COPC Handbook December 2023 Q4

EMPLOYEE HANDBOOK

Updated December 2023

Introduction At Central Ohio Primary Care (COPC or “the Company”), we recognize that employees are vital to our success. We value and appreciate the contributions all our employees make each day to this organization. It is our intent to work closely with our employees, making certain they understand the requirements of their job and providing them with opportunities to develop so that they may be successful and passionate about the important work they do. Physicians and staff, at all levels of the Company, are considered “employees” for the purpose of and as referenced in this handbook. This handbook does not create a contract, implied or expressed, with employees of COPC. Employment may be terminated “at will” by COPC management or by the employee at any time and for any reason or no reason at all. No manager or employee of COPC has the authority to enter into any agreement for employment for any specified period-of-time or to make any agreement contrary to the foregoing or to the conditions set forth in this handbook. Any such agreement must be in writing and signed by the Chief Executive Officer (CEO). COPC reserves the right to interpret, modify, revoke, revise, suspend, or terminate this handbook and/or any and all of the policies, procedures or benefits described herein in whole or in part, at any time, with or without prior notice. In addition, changes to applicable federal, state, or local laws or regulations may require the Company to modify or supplement this handbook. Any oral representations related to the policies in this handbook do not create a binding employment contract of any kind or any promise of job security upon which an employee should rely. The policies set forth in this employee handbook are the policies that were in effect at the time of publication, and the current handbook supersedes all previous versions. Should employees have any questions as to the interpretation or understanding of any policy or procedure in this handbook, they should contact their Direct Supervisor or the Human Resources Department for clarification. It is important for all employees to have a full and complete understanding of all employment policies and procedures.

03 04

Introduction

Welcome Message

06

Section I: General Employment Policies

18

Section II: Hiring, Employment Classifications, Termination of Employment and Recordkeeping

24

Section III: Standard Operating Guidelines

32

Section IV: Drug and Alcohol Policy

36

Section V: Attendance, Timekeeping and Payroll

40

Section VI: Benefits, Observed Holidays and Paid Vacation Benefits

44

Section VII: Leave Policies and Other Excused Time-Off

50

Section VIII: Family Medical Leave Act (FMLA)

56

Section IX: Computer, Email and Internet Use

60

Section X: Use of Company Property

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

Welcome Message

Welcome to COPC! We are pleased with your decision to join COPC and glad to have you as part of our team. COPC is committed to providing a work environment that is professional, affirming, inclusive, and respectful of the uniqueness of every employee. You are now part of an organization which has an outstanding reputation for providing quality health care throughout Central Ohio. We trust that you will find satisfaction and take pride in knowing that your work makes a difference to our patients and to the communities we serve through Clinical Excellence , Mindful Service , and the Modernization of Primary Care . Our mission is to be the Best for our Patients, the Best for Each Other, and the Best for Primary Care. To accomplish this mission, we must: • Always seek a higher standard of excellence • Always take responsibility for the entirety of a patient’s care

• Always be mindful of the power of kindness • Always pursue collaborative independence • Always work toward the improvement of primary care

Regardless of the title or position you hold with COPC, you play an important role in taking great care of our patients. Every job here is important and we believe every employee contributes to the overall success of COPC. The day you start working, you become an integral part of COPC and the overall health of our patients. We expect all employees to treat one another and our patients with professionalism, compassion, kindness, and respect. We can accomplish this by: • Being intentionally kind – choose first to make others feel welcome, valued, and appreciated. • Collaborating – working together moves us all forward. Every role contributes to our success. • Being transparent – share information openly, involve others and ask for feedback. • Investing in each other – support personal and professional development. • Prioritizing health and wellness – find time to balance care for your health and the health of others. This employee handbook contains general information regarding policies, procedures, and benefits. Please read it carefully. You will be required to acknowledge your understanding of its contents and abide by the policies of this employee handbook. Should you have questions regarding any of the information contained within, please reach out to your Direct Supervisor or the Human Resources Department. We’re glad you’re here and welcome to the team!

Donald Deep, M.D. Chief Executive Officer

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

SECTION I

1.1

Code of Conduct The COPC Code of Conduct is a commitment to perform work in an ethical, honest, moral, and legal manner. Employees are required to perform their job duties and responsibilities in a cooperative and professional manner that reflects favorably on themselves and the Company. All employees are expected to maintain high ethical and work performance standards. Employees are to exercise a mature, courteous, and helpful attitude. Service to our patients, employees, vendors, and others will be professional, thorough, and timely. This means any words or actions which could be construed as harassing, degrading, or offensive will not be tolerated. To ensure orderly operations and an enjoyable work environment, the Company expects employees to follow rules of conduct that will protect the interest and safety of all employees and the organization. All employees must be alert and sensitive to situations that could result in improper, unethical, or illegal conduct. Employees with a compliance or ethics concern have an obligation and responsibility to report the concern to either a Direct Supervisor or the Compliance Hotline. The toll-free Compliance Hotline number

While not intended to be an all-inclusive list, the examples listed below represent behaviors which are considered to be unacceptable in the workplace. Behaviors such as these, as well as other forms of misconduct, may result in disciplinary action, up to and including termination of employment, and in some cases, immediate termination of employment with no notice: ● Fighting or threatening workplace violence ● Unsafe medical practices ● Violation of patient ethics and patient privacy ● Sexual harassment and/or other unlawful or unwelcome harassment ● Workplace bullying ● Theft of any kind (including falsification of timekeeping records) ● Insubordination ● Unprofessional or disrespectful conduct ● Negligence or improper conduct leading to damage of Company owned or patient owned property ● Unauthorized presence on Company property during non-business hours ● Use of Company equipment without prior authorization ● Misrepresentation of personal work history, skills, or training ● Divulging COPC confidential information ● Any misrepresentation of COPC not limited to a patient, a prospective patient, the general public, a vendor, or an employee ● Possession, distribution, sale, transfer, or use of illicit drugs in the workplace, as well as any inappropriate use of legal drugs/substances (including but not limited to prescription medications, over-the-counter medications, alcohol, or marijuana) that results in impairment while working. See Section 4.4 ● Gambling ● Gossiping or spreading rumors about co- workers ● Dishonesty ● Boisterous or disruptive activity in the workplace ● Violation of safety or health policies/rules ● Smoking violations in the workplace in any form, as described in Section 1.15 ● Excessive absenteeism or absence without notice Other forms of misconduct not listed above may also result in disciplinary action, up to and including termination of employment. Civil and/or criminal penalties may also apply depending on the severity of the offense.

General Employment Policies

1.1 Code of Conduct 1.2 Physician Code of Professional Behavior 1.3 “At Will” Employment

1.4 Equal Opportunity Employer 1.5 Immigration Law Compliance 1.6 Americans with Disabilities Act (ADA) and ADA Amendments Act (ADAAA) 1.7 Service Animals 1.8 Anti-Retaliation and Whistleblower 1.9 Conflict of Interest 1.10 Open Door 1.11 Communications & Problem Solving

is (866) 539-5813 and is available 24 hours a day, 7 days a week.

Calls are answered by a third-party vendor with trained staff who will ask questions to obtain the facts and circumstances of the concern, prioritize and categorize the concern, and assign a severity level. A call back date will be provided to obtain follow-up information on the concern. Every reasonable effort will be made to keep employee identity confidential but, despite our best efforts, there may be instances in which caller identity may become known or may have to be revealed to investigate the concern. Employees are responsible for abiding by the Code of Conduct. Managers and Physicians have an additional responsibility to understand the Code of Conduct so they can serve as role models and provide guidance to employees. Violations not only have potential legal and regulatory consequences; they can harm the reputation of COPC.

1.12 Relationships at Work 1.13 Employment of Relatives

1.14 Office Closures (Unplanned and Planned) 1.15 Smoke-Free, Tobacco-Free Workplace

1.16 Break Time for Nursing Parents 1.17 Safety & Accident Rules - OSHA 1.18 Health & First Aid

1.19 Communicable Diseases 1.20 Vaccine Recommendations 1.21 Personal Property: Damaged, Lost, or Stolen 1.22 Solicitations, Distributions, and Posting of Materials

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

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Physician Code of Professional Behavior

in a work environment that supports teamwork and respect for other people, regardless of their position in the organization. Disruptive behavior that intimidates others and affects employee morale can also harm care. The Physician Discipline policy can be found here. In addition, all staff must adhere to the Gifts and Gratuities To/From Patients policy.

The physicians and staff at each COPC work location are dedicated professionals focused on providing quality, safe care for their patients. The intent of this policy is to ensure that all individuals are treated with courtesy, respect, and dignity. This policy focuses on the expected conduct that physicians display towards each other, their staff, and their patients. In addition, this policy addresses the process that will be used to handle cases of inappropriate conduct. Safety and quality thrive “At Will” Employment Employment at COPC is “at will” for all employees who are hired to work for COPC. This means employees are free to resign at any time and COPC may terminate the employment relationship at any time, for any reason not prohibited by law. As an “at will” employee, it is not guaranteed in any manner that employees will be employed with COPC for any set period of time. An employee’s job description may be amended, modified, or terminated at any time by COPC. Only the Chief Executive Officer (CEO) has authority to enter into an agreement for employment for a specified Equal Opportunity Employer COPC is an Equal Opportunity Employer. Employment opportunities at COPC are based on an employee’s qualifications and capabilities to perform the essential functions of a particular job. All employment opportunities are provided without regard to race, color, religion, gender and gender expression, transgender, sexual orientation, citizenship, national origin, ancestry, age, military status, veteran status, disability, genetic information, pregnancy, or any other characteristic protected by local, state, or federal law. This Equal Employment Opportunity policy governs all aspects of employment including, but not limited

1.3

period of time or to make an agreement for employment other than “at will”, and then it must be in writing and signed by both the employee and CEO. No other member of management or employee at COPC has the authority to make any such agreement. Nothing in this handbook may be construed as creating a promise of future benefits, a guarantee of continued employment, or a binding contract between COPC and any of its employees.

1.5

Immigration Law Compliance COPC adheres to the Immigration Reform and Control Act of 1986 (IRCA), which is a federal law. The IRCA requires the Company to complete required I9 forms to verify that every employee hired is authorized to be employed in the United States. The Act requires that on the first day of employment, all employees complete and sign Section 1 of Form I-9, Employment Eligibility Verification Form and present documents proving their identity and eligibility to work in the United States.

The law applies to all classifications of full-time and part-time employees employed by the Company. Should an employee be unable to present required documents within three (3) days of hire or show proof that they have applied for the required documents (and provides the documents within 90 days of hire), the Company will be forced to terminate the employment relationship no later than the third day of hire from COPC, as required by law.

1.4

to, recruitment, hiring, selection, job assignment, promotions, transfers, compensation, discipline, termination of employment, layoff, access to benefits and training, and all other conditions and privileges of employment. COPC requires the reporting of all instances of discrimination and harassment as a condition of employment and prohibits retaliation against any individual who reports discrimination or harassment, or participates in an investigation of such report. Violations of this policy may result in disciplinary action, up to and including termination of employment.

1.6

Americans with Disabilities Act (ADA) and ADA Amendments Act (ADAAA)

It is the policy of COPC to comply with all federal and state laws concerning the employment of persons who are pregnant or disabled and to act in accordance with regulations and guidance issued by the Equal Employment Opportunity Commission (EEOC). Furthermore, it is the policy of COPC not to discriminate against qualified individuals who are pregnant or disabled regarding the application procedures, hiring, advancement, discharge, compensation, training, or other terms, conditions, and privileges of employment. The Company will reasonably accommodate qualified individuals who are pregnant or disabled

so that they can perform the essential functions of a job unless doing so causes a direct threat to these individuals or others in the workplace and the threat cannot be eliminated by a reasonable accommodation and/or if the accommodation creates an undue hardship to COPC. Important note: It is the obligation of the employee to notify their Direct Supervisor and/or to notify any member of the Human Resources Department if the employee needs an accommodation to perform their job.

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

1.8

Anti-Retaliation and Whistleblower This policy is designed to protect employees and address the commitment of COPC as it relates to integrity and ethical behavior in the workplace. In accordance with federal anti-retaliation and whistleblower protection regulations, COPC will not tolerate any retaliation against an employee who: ● Makes a good faith complaint or threatens to make a good faith complaint regarding

● Objects to or refuses to participate in any activity, policy, or medical practice which the employee reasonably believes is a violation of the law. ● Provides information to assist in an investigation regarding violations of the law. ● Files, testifies, participates, or assists in a proceeding, action or hearing in relation to alleged violations of the law.

suspected company or employee violations of the law, including discrimination or other unfair employment practices. ● Makes a good faith complaint or threatens to make a good faith complaint regarding accounting, internal accounting controls, or auditing matters that may lead to incorrect or misrepresentations in financial accounting. ● Makes a good faith report or threatens to make a good faith report of a violation that endangers the health or safety of an employee, client, or patient, environment, or the general public. Conflict of Interest A conflict of interest occurs when an employee’s personal interests interfere, or appear to interfere, with the employee’s ability to make sound business decisions on behalf of the Company. COPC employees have a responsibility to avoid any real or potential conflicts of interest as outlined in the guidelines below. Conflicts of interest include, but are not limited to the following scenarios: ● When an employee is in a position to influence a decision or have business dealings on behalf of COPC that might result in a personal gain for the employee or for one of the employee’s relatives or friends. ● A conflict of interest may occur when an employee has financial interest in a business or venture that may conflict with the interests of COPC. ● A personal gain is defined as a gift, gratuity, favor, service, compensation in any form, discount, special treatment, or anything of monetary value. Open Door COPC welcomes the opportunity to discuss business, employee, and/or patient-related concerns and suggestions for improvements to business operations, employment experience, and/or patient care as a whole and strives to

1.9

COPC does not automatically assume that there is a conflict of interest when an employee has a relationship with another company. By informing COPC that there is the possibility of an actual or potential conflict of interest, COPC has the opportunity to establish safeguards to protect everyone involved. All inquiries will be kept confidential to the maximum extent possible. Employees should consult with the Compliance or Legal Departments when circumstances are such that there is a question regarding a potential conflict of interest. Failure to identify a conflict of interest may result in disciplinary action, up to and including termination of employment. This policy is not intended to restrict an employee’s right to discuss, or act together to improve, wages, benefits, and working conditions with co-workers or in any way restrict employees’ rights under the National Labor Relations Act.

1.7

Service Animals Service animals are animals (primarily dogs) that are individually trained to do work or perform tasks for people with disabilities. Service animals are working animals, not pets. The work or task a service animal has been trained to provide must be directly related to the person’s disability and documentation. Employees may be asked to confirm that the service animal is required because of a disability and the work or task the animal has been trained to perform. Animals whose sole function is to provide comfort or emotional support do not qualify as service animals under the Americans with Disabilities Act (ADA). Under the ADA and Section 504 of the Rehabilitation Act of 1973, health care facilities must permit the use of a service animal by a person with a disability, including during a public health emergency or disaster. ● Service animals are to accompany the

● It may be appropriate to exclude a service animal from limited access areas that employ general infection control measures where the animal’s presence may compromise a sterile field environment. ● Service animals must be harnessed, leashed, or tethered, unless these devices interfere with the service animal’s work or if an individual’s disability prevents using these devices. The handler/owner must maintain control of the animal through voice, signal, or other effective controls. ● When encountering an individual with a service animal, do not interact with or distract the animal.

individual with a disability in all areas of COPC offices where employees, visitors, and patients are normally allowed during patient services, unless the animal’s presence or behavior creates a fundamental alteration in the nature of a facility’s services in a particular area or a direct threat* to other persons in a particular area. *A “direct threat” is defined as a significant risk to the health or safety of others that cannot be mitigated or eliminated by modifying policies, practices, or procedures. ● A person with a disability will be asked to remove their service animal from the premises if the animal is not housebroken, is out of control, or if the handler/owner does not take effective action to control the service animal.

1.10

maintain an open-door policy with employees. Employees should feel free to discuss any questions, problems, complaints, or suggestions with any member of management.

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

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1.14

Communications and Problem Solving It is the intent of the Company to deal fairly with all employees. In the event a problem, misunderstanding, or complaint occurs regarding an employee’s job evaluation, discipline, or other matters affecting the work relationship, the employee should follow the procedure below to resolve the issue.

Office Closures (Unplanned and Planned) Unplanned Closure COPC recognizes that on occasion weather or emergency situations may affect our ability to be open for business, remain open for the entire day, or may affect an employee’s ability to travel safely to and from their work location. Employees should assume their work location is open for business unless otherwise notified by their Direct Supervisor or another member of the leadership team. Emergencies that may cause office closures, delayed openings, or early releases include, but are not limited to, water main breaks, power failures, public health crisis or pandemic, hazardous weather conditions, or severe transportation difficulties. Certain essential services may be required to be maintained during any closing. Essential staff involved in these essential services are excused from work only with the specific authorization of their Direct Supervisor, regardless of other closure notifications. Supervisors should make clear beforehand who are essential staff in emergencies, Smoke-Free, Tobacco-Free Workplace COPC is committed to providing a safe and healthy workplace and to promoting the health and well-being of our employees. As required by the State of Ohio and also as motivated by our desire to provide a healthy work environment for everyone, COPC prohibits smoking and the use of all tobacco-related or tobacco-substitute products including cigarettes, pipes, cigars, smokeless tobacco, vapes, and e-cigarettes on all company premises unless an outside area has been designated by management and is clearly identified to allow smoking. All laws governing the State of Ohio regulations around smoking, in addition to alternate locations which prohibit smoking (for which an employee may be or is assigned to work at) will be strictly enforced by COPC.

For more information regarding pay and procedures during both unplanned and planned office closures, please reference the Office Closures policy. preferably no less than two weeks prior to the closure. The closure may consist of certain hours of a regular workday (e.g., delayed start or closing early) or in full day increments. what their obligations are, and establish procedures to let them know whether they will be needed to work. Failure to report to work during emergencies by employees required for essential services may be cause for disciplinary action, up to and including termination of employment. Planned Closure There may be times in which a work location may choose to have a planned closure. A planned closure is defined as one in which the closure is announced to staff with as much notice as possible, Please note, the smoke-free, tobacco-free workplace policy applies to: ● All employees ● Alternate locations which prohibit smoking ● All areas of Company buildings ● All off-site Company-sponsored events and meetings ● All vehicles owned or leased by the Company ● All visitors (patients and vendors) to any Company premises ● All contractors and consultants and/or their employees working on Company premises

Discuss the matter with the employee’s Direct Supervisor at the earliest possible time. Everyone benefits from efforts to settle the difficulty on its merits and without delay. If an employee believes the management team or a member of the management team is contributing to the problem, employees should contact Human Resources at the earliest available opportunity. If an employee feels they are unable to initiate resolution to the issue in this manner, proceed to Step #2.

At the employee’s request, another member of the management team or Human Resources can speak with the employee independently and, if appropriate, will mediate with the employee and the employee’s manager to discuss the facts of the issue in an effort to settle it.

If the matter continues to remain unresolved, at the employee’s request, the Chief Human Resources Officer (CHRO) or the CEO will meet with the employee independently. Based on this meeting and the facts gathered to date, the CHRO and/or the CEO will have the authority to determine a resolution which is in the best interest of both COPC and the employee.

If the employee’s complaint is of discrimination, sexual harassment or any form of unlawful or unwelcome harassment, the procedures set forth in Section 3.10, “Discrimination, Harassment and Sexual Harassment Prevention Policies and Complaint Procedure” should be followed.

1.15

1.12

Relationships at Work

Employment of Relatives While COPC does permit the employment of relatives, it is strongly discouraged that those relatives be in any direct or indirect manager/ COPC discourages employees from having personal relationships with another employee while both employees are employed by COPC. Personal relationships in the workplace may result in an increased potential for unlawful or unwelcome sexual harassment, may give the appearance of favoritism in managerial decisions, may add to the impairment of job performance and behavior, and/ or may cause disruption in the workplace. Should subordinate relationship. Being in a direct or indirect manager/subordinate relationship with a relative may create the appearance of favoritism and/or bias, real or not real. In addition, personal conflicts between relatives may carry over into the workplace and create a disruptive work environment, which will not be tolerated. New hires must disclose if they are married to or otherwise related to other COPC employees in which there may be a direct or indirect manager/ subordinate relationship via the Conflict of Interest form they complete during onboarding.

such a disruption in the workplace be brought to management’s attention and it is determined that a negative effect on business operations has resulted, disciplinary action may be taken, up to and including termination of employment. Be advised COPC reserves the right to reassign one or both employees’ positions within the Company or require one or both employees to leave the Company.

1.13

Should a manager/subordinate relationship develop after employment begins, full disclosure of this information must be communicated to the employees’ Direct Supervisors or to a member of Human Resources. Should there be a situation in which the manager/subordinate relationship between relatives becomes inappropriate, unprofessional, or disruptive, the Company will try to find a suitable solution which may include moving one of the employees to another reporting relationship. If unable to accommodate the situation or find a suitable solution, one or both effected employees may be required to voluntarily terminate employment with COPC.

Violations of this policy may result in disciplinary action, up to and including termination of employment.

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

1.16

1.19

Break Time for Nursing Parents

Communicable Diseases COPC’s decisions involving persons who have or may be/have been exposed to communicable diseases shall be based on current and well- informed medical judgments concerning the disease, the risks of transmitting the illness to others, the symptoms and special circumstances of each individual who has a communicable disease, and a careful weighing of the identified risks and the available alternatives for responding to an employee with a communicable disease. Communicable diseases include, but are not limited to, measles, influenza, viral hepatitis-A (infectious hepatitis), viral hepatitis-B (serum hepatitis), human immunodeficiency virus (HIV infection), AIDS, AIDS-Related Complex (ARC), leprosy, Severe Acute Respiratory Syndrome (SARS), including SARS-CoV-2 (coronavirus), and tuberculosis. COPC may choose to broaden this definition within its best interest and in accordance with information received through the Centers for Disease Control and Prevention (CDC). Vaccine Recommendations According to the Centers for Disease Control (CDC), Healthcare workers (HCWs) (including physicians, nurses, emergency medical personnel, dental professionals and students, medical and nursing students, laboratory technicians, pharmacists, hospital volunteers, and administrative staff) are at risk for exposure to serious, and sometimes deadly disease. Individuals that work directly with patients or handle material that could spread infection should get appropriate vaccines Personal Property: Damaged, Lost, or Stolen Employees should use discretion when bringing personal property into the workplace. COPC assumes no risk for any loss or damage to personal

COPC will not discriminate against any job applicant or employee based on the individual having a communicable disease. Applicants and employees shall not be denied access to the workplace solely on the grounds that they have a communicable disease. COPC reserves the right to exclude a person with a communicable disease from the workplace facilities, programs, and functions if the organization finds that, based on a medical determination, such restriction is necessary for the welfare of the person who has the communicable disease and/or the welfare of others within the workplace. COPC will comply with all applicable statutes and regulations that protect the privacy of persons who have a communicable disease. Every effort will be made to ensure procedurally sufficient safeguards to maintain the personal confidentiality about persons who have communicable diseases.

COPC will accommodate employees who wish to express breast milk for the employee’s nursing child up to 1 year after the child’s birth during the workday by providing reasonable accommodations for break times to do so. The Company will provide a designated room, other than a bathroom, which is shielded from view, free of intrusions from coworkers and the public, and is compliant with all other applicable laws for this purpose. Employees should discuss their needs with their Direct Supervisor so that accommodations can be considered. Safety and Accident Rules - OSHA Safety is a priority at COPC. The Company strives to provide a clean, hazard-free, and safe environment in accordance with the Occupational Safety and Health Act of 1970 (OSHA). Our goal is to always provide a safe and healthy work environment for employees, patients, and visitors. Each employee is expected to obey safety rules, comply with safety policies, and to exercise caution and judgement in all work activities. Strict adherence to OSHA regulations and guidelines is expected through exercising caution and good judgement in all work activities. Employees are expected to take part in maintaining the environment by observing all posted safety rules, adhering to all safety instructions provided by Supervisors, and always using safety equipment when required. Every employee has the responsibility to learn the location of all safety and emergency equipment, as well as the location Health and First Aid Any medical condition considered to be beyond normal first aid, may require that 911 be called immediately. First aid supplies are available at each location. Our goal is to provide employees with the necessary information regarding appropriate techniques associated with administering medical assistance to others. COPC is concerned about employees who may be exposed to blood and other bodily fluids when administering first aid to other employees and patients. To safeguard employees when administering first aid, the following precautions should be used:

Employees who use regularly scheduled rest breaks to express breast milk will be paid for the break time. If the lactation break does not run concurrently with the employee’s regularly scheduled, compensated break period, the lactation break time may be unpaid. If an employee has any concerns regarding nursing accommodations or break times, they should speak with their Direct Supervisor and/or Human Resources immediately.

1.17

of safety and/or emergency phone numbers. Additionally, please note the following: ● Employees are required to immediately report any problems with COPC safety equipment to their Safety Health Officer (SHO), their Direct Supervisor, or to a member of the Human Resources Department. ● Employees who believe it is not safe to perform their job for any reason, must report the problem immediately to their Direct Supervisor or to a member of the Human Resources Department. ● Employees involved in an accident may be required to submit to a drug and/or alcohol test as soon as reasonably and/or medically possible, following the accident. ● All work-related accidents will be considered under Workers’ Compensation insurance. ● Only those employees who are certified to perform CPR may administer CPR. ● If an AED machine is available at the work location, only those trained on the machine may use it. ● Hands must be thoroughly washed before and following any first aid procedure. If an employee or patient is injured or requires medical attention while on the job or at COPC, management should be notified immediately and an incident report completed. Additionally, if medical attention is required a First Report of Injury form must be completed.

1.20

to reduce the chance that they will get or spread vaccine-preventable diseases. As a healthcare provider, COPC offers vaccination at no cost to employees for all CDC recommended vaccines. If you are not currently vaccinated for one of the above required or recommended vaccines and would like to receive your vaccination through COPC, please email HumanResources@COPCP.com to request vaccination.

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1.18

property. COPC also assumes no risk for personal vehicles parked in any of our lots or alternate work locations that may be damaged or stolen.

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

1.22

Solicitations, Distributions, and Posting of Materials COPC prohibits the solicitation, distribution, and posting of materials on Company property by any employee or non-employee, except as may be permitted by this policy. The exception to this policy is that of charitable and community activities supported by COPC management and Company-sponsored programs related to COPC announcements, events, and services. Provisions: ● COPC limits the distribution of literature of any kind during work times or in any work area at any time, except in connection with a Company- approved or sponsored event. ● Non-employees may not solicit employees or distribute literature of any kind on Company premises at any time. ● COPC limits employee solicitation between COPC employees to non-work time, except in connection with a Company-approved or sponsored event. This includes solicitations via email. ● The posting of materials or electronic announcements are permitted with approval from the CEO of COPC.

● Employees may not wear nor display in their workspaces (including alternate work locations) any materials that reference a political or social agenda or movement. ● Employees may only admit non-employees to work areas with management approval or as part of a Company-sponsored program. These visits must not disrupt patient care or workflow. An employee must always accompany the non-employee. Former employees are not permitted onto Company property except to conduct official Company business and with management approval. ● This policy is not intended to restrict employees’ rights to discuss or act together to improve wages, benefits, and working conditions with co-workers or in any way restrict employees’ rights under the National Labor Relations Act.

Violations of this policy may result in disciplinary action, up to and including termination of employment.

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

SECTION II

2.1

Hiring and Selection All job applicants are required to complete an application for employment and may be asked to provide a detailed resume of the applicant’s qualifications and work history. Applicants for any position with the Company will be evaluated based on qualifications, including, but not limited to, work experience, knowledge, skills, and behavioral attributes in relationship to the requirements of the

open position. Job related testing may be required as an additional tool to evaluate the qualifications and skills of candidates. The selected candidate will be provided a job offer conditioned upon the successful completion of a background check, drug/alcohol testing, and any other testing/checks the Company may require.

Hiring, Employment Classifications, Termination of Employment and Recordkeeping

2.2

Employment Classifications COPC complies with Ohio’s Minimum Fair Wage Act and the Fair Labor Standards Act in its classification of employees as exempt and non-exempt.

● Employees classified as “exempt” are exempt from federal and state overtime laws and, but for a few narrow exceptions, are generally paid a fixed amount of pay for each week in which work is performed.

● Employees classified as “non-exempt”* are entitled to overtime pay in accordance with federal and state overtime provisions.

A contingent employee is an employee who is hired for occasional work. A contingent employee is not guaranteed any number of hours and may be expected to work with limited notice. Contingent employees are not eligible to participate in benefit plans and are not eligible to receive holiday or paid time off benefits. Contingent employees must work a minimum of one shift per quarter to remain active. Certain departments/ sites may have additional requirements. If minimums are not met, contingent employees will be terminated and will need to complete the rehire process should they wish to return to work at COPC.

Full-time employees are regularly scheduled to work 30 hours or more per week on average. Regular, full-time employees are eligible for COPC benefits, subject to the terms, conditions, and limitations of each benefit program. Part-time employees are regularly scheduled to work less than 30 hours per week on average. Regular, part- time employees may or may not be eligible for some of the COPC benefits, subject to the terms, conditions, and limitations of each benefit program.

A temporary employee is an employee who is hired for a certain length of time which includes a start date and an end date to be communicated to the temporary employee at the time of hire. Temporary employees will be paid for the actual number of hours worked and are not eligible to participate in benefit plans nor receive holiday or paid time off benefits. *Employees classified as non-exempt may not work overtime without advance permission from their manager and may not access job-related emails or conduct other business outside of work hours without advance permission from management.

2.1 Hiring and Selection 2.2 Employment Classifications 2.3 Employment of Minors

2.4 Employee Data & Information Changes 2.5 Employee Personal Health Information 2.6 Termination of Employment-Voluntary & Involuntary 2.7 Outside Employment 2.8 Property Access Key Management 2.9 Business and Travel Expenses 2.10 Use of Personal Vehicle for Company Business

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

2.3

2.6

Termination of Employment-Voluntary and Involuntary Termination of employment for an employee, whether actively working or on inactive status, can occur for the following reasons:

Employment of Minors COPC does permit the employment of minors aged 16+ in certain positions within the Company as outlined below. To be eligible to work as a minor at COPC, the candidate must be aged 16 or 17, the relative/dependent of a provider or employee of COPC or connected with a trade or

technical school as part of training in the healthcare field (Clinical Assistant only). The minor is required to provide a work permit during any time school is in session and must complete an extended HIPAA training as part of their New Employee Orientation.

As an “at will” employee not subject to an employment contract, employees may choose to end their employment with COPC at any time and for any reason or for no reason at all. Employees are requested to submit a working notice of resignation in writing to their manager two (2) weeks (or as otherwise designated per position or contract) prior to the date they intend the resignation to take effect, to assist the Company in planning for the departure.

Employees are requested to submit notice of a planned retirement date in writing to their Direct Supervisor as far in advance of the effective date as possible. This will assist the Company in planning for the departure.

Termination of employment with or without cause: As an “at will” employee not subject to an employment contract, COPC may terminate employment at any time and for any reason not prohibited by law or for no reason at all, regardless of work performance, or compliance with the rules set forth in this handbook.

Working Title (full job descriptions attached) Clerical Support Clerical eCW Support Clinical Assistant (no injections)

Age Minimum

Access Level

16 16 17

No eCW Limited eCW Full eCW

A Minor Interest Form must be completed for identified candidates and submitted to HumanResources@COPCP.com.

2.4

Employee Data and Information All changes of home address, email address, phone number, marital status, number of dependents, emergency contact information, etc., should be updated using the Human Resources Information System (HRIS) or reported promptly to the employee’s Direct Supervisor or to Human Resources. Failure to disclose information (such as new or added dependents) in a timely manner could affect insurance coverage or COPC’s ability to contact the employee or family in the event of an emergency. Employee personnel records are maintained by the Human Resources department. Employees may request access to their personnel file by submitting a request via email to HumanResources@COPCP.com. Upon receipt of the written request, Human Resources

● Dishonesty ● Failing to work cooperatively with others or preventing others from performing their jobs ● Falsifying the application for employment ● Failure to notify the Company within 24 hours of intent to return to work and/or failure to report for work within three (3) working days once the Company has recalled the employee after a layoff ● Conviction of a felony offense and/or imprisonment ● Violation of established COPC policies ● Violation of policies and procedures set forth at the work location, not specified in this handbook Return of Property Regardless of the reason for separation of employment, employees are responsible to immediately return all COPC owned materials, written information, property, office keys, security badges, etc., to their site or the Human Resources department. Where permitted by law, COPC may withhold from the employee’s final pay the cost of any items that are not returned when required. COPC may also take all action deemed appropriate to recover or protect its property regardless of whether the termination is voluntary or involuntary. Exit Interview COPC will make every attempt to gather exit interview information from separated employees. The exit interview provides an opportunity to share information to help us make COPC a better place to work.

Involuntary Terminations: The following list is not meant to be all inclusive—there may be other reasons for involuntary terminations than those listed here: ● As a result of a reduction of the work force ● As a result of poor performance, behavior, or attendance ● Absence for three (3) or more consecutive days without notifying the Company of reasons for the absence ● Failure to report to work on the first workday following the expiration of an authorized leave of absence ● Giving a false reason for a leave of absence or seeking or engaging in other work during such a leave 2.6.1 Termination Process Paid Time Off (PTO) Any accrued, but unused PTO will be paid on the employee’s final paycheck in accordance with the normal pay periods. Exceptions to this include employees who leave the company prior to 90 days of employment and those who do not provide a two-week working notice prior to their voluntary termination. In these two cases, accrued but unused PTO will be forfeited. COBRA The COBRA administrator will be notified by Human Resources. The COBRA administrator will then notify employees of any potential COBRA benefits they are eligible for. Current medical, dental, and vision benefits will continue through the end of the month in which the employee’s last day occurs. All other benefits end on the last day of employment.

will schedule an appointment to view the file during normal office hours. Employees are not permitted to remove any documents from the personnel file but may provide a written response to any document in the file. Written responses will be attached to the original document in the file. Employees may also request copies of documents in their personnel file by contacting Human Resources via email. Release of requested documents, will be at the sole discretion of the Human Resources department and not all requests will be granted.

COPC managers and supervisors are responsible to ensure employee data and information reflects changes as they occur.

2.5

Employee Personal Health Information

situations deemed a Public Health Emergency, certain guidelines and restrictions may be temporarily lifted or changed, in accordance with the law.

COPC will maintain the privacy and confidentiality of an employee’s personal and health information to the extent possible. Only employees with a work-related need to know the information will have access to an employee’s personal record. In

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

2.7

2.9

Business & Travel Expenses COPC will compensate employees for approved, reasonable business and/or travel expenses incurred in the course of employment. Management must approve all business travel in advance. Mileage will be reimbursed at the current rate per mile for approved business travel in an employee- owned vehicle. The Mileage Reimbursement policy can be found here . Expense and Mileage reimbursement forms can be found on MyCOPC. Employees in positions classified as nonexempt under the Fair Labor Standards Act may be eligible Use of Personal Vehicle for Company Business Certain roles within COPC require employees to use their own personal vehicle to complete work for COPC during their scheduled work hours. Employee Driver Safety Rules: ● Driving for COPC under the influence of alcohol, and/or illegal drugs is forbidden and is sufficient cause for disciplinary action, up to and including termination of employment. No employee is permitted to drive for COPC business when their ability to do so safely has been impaired by any factor, such as illness, fatigue, injury, use of illegal or legal drugs/substances (including but not limited to prescription medications, over-the-counter medications, or marijuana). ● No employee is permitted to drive for COPC business when their ability to do so safely has been impaired by illness, fatigue, injury, or prescription medication. ● Employees driving on Company time must always respect the rights of other drivers and pedestrians.

Outside Employment Employees may hold outside employment if the employee meets the performance standards of their position with COPC and only if the outside employment does not compete with COPC business. Unless an alternative work schedule has been approved by COPC, employees will be subject to the Company’s scheduling

for compensation for the time they spend traveling. The compensation an employee receives depends on the kind of travel and whether the travel time takes place within normal work hours. Employees are responsible for accurately tracking, calculating, and reporting travel time on their timecard using COPC’s HRIS system in accordance with this policy. The full Travel Policy can be found here .

demands regardless of any existing outside work assignments. This includes availability for overtime when necessary. COPC property, office space, equipment, materials, trade secrets, and any other confidential information may not be used for any purposes relating to outside employment.

2.8

Property Access Key Management

Assignment of office keys, access badges, and security codes are based on an employee’s need to have access to specific facilities/equipment and will be issued depending on an employee’s job duties and work hours. COPC has established procedures that minimize the potential for problems to arise while maximizing the protection of Company employees, facilities, and equipment. ● Employees who are issued office keys, access badges, and security codes are responsible for their safekeeping. ● Employees may not share a Company office key, access badge, or security codes to another person without management approval and may never share with individuals outside of COPC.

● Keys are never to be copied or duplicated without the permission of management. Security codes are not to be shared with anyone inside or outside of the Company. ● Upon termination of employment, the employee will relinquish all office keys, access badges, and/or security codes in their possession. Failure to relinquish office keys, access badges, and/or security codes may result in deductions from an employee’s paycheck or other legal action.

2.10

● When driving, employees must adhere to all Ohio (and/or any other state laws, as applicable) Department of Transportation, federal, state, or local laws/rules regarding cell phone use. Employees who incur fines because of violating these laws/rules, will be solely responsible for such fines. ● When driving on Company time, employees may only use their cell phone if they are using a hands-free device or if they have pulled over to a safe area to complete the call. At the discretion of COPC, the Company may request that one or all these items are completed: ● (Motor Vehicle Reports) on an employee using their personal vehicle on behalf of the Company. ● Proof of the employee’s auto liability insurance with the appropriate limits in the state in which they operate and/or reside. ● Proof of the employee’s current and valid driver’s license.

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

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