NaphCare business or questioned about NaphCare business, please do not participate without authorization from Human Resources. Keep Personal Visitors Away You are not permitted to have visitors while at work. No one may enter our facilities unless working for or conducting business with the Company. It is inappropriate to bring children or pets to work under any circumstances. Respect Our Policies on E-mail, Computers, and Other Company Provided Equipment All Company provided equipment is the sole property of NaphCare. Any information transmitted by, received from, or stored in such equipment belongs to the Company. These systems are only for legitimate business purposes to advance the Company’s interest, and are not for employees’ personal


use. Employees are not to data stream on computers during work hours. The use of instant messaging must be approved by management. These systems may not be used to transmit or download offensive, vulgar or otherwise inappropriate messages or pictures, including, but not limited to, messages or pictures that would violate the Company’s Equal Employment Opportunity and Anti-Harassment policies. Any information, data, files, email, or other material on the Company’s network and systems, both personal and business-related, shall be subject to inspection and review by the Company for any purpose at any time. The Company reserves the right to monitor all employee usage, the security of Company data, and to retrieve and use the contents of any employee files, data, email, or communication in these systems. Management may access or use all files, including archived material of present and former employees, without the user’s consent for any purpose at any time. Employees may not use passwords to retrieve any stored communications or files without prior authorization. Passwords are “on loan” to employees and are at all times considered Company property. Passwords may not be given to other NaphCare employees or to individuals outside the Company without prior authorization. The Company has a standard set of software installed on each computer. Employees may not install additional software on their computer without prior authorization from management. The Company reserves the right to uninstall any software program not approved by management or that does not comply with the Company standard. The Company is not responsible for the security of an employee’s personal information to the extent the employee is using the Company’s computer or other communications equipment for personal use. You should exercise caution when transferring large files. You are directed to consult with the Information Systems Department for assistance in handling any large file transfers. Any employee violating the Company’s Technology Policy may be subjected to discipline, up to and including, termination from employment. If you have any technical questions related to your computer or other communications systems or equipment, contact the Information Systems Department at [email protected]. Mobile Devices NaphCare may, at times, provide employees with mobile devices to perform NaphCare business remotely. NaphCare may also allow employees to utilize their personal smartphones or other mobile devices to access NaphCare network resources for the performance of NaphCare business. Mobile devices include (but are not limited to) laptop computers, Smartphones or Personal Digital Assistants (PDAs), tablet devices such as iPads and removable storage media such as USB drives or jump drives. NaphCare is committed to safeguarding Protected Health Information (PHI), including electronic Protected Health Information (e-PHI) on all mobile devices that store, process or access such data. As such, only mobile devices approved by NaphCare’s IT Department may be used to connect to NaphCare’s internal network. Employees must not download or store e-PHI on any mobile device without a specific business need which must be explicitly authorized by appropriate management (see your immediate supervisor with questions as an approved encryption solution authorized by NaphCare’s IT Department must be utilized to encrypt e-PHI on all mobile devices). Remote access to/from sensitive data on mobile devices must be done in a secure manner so that no unauthorized access to e-PHI is allowed during transmission. All mobile devices must be protected with a suitable anti-virus or malware solution at all times. When mobile devices are used to access internal e-PHI systems from outside of NaphCare’s internal network, the devices must use an approved Virtual Private Network (VPN) solution for such access. All wireless transmissions made by mobile devices must be encrypted with an approved encryption solution that is sufficiently strong to protect e-PHI. Only approved synchronization applications may be used when synchronizing e-PHI to mobile computing devices. Mobile devices must be physically secured by the device’s owner at all times. All mobile devices must be configured to require a password when it is powered on or if the device has not been in use for a maximum of 10 minutes. If an employee mobile device used in conjunction with NaphCare’s network resources is determined by NaphCare’s IT Department to be lacking a password, NaphCare’s IT Department may override the device by requiring a password to unlock it and automatically setting the lockout to 10 minutes. Software or patch updates on mobile devices must be planned, tested and applied in a timely manner. Users must not install unauthorized

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applications on company owned mobile devices and must not Jail Break (install software that allows bypass of standard built-in security features and controls) company owned or personal mobile devices. All e-PHI on mobile devices must always be backed up on a NaphCare designated server. The data backup must be performed as frequently as possible but certainly every 24 hours. Upon the loss or theft of a mobile device, Employee must report the event immediately to his/her supervisor, as well as the NaphCare IT Department. Employees agree that personal or company owned devices may be disconnected from the network and/or remotely wiped by IT, without notification, if (i) the device is lost, stolen or compromised; (ii) employee terminates employment with NaphCare; (iii) the IT section detects a data or policy breach or virus; or (iv) if employee incorrectly types employee password 10 consecutive times. With regard to personal employee owned devices, NaphCare will make all attempts to only delete company related data but cannot guarantee that all data on the device will not be erased when the remote wipe takes place. Similarly, employee acknowledges that the use of their personal mobile device in connection with NaphCare business carries specific risks for which employee assumes full liability, including but not limited to, the partial or complete loss of data as a result of a crash of the operating system, errors, bugs, viruses, downloaded malware, and/or other software or hardware failures or programming errors which could render a device inoperable. Restrict Conflicting Outside Activities Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This can occur when an employee has the capability to use NaphCare’s business dealings to influence a decision that may result in personal gain for that employee or for a close friend, acquaintance, or relative. If an employee has any influence on transactions involving purchases, contracts, or leases, it is imperative that he or she disclose the existence of that relationship to their supervisor and the corporate office as soon as possible so that safeguards can be established to protect all parties. Other examples of personal gain include an employee receiving any kickback, bribe, substantial gift, or special consideration as a result of any transaction or business dealing involving the Company. All conflicts of interest or potential conflicts of interest must be reported in writing to your immediate supervisor as soon as such conflicts or potential conflicts become known. Obey Our Solicitation and Distribution Rules NaphCare employees may not solicit or distribute goods and/or literature while working or in work areas for any purpose. “Working” does not include meal times or rest periods. “Work areas” of the Company do not include break rooms or restrooms. If you have any questions about this Policy, please contact your immediate supervisor or the corporate office. Follow Common Sense Standards of Conduct to Avoid major Offenses NaphCare expects employees to behave in a professional manner at all times. Every employee of NaphCare is a reflection of the Company and is expected to behave in a manner that complies with the Company’s core values. Employees should be aware that there are certain offenses that may result in immediate termination, without any prior counseling or notice. The decision regarding what form of discipline is appropriate is at the Company’s discretion. The following is a list of unacceptable behaviors intended by the Company to serve as a guideline for all employees. This list is not all-inclusive and is not intended to encompass every offense that may result in discipline. However, commission of any of the following offenses will result in discipline, up to and including, termination from employment.

1. Insubordination. 2. Job abandonment. 3. Failure to follow the chain-of-command.


4. Failure to show up for your scheduled shift without contacting your supervisor or failure to follow the established “call off” procedure.

5. Chronic, habitual or excessive lateness or absenteeism of any type. 6. Failure or refusal to carry out orders or instructions. 7. Unsatisfactory work performance. 8. Failure to meet production standards for your position. 9. Failure to cooperate with coworkers or treating coworkers in a rude, disrespectful, or

unprofessional manner. 10. Treating a client, customer, patient, vendor, supplier, or other affiliate of NaphCare in a

rude, disrespectful, or unprofessional manner. 11. Failure to remain in your designated work station or area for prolonged periods without

a business-related purpose or justification. 12. Fraternizing with inmates through the course of performing your duties with NaphCare. 13. Failure to maintain the confidentiality of Company information. 14. Failure to fulfill the responsibilities of the job to an extent that might or does cause

injury to a person, or damage to or loss of product, machinery, equipment, facilities, or other Company property.

15. Violation of a safety, fire prevention, health, or security rule, policy or practice of the Company or of a facility being visited or contracted with the Company.

16. False, fraudulent, misleading or harmful statement, action or omission involving another employee, a customer, a patient, the Company or relations with the Company; or any action disloyal to the Company. This includes but is not limited to timesheets, expense forms, medical forms, forging signatures or falsifying any medical record documentation.

17. False, fraudulent, misleading or harmful statement, action or omission related to an employment application or any other information provided to or requested by the Company whether oral or written; or refusal or failure to timely provide such information.

18. Unauthorized use of, removal of, theft of or damage to the property of the Company, an employee, an independent contractor, or a visited facility.

19. Engaging in threatened or actual physical violence. 20. Using profane or abusive language. 21. Using the internet or email or any other Company property or technology for an

inappropriate or improper purpose. 22. Carrying any weapon while on Company business, job site, premises or property without

authorization from the Company. 23. Violation of any provisions of the Company’s Drug and Alcohol Free Workplace Policy. 24. Gambling or engaging in other disorderly or immoral conduct while on Company

premises, job site or business. 25. Engaging in conduct outside of the workplace that could harm the Company’s reputation. 26. Soliciting or distributing goods and/or literature in the workplace in violation of Company

policy. 27. Accepting or engaging in any outside employment with a competitor of the Company;

or conducting or attempting to conduct any outside business while on the Company’s premises or on Company business.

28. Garnishments beyond the type and number protected by law. 29. Harassment of or discrimination against another employee in violation of Company

policy. 30. A criminal conviction of an employee, depending on the particular circumstances and

the offense charged, including but not limited to the Company’s judgment as to the potential risk to the safety or health of employees, the security of Company premises and property, and/or the Company’s reputation.

31. Failure to dress or behave in a professional manner in the workplace or while on Company business.

32. Requesting or accepting gifts, premiums, or benefits of any kind valued in an amount greater than $25.00 from a supplier, vendor, or affiliate of the Company.

33. Violating any policy contained in this Handbook. Comply With Our Standards of Attendance In congruence with NaphCare’s core values, the Company expects employees to take pride in their work. Excessive absenteeism or tardiness is unacceptable and could be damaging to the quality of services


NaphCare provides. Excessive absenteeism or tardiness may result in disciplinary action, up to and including, termination. Excessive absenteeism or tardiness includes, but is not limited to, the following occurrences:

(a) Three (3) or more unscheduled absences or tardies in a three (3)-month period; (b) Failure to show up for work or arriving late for your shift one (1) or more days without

calling in; (c) Failure to follow the proper call-off procedure; or (d) Absence from work for two (2) or more consecutive work days without a legitimate

excuse such as illness or injury or other permissible leave provided for in this Handbook or under applicable law.

A doctor’s excuse must be provided for any illness or injury-related absence lasting three (3) or more consecutive days. Doctor’s excuses may also be requested within management’s discretion for any absence. If a full-time employee falls below the minimum hours required for their position and does not have the necessary PTO to fulfill those requirements it may result in a loss of benefits and full-time status unless otherwise protected by state or federal laws. Your designated facility may have a separate operating policy/procedure regarding attendance based on clinical needs within the facility. Said procedure/policy shall supersede this provision of the Employee Handbook. Maintain a Drug and Alcohol Free Workplace NaphCare has adopted a Drug and Alcohol Free Workplace Policy in order to protect the health, safety, and productivity of all employees and to promote the general welfare of the Company. The following actions are considered a violation of this Policy:

(a) Bringing onto the Company’s premises, property or job site, having possession of, being under influence of, using, consuming, distributing or attempting to distribute, manufacturing or dispensing, any form of narcotics, depressants, stimulants, hallucinogens, or any other perception-altering drugs, or prescription medications.

(b) Bringing onto the Company’s premises, property or job site, having possession of, being under the influence of, using, consuming, distributing or attempting to distribute, manufacturing or dispensing, any form of alcohol during working hours or outside working hours if such activity could or does adversely affect your job performance, yours or another person’s safety, or the Company’s property or reputation.

The Company reserves the right, in its discretion and to the extent permitted by federal, state, and local law, to examine or test for the presence of alcohol and/or drugs in the following situations:

(a) As part of a pre-employment physical examination. (b) As part of a physical examination which the Company may require employees to undergo

on a regular basis, on a schedule determined by the Company. (c) Where safety or health risks or the sensitive security duties of a specific job warrant it,

as determined in the Company’s discretion. (d) Following a safety infraction or work-related accident that does or might cause bodily

injury or damage to property. (e) When reasonable suspicion exists. Reasonable suspicion is defined as specific employee

behavior on the job, including, but not limited to, appearance, odor, speech, or other erratic or unusual conduct or circumstances, which suggests drug or alcohol use or a violation of the Company’s Drug and Alcohol Free Workplace Policy.

(f) As otherwise required or permitted by applicable law. Problem Resolution Procedure Employees who believe they have a valid work-related problem or who would like advice and counsel are encouraged to discuss problems with Company management without fear of reprisal. It is company


policy that no employee will be penalized for submitting a complaint or problem. If a difficult or problem situation arises, employees are urged to discuss it with their own supervisor first. Employees should request a meeting or telephone conference with Human Resources if the supervisor cannot resolve the situation. Every reasonable effort should be made to resolve the matter at the supervisory or Human Resources level. Problems submitted to Human Resources will be acknowledged and a proposed resolution will be presented to the employee as soon as possible, but no later than thirty (30) working days from the day the problem was first presented. If the employee believes that the problem has not been resolved at this level, the problem may be addressed at the executive level of management. This should be done in writing and should include the employee's name, work address, a summary of the problem, the date(s) of occurrence, the name(s) of individual(s) involved (if any), and the names and titles of witnesses, if any. A decision by executive management on the problem will be final. Corporate Compliance Program To ensure the provision of quality health care in compliance with constantly evolving laws and regulations, NaphCare has developed a Compliance Program. This program ensures our business practices are conducted legally and ethically and assists employees in making the right choices regarding our business practices. The Compliance Program is responsible for establishing and maintaining NaphCare’s Code of Business Ethics and Conduct Guide. The Compliance Program and the Code of Business Ethics and Conduct Guide can be found posted on the company intranet, via NaphCare Online. In the event you believe a violation of NaphCare’s Code of Business Ethics and Conduct Guide has occurred, you should follow the procedure described in Code of Business Ethics and Conduct Guide. Workplace Violence It is NaphCare’s policy to promote a safe working environment for all of our employees. The Company will not tolerate violence, threats of violence, harassment, intimidation, or any other disruptive behavior in the workplace or outside of the workplace as between employees. Individuals who commit such acts may be removed from the premises immediately and will be subject to discipline, up to and including, termination from employment. The cooperation of all employees is needed to maintain a safe working environment. If you observe or experience violence, threats of violence, harassment, intimidation, or other disruptive behavior by anyone on Company premises, whether the person is an employee or not, you are to report it immediately to your supervisor. In the same manor, if you observe these behaviors between Company employees whether on or off Company premises, you are to report this behavior to your supervisor immediately. All reports will be taken seriously and dealt with immediately within the Company’s discretion. No Harassment NaphCare makes every effort to assure a safe and pleasant work environment; however, certain elements of the correctional environment are beyond our control. If any situation arises where you feel the behavior, language or action of inmates or facility personnel is inappropriate or offensive, you should notify your immediate supervisor. NaphCare is also committed to its policies of preventing and promptly correcting workplace harassment. The law prohibits harassment based upon an individual’s race, color, sex, age, national origin, religion, disability, pregnancy, veteran or military status, or other characteristic protected by federal, state or local law. In keeping with the spirit and letter to Title VII of the Civil Rights Act of 1964 and other applicable laws, NaphCare does not authorize and will not tolerate any form of harassment of or by any employee (supervisory or non-supervisory) or non-employee. The term harassment includes, but is not limited to, offensive language, jokes, or other verbal, graphic or physical conduct relating to an employee’s race, color, sex, age, national origin, religion, disability, pregnancy, veteran or military status, or other characteristic protected by federal, state or local law which would make the reasonable person experiencing such harassment uncomfortable in the work environment or which could interfere with the person’s job performance. It is also unlawful to retaliate against an employee who reports a complaint of harassment. Any NaphCare employee who engages in unlawful harassment or retaliation will be disciplined, up to and including, termination from employment. Sexual harassment may include unwelcome sexual advances, requests for sexual favors, sexually suggestive or degrading communications, or other statements and conduct of a sexual nature. Sexual harassment may be overt or subtle. Some behavior that is appropriate in a social setting may not be appropriate in the workplace. Sexual harassment does not refer to behavior or occasional compliments


of a socially acceptable nature. It refers to behavior that is not welcome and that is personally offensive. Sexual harassment may include unwelcome sexual advances, request for sexual favors, sexually degrading or suggestive communications, or statements, and other verbal, visual or physical conduct of a sexual nature. All new employees review the sexual harassment training video during their orientation period.


THE COMPANY’S RESPONSIBILITIES Management Rights Notwithstanding any other provision of this handbook, all managerial and administrative functions and prerogatives entrusted to and conferred upon employers inherently, expressly, and by law, are retained and vested exclusively with our Company. This includes but is not limited to the right to exercise our judgment and discretion to take whatever action is necessary to operate the Company's business, protect its employees, clients, property, security, and general welfare; to reduce, contract out, sell, close down, or relocate the Company’s operations or any part thereof; to hire, layoff, direct, discipline, discharge, or increase the efficiency of the workforce in the manner and to the degree the Company deems appropriate; to set the standards of productivity, maintenance, services, security, research and development; and, in general, to take whatever other actions necessary in the Company's judgment and discretion to administer the Company's operations and direct its work force. Although the Company from time to time expects to expand the wages, benefits, work rules, services, and policies summarized in this handbook, we reserve the right to alter, amend, reduce or discontinue any wage schedule, policy, work rule or benefit included in this handbook. The failure of the Company to exercise any prerogative or function in a particular way shall not be considered a waiver of the Company's right to exercise such prerogative or function or preclude it from exercising that prerogative or function in some other way. Affirmative Action/Equal Opportunity Employment NaphCare is an affirmative action and equal opportunity employer. The Company is firmly committed to its policies of treating all job applicants and employees equally without regard to race, color, sex, age, national origin, religion, disability, pregnancy, veteran status, or any other characteristic protected by federal, state or local law. NaphCare maintains programs to comply with all federally mandated affirmative action requirements in all of its employment activities, including, but not limited to, recruiting, hiring, promoting, discipline and termination, and compensation. The Company’s Equal Employment Opportunity Policy is attached to this Handbook for further review and reference. If you have any questions or concerns about the Company’s affirmative action or equal employment opportunity policies, please contact your immediate supervisor or the NaphCare corporate office. Guidelines for this Handbook This Handbook has been prepared to provide general information about employment with NaphCare. The provisions of this Handbook are intended to be guidelines only and are not an all-inclusive or exhaustive set of all NaphCare rules and policies. This Handbook does not constitute a contract of employment. Employment with NaphCare is at will. This means that employment is for no guaranteed or specific duration. Your employment may terminate for any reason with or without cause or notice at the discretion of NaphCare. This provision is subject to and limited by state law where applicable. This Employee Handbook supersedes any prior Employee Handbook of NaphCare. To the extent a conflict exists between a provision in this Handbook and another written policy or unwritten practice and procedure of NaphCare, the provisions of this Employee Handbook shall control. Further, to the extent any state law provision conflicts with the provisions of this Handbook, the governing authority shall control. If you have questions about your employment with NaphCare or the materials contained in this


Handbook, consult your immediate supervisor or Human Resources. Employees Subject to Collective Bargaining Agreement Some NaphCare employees may be union members and subject to a Collective Bargaining Agreement. To the extent your employment with NaphCare is covered by a Collective Bargaining Agreement, and a conflict exists between a provision of the Collective Bargaining Agreement and this Handbook, the provision of the Collective Bargaining Agreement controls. Otherwise all provisions of this Handbook remain in full force and effect.



ACKNOWLEDGEMENT OF RECEIPT OF EMPLOYEE HANDBOOK EFFECTIVE January 1, 2020

I __________________________________________, acknowledge and agree to the following:

(Please Print Name)

1. I have received a printed copy and understand that the NaphCare Employee Handbook

(“Handbook”) is also available via the Company Intranet. 2. I will read the Handbook in its entirety. I understand that I am obligated to comply with

all of the policies and procedures contained in the Handbook and that any failure by me to abide by those policies and procedures may result in disciplinary action against me including, but not limited to, my employment being terminated.

3. The Handbook is a summary of some of the policies and procedures that govern

employees.

4. I acknowledge that I have read and understand the Mobile Devices policy contained within this Handbook and will comply with the requirements listed within the policy to ensure confidential information and protected health information are secured on my device(s) properly.

5. The Handbook supersedes and replaces all previously issued handbooks.

6. The Handbook and the policies contained therein do not create an employment contract

between NaphCare and me, or any other employee. In addition, NaphCare has the right to change compensation and benefits plans at its discretion.

7. NaphCare may revise the policies or procedures in the Handbook, in whole or in part, at

any time, with or without notice.

8. Unless I have a written employment contract which specifies to the contrary and which is executed by an authorized NaphCare representative, my employment is at-will and not for any specific period of time. I further acknowledge that this Handbook does not limit my right or NaphCare’s right to terminate my employment at any time for any reason not prohibited by law.

_________________________________ __________________________ Employee’s name (please print) Witness _________________________________ Employee’s signature _________________________________ Date


ACKNOWLEDGMENT OF HARASSMENT TRAINING I hereby acknowledge that I have reviewed NaphCare’s policy against harassment in the workplace, including the company’s procedures for reporting a complaint of harassment. I further acknowledge that I have viewed the company’s sexual harassment training video. Employee Name (Printed) Employee Signature Date


EQUAL EMPLOYMENT OPPORTUNITY POLICY NaphCare, Inc. (the “Company”) maintains a continuing policy of non-discrimination in employment. It is the Company’s policy to provide equal opportunity and access for all persons, without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, or status as a disabled veteran or other protected veteran, in all phases of the employment process and in compliance with applicable federal, state, and local laws and regulations. This policy of non-discrimination shall include, but not be limited to, the following employment decisions and practices: hiring; promotions; demotions or transfers; layoffs; recalls; terminations; rates of pay or other forms of compensation; selection for training, including apprenticeship; and recruitment or recruitment advertising. The Company will not discharge or in any other manner discriminate against employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant. However, employees who have access to the compensation information of other employees or applicants as a part of their essential job functions cannot disclose the pay of other employees or applicants to individuals who do not otherwise have access to compensation information, unless the disclosure is (a) in response to a formal complaint or charge, (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer, or (c) consistent with the Company’s legal duty to furnish information. Employees and applicants of the Company’s t will not be subjected to any form of harassment or discrimination for exercising rights protected by, or because of their participation in an investigation or compliance review related to, the Americans With Disabilities Act, Section 503 of the Rehabilitation Act of 1973, the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, the Veterans Employment Opportunities Act of 1998, or any other federal or state non-discrimination law, rule, or regulation. Such rights include protection against discrimination on the basis of a person’s relationship or association with a protected veteran.

If you believe that you have been discriminated against in any manner as described above, you should notify Human Resources. Human Resources will continue to direct management personnel to take such action as may be required to prevent behavior prohibited by this policy. All matters will be investigated and appropriate disciplinary action will be taken, up to and including termination of employment, if necessary. Retaliation against anyone who complains of or witnesses behavior contrary to this policy is also prohibited.

The Company also maintains affirmative action programs to implement our equal employment opportunity policy for disabled individuals and protected veterans. Employees or applicants who wish to review the Company’s affirmative action program for disabled individuals and protected veterans may schedule an appointment to do so by contacting the Human Resources office Monday – Friday from 8:00 a.m. until 5:00 p.m.

Bradford T. McLane Chief Executive Officer

Documents

EMPLOYEE HANDBOOK · month, the Company’s Human Resources Department will run reports to identify licenses due to expire ... reference checks. This process is conducted for security