Substance Abuse and Drug-Free Workplace

The Company is concerned about the use of alcohol, marijuana, illegal drugs, and controlled substances and the effect such use has on the workplace. Use of these substances, whether on or off the job, can detract from an employee's work performance, efficiency, safety, and health, and can seriously impair Company operations. Use or possession of these substances on the job creates a potential danger to the welfare and safety of other employees and exposes the Company to the risk of property damage, loss, or injury to others.

Prohibited Conduct

The following rules and standards of conduct apply to all employees while on Company property, while at work, or while working on Company business. Each of the following is strictly prohibited:

• Being under the influence of, or impaired by, an illegal or controlled substance, alcohol, or marijuana while on the job.
• Using or possessing illegal or controlled substances, alcohol, or marijuana while on the job, including the illegal use of prescription drugs and the possession of drug paraphernalia.
• Being under the influence of a controlled substance for which the employee has a valid prescription, unless the prescribing physician has advised the employee that the substance will not adversely affect his or her ability to perform job duties safely and efficiently.
• Distributing, selling, or purchasing an illegal or controlled substance, alcohol, or marijuana while on the job.

Note that, although Florida law permits the use of medical marijuana by qualified patients, marijuana remains a Schedule I controlled substance under federal law. Florida law does not require an employer to accommodate the on-duty use, possession, or impairment from marijuana, and use of marijuana in any form is treated under this policy in the same manner as use of any other controlled substance.

Violations of these rules and standards will not be tolerated. The Company also reserves the right to bring violations to the attention of appropriate law enforcement authorities.

Searches and Investigations

To enforce this policy, the Company reserves the right to conduct searches of Company property, of employees, and of employees' personal property brought onto Company premises, and to take other measures reasonably necessary to deter and detect abuse of this policy.

Off-Duty Conduct

An employee's conviction on a charge of illegal sale or possession of a controlled substance, even off Company property and off-duty, will not be tolerated, because such conduct reflects adversely on the Company. The Company also has a strong interest in keeping individuals who sell or possess controlled substances off Company premises in order to keep the controlled substances themselves off the premises.

Florida Drug-Free Workplace Program

The Company may elect to maintain a Drug-Free Workplace Program under Florida Statutes Section 440.102. Where the Company participates in the program, the following procedures apply in addition to the general policy above:

• Written policy and notice. The Company will maintain a written substance abuse policy and will provide employees with a copy and with at least 60 days advance notice before drug testing begins (except as otherwise permitted by law for newly hired employees and certain other situations).
• Categories of testing. Testing may be conducted on a pre-employment, reasonable suspicion, post-accident, routine fitness-for-duty, and follow-up basis, as defined by Section 440.102 and the Company's written policy.
• Substances tested. Specimens may be tested for alcohol and for the controlled substances identified in the Florida Drug-Free Workplace Program rules and the Company's written policy.
• Employee assistance. The Company will provide employees with information regarding available employee assistance programs and resources for the treatment of substance abuse.
• Confidentiality. Information obtained through the Drug-Free Workplace Program will be treated as confidential and will be released only as permitted by Section 440.102 and other applicable law.
• Right to explain and to challenge results. Employees and applicants will have an opportunity to provide the medical review officer with information relevant to a confirmed positive test result and to contest or explain the result in accordance with the program rules.
• Consequences of refusal or positive results. A refusal to submit to testing, a confirmed positive test, or tampering with a sample may result in disciplinary action, up to and including termination, and may affect eligibility for workers' compensation indemnity benefits as provided under Florida law.
• Notification of convictions. Any employee convicted of a criminal drug violation occurring in the workplace must notify the Company in writing within five calendar days of the conviction. The Company will take appropriate action within 30 days of notification, and federal contracting agencies or affected payers will be notified when required.

Treatment and Rehabilitation

The Company encourages and will reasonably accommodate employees who have an alcohol, marijuana, or drug dependency to seek treatment or rehabilitation. Employees who wish to seek such assistance should request a treatment or rehabilitation leave. The Company is not, however, obligated to continue to employ any person whose performance of essential job duties is impaired because of drug, alcohol, or marijuana use. Employees who are given the opportunity to seek treatment or rehabilitation but who fail to successfully overcome their dependency will not automatically be reemployed or be granted a second opportunity for treatment.

This treatment and rehabilitation provision is not intended to affect the Company's response to violations of the prohibited conduct described above. Rehabilitation is an option for an employee who acknowledges a chemical dependency and voluntarily seeks treatment to end that dependency.

This policy represents management guidelines. For more information, please contact Human Resources.