COPC Handbook April 2025 Q2

4.4.1 Employee Use of Illicit Drugs and Alcohol

4.4.2 Exceptions to Alcohol Rules From time to time, COPC may sponsor social or business-related events at which alcohol is served. This policy does not prohibit the use or consumption of alcohol at such events. However, if employees choose to consume alcohol at such events, they must always do so responsibly and maintain their obligation to conduct themselves properly and professionally. Attendance at all or manufacture illicit drugs and/or alcohol while on the job or on/in Company property, as well as employees who are impaired by legal drugs/ Employees who are under the influence of, and/or who use, possess, purchase, receive, sell, distribute,

substances (including but not limited to prescription medications, over-the-counter medications, alcohol, or marijuana) that result in impairment while working, are in violation of this policy.

Company social events and/or parties is not required and is completely voluntary. Under no circumstances may alcohol be consumed by or will alcohol be made available to any individual under the age of 21 on the job, on/ in Company premises/property or at Company- related activities.

4.4.3 Prescription and Over the Counter Drugs

COPC does not prohibit employees from using prescription or over-the-counter drugs when used as prescribed, provided: (a) the prescription drugs are prescribed to the employee for medical reasons by a United States-licensed medical practitioner, and are used according to dosage and frequency of use prescribed on the label or accompanying documentation, and (b) the employee’s use of the prescription or over-the-counter drug does not adversely affect the employee’s job performance or conduct; threaten the safety, productivity, public image, or property of COPC or its employees or patients; or result in criminal behavior (e.g., a drug related arrest or conviction, etc.).

It is an employee’s responsibility to learn if a prescription or over-the-counter drug they are taking may adversely affect job performance or conduct; threaten the safety, productivity, public image, or property of COPC or its employees or patients; and/or result in criminal behavior. No employee is to perform any function or duty on behalf of COPC if the drugs being taken under this provision could adversely affect their ability to perform any such function or duty safely and satisfactorily. In such situations, the employee should notify their Direct Supervisor or a member of the Human Resources Department for resolution to the issue.

4.4.4 Medical and Recreational Marijuana

We recognize that employees may engage in the use of marijuana for medical or recreational purposes. At no time are employees permitted to work while impaired by the use of marijuana (due to medical or recreational use) or any other drug, substance, or medication which may negatively impact the workplace. The employee must retain valid documentation that is easily accessible and presented to COPC and other appropriate authorities upon request.

Applicants who voluntarily share that they use medical marijuana may be required to provide documented proof of their medical marijuana prescription. Any employee who is impaired at work due to medical marijuana or who tests positive for it after reasonable suspicion testing, may be terminated from employment.

4.4.5 Use that Impacts the Workplace

Employees who use illicit drugs or legal drugs/ substances (including but not limited to prescription medications, over-the-counter medications, alcohol, or marijuana) off-the job in a manner which affects job performance and/or threatens the safety, productivity, public image, 4.4.6 Employees Who Are On-Call Should a situation occur in which an employee is contacted to report for duty and the employee believes that they may be under the influence as defined in this policy, the employee is required to

or property of the Company or its employees or patients may violate this policy. Additionally, employees whose behavior results in a criminal incident, (e.g., DUI, another drug and/or alcohol- related arrest or conviction, etc.) may be in violation of COPC policy.

notify their Direct Supervisor of the specific situation in order to determine what may be the best solution for the impaired employee and for the requirements of completing the business needs at hand.

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