Sun River Health Employee Handbook by SunRiverHealth

Resources & Guidelines For Employees

Approved and Effective June 21, 2022

TABLE OF CONTENTS SECTION 1 WELCOME AND SUN RIVER HEALTH ORGANIZATIONAL OVERVIEW ................................... 10 Welcome to Sun River Health ............................................................................................................................ 10 Mission Statement ............................................................................................................................................. 11 Who We Are ........................................................................................................................................................ 11 SECTION 2 EMPLOYMENT PRACTICES ......................................................................................... 12 Equal Employment Opportunity....................................................................................................................... 12 Americans with Disabilities Act ......................................................................................................................... 14 Reproductive Health Decisions ......................................................................................................................... 15 Employee Referrals............................................................................................................................................ 15 Job Requisitions and Postings .......................................................................................................................... 15 Employment Procedures................................................................................................................................... 16 Immigration Law Compliance ........................................................................................................................... 16 Certification and Licensure ............................................................................................................................... 16 Medical Exams and Vaccination Requirements ............................................................................................... 16 Pre-work .............................................................................................................................................. 16 Annual .................................................................................................................................................. 17 Introductory Period ........................................................................................................................................... 17 Job Transfers and Promotions ......................................................................................................................... 17 Performance Evaluations .................................................................................................................................. 18 Education and Training ..................................................................................................................................... 18 Outside Employment......................................................................................................................................... 19 Personal Relationships in the Workplace ......................................................................................................... 19 Separation from Employment........................................................................................................................... 20 Exit Interviews.................................................................................................................................................... 21 Return of Property ............................................................................................................................................. 21 SECTION 3 EMPLOYEE CONDUCT ................................................................................................ 22 Performance and Behavior Expectations ......................................................................................................... 22 Disciplinary Action ............................................................................................................................................. 23 Sexual and Other Harassment is Prohibited .................................................................................................... 24 Harassment Defined............................................................................................................................ 25 Investigations and Enforcement ........................................................................................................ 26 Policy Against Retaliation ................................................................................................................... 27 Additional Resources .......................................................................................................................... 28 Workplace Violence Policy ................................................................................................................................ 28 Workplace Violence Defined ............................................................................................................... 29 Weapons Prohibited in the Workplace ............................................................................................... 30 Complaint Procedure .......................................................................................................................... 30 Confidentiality ................................................................................................................................................... 30 HIPAA Compliance ............................................................................................................................................. 31 Attendance and Punctuality ............................................................................................................................. 32 Reporting Absences ............................................................................................................................ 33 Certification ......................................................................................................................................... 33 Voluntary Separation .......................................................................................................................... 33 Appearance ........................................................................................................................................................ 33 Substance-Free Workplace ............................................................................................................................... 35 Drug and Alcohol Testing .................................................................................................................... 36 Self-Reporting ..................................................................................................................................... 37 Electronic Resources and Applications ............................................................................................................ 37 Computer, E-Mail, Voice Mail, Internet, Texting, Conferencing, and other Social Media

applications ......................................................................................................................................... 37 No Expectation of Privacy ................................................................................................................... 38 Use Guidelines ..................................................................................................................................... 38 Cell Phones, Smart Phones, and Other Data Devices ...................................................................................... 39 Social Media ....................................................................................................................................................... 40 Application .......................................................................................................................................... 41 Social Media Guidelines ...................................................................................................................... 41 Addressing Concerns........................................................................................................................... 42 Accountability ..................................................................................................................................... 43 Solicitation and Bulletin Boards ....................................................................................................................... 43 Solicitation .......................................................................................................................................... 43 Bulletin Boards .................................................................................................................................... 43 Business Ethics .................................................................................................................................................. 44 False Claims Act ................................................................................................................................................. 44 Potential Liability .............................................................................................................................................. 45 Whistleblower Protections and Open Lines of Communication – (888) 692-6675 ........................... 46 Notice to Employees ........................................................................................................................... 46 Conflicts of Interest ........................................................................................................................................... 47 Procedures for Addressing the Conflict of Interest ............................................................................ 48 Gifts .................................................................................................................................................................... 48 Reporting Suspected Ethical and Legal Violations .......................................................................................... 49 Relationships with Patients............................................................................................................................... 49 Employees as Patients of Sun River Health ...................................................................................................... 49 Benefits ................................................................................................................................................ 50 Considerations as a patient ................................................................................................................. 50 Considerations as a Clinician ............................................................................................................... 50 Process Reminders .............................................................................................................................. 51 Relationships with the Public............................................................................................................................ 51 Dispute Resolution Procedure .......................................................................................................................... 52 SECTION 4 EMPLOYEE SUPPORT SERVICES ................................................................................ 53 SECTION 5 GENERAL INFORMATION ........................................................................................... 55 Employee Records ............................................................................................................................................. 56 Protection of Employee Information ................................................................................................................ 56 Sun River Health Physical Property .................................................................................................................. 56 Workplace Searches .......................................................................................................................................... 57 Employee Identification Badges, Access Cards and Keys ................................................................................ 57 Housekeeping .................................................................................................................................................... 58 Recycling ............................................................................................................................................................ 58 Intranet .............................................................................................................................................................. 58 Health, Safety and Security ............................................................................................................................... 58 Infectious/Communicable Disease Plan (IPC) .................................................................................................. 59 Injury Reporting ................................................................................................................................................. 60 Hazard Communication Information................................................................................................................ 60 Smoke-Free Workplace ..................................................................................................................................... 61 Fire Prevention and Protection ......................................................................................................................... 61 Emergency Evacuation ...................................................................................................................................... 61 Emergency Operations Guidelines – Inclement Weather, Power Failure and Other Circumstances ............... 61 Work Reporting and Pay Guidelines ................................................................................................... 62 Visitors................................................................................................................................................................ 62 Remote Working Arrangements (RWA) ............................................................................................................. 62 Definitions ........................................................................................................................................... 63

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Program Requirements....................................................................................................................... 63 Eligibility .............................................................................................................................................. 63 Schedules, Hours of Work, Pay, and Leave ........................................................................................ 63 Equipment and Supplies..................................................................................................................... 65 SECTION 6 COMPENSATIONAND PAY PRACTICES......................................................................... 66 Employment Classifications.............................................................................................................................. 66 Salary and Pay Status ......................................................................................................................... 66 Employment Status and Benefits Eligibility ...................................................................................... 66 Payroll Process .................................................................................................................................................. 67 Wage Disclosure Protection .............................................................................................................................. 67 Paycheck Deductions and Garnishments ......................................................................................................... 67 Overtime ............................................................................................................................................................ 68 Designated Holiday Work Pay ........................................................................................................................... 69 Work Schedules ................................................................................................................................................. 69 Time Records ..................................................................................................................................................... 69 Duty to Review Paycheck and Report Errors .................................................................................................... 70 Meal Periods....................................................................................................................................................... 70 Lactation Breaks ................................................................................................................................................ 70 Compensation Philosophy ................................................................................................................................ 71 Performance Pay Increases .............................................................................................................................. 71 On-Call Requirement ......................................................................................................................................... 72 Business Expense Reimbursement ................................................................................................................... 72 Use of Personal or Sun River Health Vehicles for Business ............................................................................. 72 SECTION 7 EMPLOYEE BENEFIT PROGRAMS................................................................................ 74 Benefits Overview .............................................................................................................................................. 74 Paid Time Off Benefit (PTO) .............................................................................................................................. 74 Eligibility .............................................................................................................................................. 75 Accrual ................................................................................................................................................. 75 Use of PTO ........................................................................................................................................... 75 Payment of PTO................................................................................................................................... 75 Designated Legal Holidays.................................................................................................................. 76 Maximum Accrual and Carryover ....................................................................................................... 76 Separation from Employment and Payout ........................................................................................ 76 Sick and Safe Time (SST) ................................................................................................................................... 77 Accrual ................................................................................................................................................. 77 Benefit Eligible Employees ................................................................................................................. 77 Non-Benefit Eligible Employees ......................................................................................................... 77 Use of SST ............................................................................................................................................ 78 Payment of SST ................................................................................................................................... 79 Carryover ............................................................................................................................................. 80 Separation from Employment ............................................................................................................ 80 Safe Time Leave (Westchester County Employees) ......................................................................................... 80 Voting Time Leave ............................................................................................................................................. 81 Jury Duty and Witness Duty Leave .................................................................................................................... 81 Crime Victim Leave ............................................................................................................................................ 81 Bereavement Leave ........................................................................................................................................... 82 Family and Medical Leave Act ........................................................................................................................... 82 Reasons for Taking Leave.................................................................................................................... 82 Notice and Certification ...................................................................................................................... 83 Failure to Provide Certification and to Return from Leave ............................................................... 84

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Guidelines for Taking Leave ................................................................................................................ 84 Compensation and Benefits During Leave ......................................................................................... 85 Health Care Benefits During Leave ..................................................................................................... 85 Job Reinstatement .............................................................................................................................. 86 Fraudulent Use of FMLA Prohibited.................................................................................................... 86 Additional Information Regarding FMLA ............................................................................................ 86 New York Paid Family Leave (PFL) .................................................................................................................... 86 Blood Donation Leave ....................................................................................................................................... 88 Bone Marrow Donation Leave ........................................................................................................................... 88 COVID-19 Vaccine Leave .................................................................................................................................... 89 Military Leave of Absence .................................................................................................................................. 89 Military Spouse Leave........................................................................................................................................ 89 Volunteer Emergency Responder Leave ........................................................................................................... 89 Personal Leave of Absence ................................................................................................................................ 90 Educational Leave of Absence .......................................................................................................................... 90 SECTION 8 EMPLOYEE BENEFIT PROGRAMS – HEALTHCARE BENEFITS ........................................... 92 Health Care Benefits Overview.......................................................................................................................... 92 Medical, Prescription and Dental Coverage ..................................................................................................... 92 Consolidated Omnibus Budget Reconciliation Act (COBRA) ........................................................................... 92 SECTION 9 INSURANCE AND DISABILITY INCOME PROTECTION ..................................................... 94 Short-Term Disability Income Protection (STD)............................................................................................... 94 Long-Term Disability Income Protection (LTD) ................................................................................................ 94 Life Insurance and Accidental Death and Dismemberment Insurance (AD&D) .............................................. 94 Workers’ Compensation Insurance................................................................................................................... 95 SECTION 10 RETIREMENT PROGRAMS ........................................................................................ 96 403(b) and 401(k) Retirement Plans ................................................................................................................. 96 Employer Contribution...................................................................................................................................... 96 Domestic Partner Coverage .............................................................................................................................. 96 Section 125 Plan ................................................................................................................................................ 97 Flexible Spending Accounts – Health Care and Dependent Care .................................................................... 97 Professional Liability Insurance ........................................................................................................................ 97 Employee Assistance Program – 1-800-252-4555............................................................................................. 98 Fitness Activity Reimbursement Program ........................................................................................................ 98 Eligibility .............................................................................................................................................. 99 Eligible program and activity expenses ............................................................................................. 99 Tuition Reimbursement Program ..................................................................................................................... 99 Eligibility .............................................................................................................................................. 99 Criteria to be Considered for Tuition Reimbursement ...................................................................... 99 Qualifying Course and Expense Criteria ........................................................................................... 100 Voluntary Benefits ........................................................................................................................................... 101 SECTION 11 EMPLOYEE SEXUAL AND OTHER HARASSMENT COMPLAINT FORM ...............................102

SECTION 1 WELCOME AND SUN RIVER HEALTH ORGANIZATIONAL OVERVIEW Our promise to patients: The care you need. The respect you deserve. Welcome to Sun River Health On behalf of all our employees at Sun River Health, we are pleased to welcome you to our organization! You are about to begin what we hope will be one of the most satisfying times in your career. Every employee is valued and essential to our success and excellent reputation. To create an optimal patient-oriented environment, we must work together as a team. Together, we achieve our goals through hard work, commitment, and team spirit. This Resource Guide provides general information about our culture and mission, employee benefits, and some of our operational guidelines. We invite you to learn about us and ask any questions you may have. This Resource Guide is a living document, which means that it will be reviewed and revised from time to time to reflect our evolving culture, philosophy, policies, and programs. Please contact your supervisor or Human Resources if you have any questions regarding this Resource Guide or any matter related to your employment at Sun River Health. Again, welcome to your new role at Sun River Health. You have our personal best wishes as, together, we face the numerous opportunities, challenges, and rewards ahead.

Anne Kaufman Nolon, MPH Chief Executive Officer Sun River Health

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Mission Statement “To increase access to comprehensive, primary and preventive health care and to improve the health status of our community, especially for the underserved and vulnerable.”

Who We Are Sun River Health is a network of 43 Federally Qualified Health Centers (FQHCs) providing primary, dental, pediatric, OB-GYN, and behavioral health care to over 245,000 patients annually. With a dedicated staff of 2,000 doctors, nurses, health care professionals, and administrative staff, we pride ourselves on delivering high-quality, affordable care to those who need it most. Sun River Health started in 1975 when four African American mothers spearheaded efforts to open our first health center in Peekskill, New York to deliver accessible, high-quality, affordable services to patients in need – regardless of race, gender, sexual identity, religion, income, or insurance status. Today, after more than 40 years of service, Sun River Health is still delivering on that promise to communities across the Hudson Valley, New York City, and Long Island. Some of our services include: • • • • • • • • • • • • •

Primary care / family medicine Dental Women’s health / OB-GYN Behavioral / mental health Pediatrics Podiatry / foot care Optometry / eye care Substance use treatment Adult day health care HIV care and prevention Women Infants and Children (WIC) program Nutrition services Urgent care

In addition, several of our larger sites offer midwifery care, infectious disease specialty care, gender affirming services, alcohol and substance use outpatient treatment, and child and family counseling. We provide many services through agreements with other healthcare providers including laboratory, radiology, pharmacy, and emergency services. Additional organizational information can be accessed at www.sunriver.org.

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SECTION 2 EMPLOYMENT PRACTICES Equal Employment Opportunity Sun River Health is an equal opportunity employer that complies with all applicable federal, state, and local laws governing nondiscrimination in employment, and is committed to equal employment opportunities for all qualified individuals, without regard to race, color, religion, creed, sex, gender, gender identity, sexual orientation, national origin, alienage, physical or mental disability, age, ancestry, marital status, genetic information or predisposition, genetic carrier status, protected military or veteran status, pregnancy, childbirth or pregnancy-related conditions, status as a victim of domestic violence or any other characteristic protected by federal, state or local law. This policy applies to all areas of employment, including recruitment, selection, compensation, leaves of absence, recall, layoff, placement, promotions, demotions, transfers, training, disciplinary action, termination and other privileges, terms and conditions of employment. Sun River Health will offer reasonable accommodations for the known physical or mental disabilities of a qualified individual with a disability who is an applicant or employee, unless doing so would result in an undue hardship. Sun River Health also provides reasonable accommodations to employees for pregnancy, childbirth, or a related medical condition, and for bona fide religious observance. Any applicant or employee who requires an accommodation to perform the essential functions of the job should contact Human Resources. Employees who feel they have been treated unfairly because of a protected characteristic, and/or who believe that a violation of the policy has occurred, should promptly report the conduct to Human Resources and/or their supervisor and/or a Chief/Vice President.

The Planetree Institute Since our earliest days, we at Sun River Health have grounded our work in a philosophy of person-centered care. Person-centered care empowers people to take charge of their own health, and so we work actively to ensure that our patients and those we serve are decision-makers in their own treatment planning and care. This same commitment applies to our staff, and so the concept of person-centered care is integrated into our employment practices as well, as you will see throughout this handbook. This person-centered care philosophy is also known as the Planetree model of care, named for its connection to Planetree International, an international organization supporting health care providers to incorporate a person-centered approach into all its

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systems. Sun River Health entered an affiliation with Planetree International in the early 1990s, as the first federally qualified health center to begin to embrace and uplift a person-centered care model. In 2019, Sun River Health re-launched our Planetree Institute. The Planetree Institute guides all person-centered care initiatives across the organization and supports departments and teams in centering patients’ voices. The Planetree Institute offers to all staff a variety of programming, in-person and virtual, that help to ground you in the philosophy of person-centered care. Through ongoing training opportunities, wellness events, book and movie discussions, and more, you will have many opportunities to deepen your understanding of patient-centered care during your employment with Sun River Health. In 2020, Sun River Health became the first and only federally qualified health center to be certified as Excellent in Person-Centered Care by Planetree International. Every three years, we undergo a re-certification process that includes on-site visits by the Planetree International team to several of our health center locations. Each member of our team reflects and embodies a person-centered care spirit in their own unique way, and we look forward to the many ways you will create these kinds of experiences for our patients, our communities, and each other. As part of your 90-day onboarding period, you will be invited to participate in a Planetree Retreat in your region. The Planetree Retreat is one of Sun River Health’s longest-running workshops that provides you with a grounding in the principles of Planetree and person-centered care, and how they can be applied to the patients and clients we serve as well as to each other as colleagues. This two-day workshop encourages you to connect with your personal ‘why’ story and our collective mission and vision for health care that empowers all.

Commitment to Diversity Our commitment to Justice, Equity, Diversity, and Inclusion (JEDI) is also underscored by the Planetree model of care and our philosophy of person-centered care for our staff, our patients, and the communities we serve. We know that for our patients to live their healthiest lives and to feel empowered to participate in their care decisions, these principles of JEDI must be centered. The same commitment holds true for our staff. As you join Sun River Health, we look forward to the authentic ways you will uphold the principles of JEDI and Planetree and welcome you to our organization.

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All staff are invited to share their pronouns as part of their email signature. During your orientation process, you will learn more about how to do so. We demonstrate our commitment to diversity in the following ways: For Our Employees 1. We recruit and hire a diverse workforce to reflect the communities we serve. 2. We leverage the unique capabilities and perspectives of individuals. 3. We respect our team members by listening and responding to their diverse needs. For Our Patients 1. We welcome all patients into our facilities. 2. We strive to make them comfortable when receiving care and services from us. 3. We respect our patients by listening and responding to their diverse needs. For Our Business 1. We retain a diverse workforce by ensuring that employees are rewarded for their contributions to the organization. 2. We provide services that reflect the diverse needs of the areas we serve. 3. We work with minority and women owned businesses to build and support our mission, vision, and values.

Americans with Disabilities Act Sun River Health is committed to providing equal employment opportunities to qualified individuals with disabilities. This may include providing reasonable accommodation where appropriate for a qualified individual to perform the essential functions of the job. Sun River Health may ask you for your input or the type of accommodation you believe may be necessary or the functional limitations caused by your disability. Also, when appropriate, we may need your permission to obtain additional information from your physician or other medical or rehabilitation professionals. Sun River Health will not seek genetic information in connection with requests for accommodation. All medical information received by Sun River Health in connection with a request for accommodation will be treated as confidential. When an employee requests a reasonable accommodation, Sun River Health shall explore with the employee the possible means of providing the reasonable accommodation, which may include, but are not limited to: • • •

Acquisition of equipment for sitting Modified computer equipment More frequent or longer breaks

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• • • • • •

Periodic rest Modifying work hours/schedules Job restructuring Break time and private non-bathroom space for expressing breast milk Modified work schedules Longer time off to recover from childbirth

Reproductive Health Decisions Sun River Health respects and supports the reproductive health decisions of individual employees. In accordance with law and policy, Sun River Health will not discriminate nor take any retaliatory personnel action against an employee with respect to any terms and conditions of employment because of or based on the employee’s or dependent’s reproductive health decisions, including, but not limited to, a decision to use or access a particular drug, device, or medical service. No employee will be required to sign a waiver or other document which purports to deny an employee the right to make their own reproductive health decisions, including use of a particular drug, device, or medical service. Sun River Health will not access an employee’s personal information regarding the employee’s or a dependent’s reproductive health decision making, including but not limited to, the decision to use or access a particular drug, device, or medical service without the employee’s prior informed affirmative written consent. Employees may also choose to pursue legal remedies with the courts. An individual may be entitled to certain legal remedies, which can include monetary damages and injunctive relief.

Employee Referrals Through its Employee Referral program, Sun River Health encourages employees to identify qualified individuals who are interested in employment opportunities with Sun River Health and to refer them for open positions. An employee should obtain permission from the individual before making a referral and should not make any commitments or promises, verbal or written, regarding employment with Sun River Health. Employees may submit the referral’s resume and/or completed application form to Human Resources for review and consideration. If a candidate referred for employment is subsequently hired, the referring employee may be eligible for a financial payment.

Job Requisitions and Postings Most job openings will be posted on the Sun River Health website and externally advertised. All job posting requests must be approved by Human Resources before posting. While we strive to hire qualified internal applicants, Sun River Health reserves the right to hire externally and to fill certain positions without prior posting.

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Employment Procedures In accordance with applicable laws, all employment offers are contingent upon successful completion of any required background checks including, but not limited to, education, professional reference, criminal, driving records, and/or professional credentials verification. Sun River Health will ensure that all background checks are conducted in compliance with all applicable federal, state, and local law statutes. Negative information disclosed because of a background check will not necessarily exclude an individual from employment. All background investigation information and test results will be treated as confidential information. Human Resources will confirm the initial offer of employment in writing upon receipt of these results.

Immigration Law Compliance All offers of employment by Sun River Health are contingent on verification of an employee’s right to work in the United States. Each employee will be asked to provide original documents verifying right to work and as required by federal law, to complete Form I-9 - Employment Eligibility Verification. The organization will use the federal EVerify program to complete the background verification. An employee must present the appropriate documents within three (3) business days of the date that employment begins. If at any time an employee cannot verify their right to work in the United States, Sun River Health is obligated to terminate such employee’s employment.

Certification and Licensure If state, Department of Transportation, or industry regulations require an employee to possess current licensure or certification credentials, the employee is required to provide valid and current proof of such documents to Human Resources. If your professional credentialing and/or license is not current and valid, you may not be permitted to continue to work in the position for which the credentials and/or license is required and therefore, will be suspended from duty without pay, terminated, or reassigned as appropriate.

Medical Exams and Vaccination Requirements Pre-work A pre-work physical examination is required for all new hires. This will include confirmation of various vaccinations including, but not limited to Hepatitis B, Influenza (flu), MMR (Measles, Mumps and Rubella), Varicella (Chickenpox), Tuberculosis (TB), COVID-19, and other requirements as determined by the New York State Department of Health and Sun River Health policy. These pre-work physical exams and

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testing/vaccinations will be provided at several of the Sun River Health centers at no expense to the applicant or the applicant may choose to have one performed by their own physician at their own expense. Employment is contingent upon satisfactory completion of the physical exam. If any accommodations are requested or needed to perform the essential functions of a position they will be reviewed in conjunction with an interactive dialogue with the candidate. Consideration for reasonable accommodation will be made in accordance with applicable law. Annual All employees are required to complete and submit to Employee Health an Annual Health Assessment questionnaire and attestation. Additional health screenings may be required based on your responses and personal health history. All personal medical information will be kept confidential. Annual flu vaccination shots are strongly recommended and provided by Sun River Health at no cost to you or you can receive one at a provider of your choice at your own expense and provide documentation to Employee Health. Anyone choosing not to receive the flu vaccination will be required to always wear a mask while in a work location.

Introductory Period As a new employee of Sun River Health your Introductory Period will be for a period of ninety (90) calendar days. The Introductory Period is designed to provide you with orientation and training for your position’s responsibilities. It is also an evaluation period to assess such attributes as aptitude, interest, and ability to satisfactorily perform the requirements of the position, as well as to follow our policies and procedures. The Introductory Period may be extended if necessary, for additional training or evaluation. It is expected that a performance evaluation will be conducted by your manager at the conclusion of your Introductory Period. Nothing in this policy shall be read or interpreted to alter the at-will relationship of employees. Your employment may be terminated at any time during or after the Introductory Period, with or without cause and with or without notice.

Job Transfers and Promotions Sun River Health encourages career development and advancement of our employees by providing opportunities for transfers and promotions. You may apply for a posted position if you have been in your current position for at least six (6) months and have a satisfactory performance record. Employees must meet all the required education and experience requirements of the position before being considered. The “Request for

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Transfer” application form can be accessed from the Human Resources tab of the organization’s Intranet. Employees applying for an internal transfer are required to notify their current manager of their intention to apply for another internal position. Current managers do not need to approve the request to transfer but are expected to be aware and provide input on the suitability of the employee for the new position. All approved internal transfers will occur no sooner than 2 weeks and no longer than six (6) weeks from the date of the transfer approval by Human Resources unless an alternative timeframe is mutually agreed to by the current and hiring managers and approved by Human Resources. Sun River Health endeavors to hire the most qualified individual for available positions. While Sun River Health prefers to fill its open positions from within, it maintains its right to advertise positions externally, to solicit outside candidates during or after the posting period, and to hire external candidates after its consideration of both internal and external applicants. Internal candidates will be considered based on their qualifications and performance, and current departmental staffing and operational needs.

Performance Evaluations Sun River Health is committed to a participatory performance evaluation process with an exchange of performance related information between you and your supervisor. Employees should receive feedback from their supervisor on a periodic basis including at the conclusion of their Introductory Period (first ninety days of employment). Employees will also typically receive annual performance evaluations. Performance evaluations may be conducted at the time of job promotion or transfer to a new position. The purpose of these formal performance evaluations is to identify and discuss the following: • • • • •

Your current job responsibilities Areas of strong performance Improvement suggestions Ongoing objectives and strategies for achieving optimal job performance standards Training and development needs and plans

Education and Training Sun River Health offers ongoing training and educational opportunities for our employees so that you have the latest information regarding new research and practices in our industry. In line with this commitment, your supervisor may coordinate training opportunities for you periodically, so that you may upgrade your knowledge and skills. Sun River Health

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may also provide special training programs for safety when deemed necessary, or as required by government regulation. Certain training programs are mandatory and as such must be completed within the timeframe established by the supervisor. You are also encouraged to further your training and development through formal programs of study that will help develop your capabilities and may enhance your potential for career advancement. You may be eligible for Tuition Reimbursement from Sun River Health or other government and organizations. If the taking of a course result in a conflict with your work schedule, prior management approval must be obtained before enrolling in the course.

Outside Employment Sun River Health recognizes that employees may spend non-working time away from the job as they wish. However, activities away from the job should not compromise Sun River Health interests or constitute a conflict of interest. In addition, activities during nonworking time should not adversely affect the employee’s job performance or responsibilities with Sun River Health. Employees should not engage in employment outside the organization that may result in a conflict of interest with Sun River Health operations or business. Outside employment that conflicts with your work schedule, impairs the performance of your duties and responsibilities, or violates your confidentiality obligations or Sun River Health’s intellectual property rights is also prohibited. Employees also may not use any Sun River Health resources in connection with outside employment. Any employee who chooses to pursue outside employment which may lead to a conflict of interest or interference with Sun River Health operations or business, whether paid or unpaid, must inform and obtain prior written approval from Human Resources, prior to beginning outside employment so Sun River Health can ensure there is no actual or potential conflict of interest.

Personal Relationships in the Workplace Sun River Health permits members of the same family and those involved in personal relationships to work at the organization. However, in some circumstances, the employment of relatives and those involved in personal relationships can cause disruption and may conflict with the best interests of Sun River Health. This is especially true when the employees work in the same department as another, directly or indirectly supervise the other, or when one has access to the confidential information of another. Employees may not directly or indirectly supervise a relative. Supervisors may not date or engage in a romantic personal relationship with employees who report directly or indirectly in any situation. When an employee marries another employee or a personal relationship has developed between manager and an employee who directly or indirectly reports to that manager, both employees are responsible for disclosing the existence of the relationship to Human Resources. A determination will be made regarding whether

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the relationship conflicts with the best interests of Sun River Health. If it is determined that such a conflict or relationship exists and it cannot be satisfactorily resolved through reassignment, then one of the employees must resign. If neither employee voluntarily resigns, the organization will terminate the employment of one of the employees. Relatives of, and those involved in a personal relationship with, a present employee may not be hired without the full knowledge and written approval of Human Resources. For the purposes of this policy, relatives are spouse, sibling, parent, child, grandparent, grandchild, uncle, aunt, nephew, niece, first cousin, or step/in-law relations. Other members of your household or other relatives may be included depending upon the individual circumstances.

Separation from Employment It is our sincere wish that you will enjoy a successful career with Sun River Health. Since employment is at-will and based on mutual consent, you and Sun River Health have the right to terminate employment at will, with or without cause at any time, with or without notice. If you decide to leave Sun River Health, you are requested to give as much advance notice, in writing, as possible, but not less than the notice period designated below. This notice should indicate your last day of work and will allow us the ability to adjust working schedules and identify a replacement if necessary. To receive payment for your accrued and unused PTO balance following resignation, you must provide and work satisfactorily through the following notice periods: •

•

Providers/Clinicians (including physicians, nurse practitioners, physician assistants, psychiatrists, psychologists, social workers, dentists, dental hygienists – 90 days’ notice Management and Professionals (All management positions including Coordinators and Supervisor through Vice President; and professional positions including RNs, LPNs, Nutritionists) – 4 weeks’ notice All Other staff not included in the first two categories – 3 weeks’ notice

Employees may not take PTO (unless previously approved) or SST during the notice period. Any employee who is out ill may be requested to extend their notice period by the number of days is out ill. Final paychecks for time worked will be paid via direct deposit in accordance with the regular paycheck schedule. PTO balance payments will be paid via direct deposit with the pay date following your last regular pay for time worked. Please remember your obligations regarding the safekeeping of Sun River Health and patient confidential and proprietary information once you leave Sun River Health. Separated employees are required to maintain the confidentiality of patient information and proprietary organizational information on-going. In addition, employees must

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immediately terminate use of organizational telephone, voicemail, computer systems and email upon separation of employment from the organization.

Exit Interviews Sun River Health will generally conduct exit interviews for those employees who leave the organization, and we appreciate your participation in this process. All terminating employees should meet with a representative of Human Resources or their supervisor so that any pertinent benefits information can be explained, or outstanding issues resolved, including life and health insurance continuation and conversion privileges, retirement plan, the return of Sun River Health property, and your entitlements to final pay. This discussion also provides you an opportunity to discuss your employment experience and provide insight and suggestions for the improvement of the organization for the benefit of remaining staff and patients.

Return of Property All Sun River Health property, including identification cards and keys, Sun River Health information, credit cards, pagers, protective equipment, security passes, tools, vehicles, and computer equipment, must be returned on or before your last day worked. Failure to return equipment promptly and in satisfactory operating condition as requested may result in a deduction from your PTO balance to cover the cost of the non-returned or damaged equipment.

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SECTION 3 EMPLOYEE CONDUCT Performance and Behavior Expectations Every employee, contractor, agent, consultant, volunteer, and other individual who acts on Sun River Health’s behalf is responsible for ensuring that their conduct is consistent with this Resource Guide, with Sun River Health’s policies and procedures, and with generally accepted standards of professionalism. Sun River Health employees, especially those in a supervisory role, are responsible for ensuring that employee conduct complies with this Resource Guide. While not an exhaustive list, the types of behavior and conduct that are unacceptable include, but are not limited to, the following: • •

•

• •

• • • • • •

Failure to support, promote or act in accordance with the Mission of Sun River Health and the Planetree principles Behavior or failure to report behavior that results in injury to or complaints from patients regarding an employee’s conduct or demeanor towards the patient or a patient’s representative or visitors Theft, destruction, misuse or damage to Sun River Health property, vehicles, equipment, or supplies, or of the property of another employee, patient, or visitor, including unauthorized removal or possession of organization property Leaving or abandoning work duties or work location without proper authorization and/or good reason Falsification of any Sun River Health document, including for example, employment applications, time and attendance records, patient related documents and reports of any kind Working under the influence of, and/or ability impaired by, alcohol or illegal drugs. Possession, distribution, sale, transfer, or use of alcohol or illegal drugs in the workplace, while on duty, while on Sun River Health premises or while operating vehicles or equipment Bullying, fighting, threatening, or engaging in actual physical violence or verbal abuse toward a fellow employee, patient, or visitor Violation of safety, security, or health rules, or engaging in conduct that creates a safety, security, or health hazard Smoking including vaping (use of e-cigarettes) in prohibited areas Sexual or other unwelcome harassment, and/or discrimination Possession of dangerous or unauthorized materials such as explosives, firearms, or other weapons in the workplace Unauthorized use of telephones, mail system, email, internet, or other employerowned equipment or property

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•

• • • • • • • • •

Unauthorized possession, use, copying, accessing, or reading of Sun River Health’s confidential information and records, or disclosure of information contained in such records to unauthorized persons Violation of Human Resource or organization policies or procedures Unsatisfactory work performance or conduct Excessive absenteeism and/or lateness; failure to call to report an absence from work, or late arrival to work Insubordination, including refusal to carry out or unreasonable delay in carrying out instructions given by your supervisor Use of foul or abusive language verbally, in writing or on clothing Making false, fraudulent, or malicious statements about a patient or another employee Illegal conduct on Sun River Health premises or while on Sun River Health business Retaliating or threatening retaliation against employees who exercise rights protected by law or by Sun River Health policy Failure to cooperate in an organizational investigation

Behaviors or conduct such as those listed above may lead to disciplinary action, up to and including termination of employment. Other types of behaviors or conduct other than those indicated above may also be subject to disciplinary action, up to and including termination of employment. Employment with the organization is at-will and the employee or Sun River Health may terminate that relationship at any time, with or without cause and with or without notice, for any or no reason.

Disciplinary Action Sun River Health’s approach to disciplinary action focuses on solving problems and encouraging changes in workplace behavior that are consistent with our culture, philosophy, and mission. We have specific work standards and job expectations. When your job performance and/or behavior are inconsistent with our guidelines, we have a progressive discipline process in place to address the problems. Disciplinary action may take any of the following forms, and in any order: verbal warning, written warning, final warning, and suspension with or without pay, or termination of employment. We will review the specifics of the situation as well as any previous disciplinary history, to determine the appropriate action. Sun River Health reserves the right to proceed directly to any disciplinary action, including termination of employment, without initiating prior disciplinary steps. Nothing in this policy shall be read or interpreted to alter the at-will relationship of employees. Your employment may be terminated at any time, with or without cause and with or without notice.

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•

A verbal counseling may be used to discuss performance or behavior issues, and to clarify organization work standards and job expectations. The discussion may be documented and kept in the employee’s Human Resources file A written warning may occur when the performance or behavior issues are more significant than would be handled with a verbal counseling, or if a prior verbal counseling has not had the desired effect on the employee’s performance or behavior. The written warning formalizes the counseling discussion, identifying specific problems or deficiencies, and outlining a corrective action plan, outcomes, and time limits. Written warnings are kept in the employee Human Resource files A suspension with or without pay, and final warning, may occur when the performance or behavior issues are more significant than would be handled with a written warning or if a prior written warning has not had the desired effect on the employee’s performance or behavior. Immediate improvement is required or additional disciplinary action up to and including termination of employment may occur. Documentation regarding suspensions will be kept in the employee Human Resource files Termination of employment may occur for serious violations of organization policies or guidelines and/or applicable laws or regulations, or for continued poor performance or behavior. Documentation regarding the termination will be kept in employee Human Resource files

Sexual and Other Harassment is Prohibited Sun River Health is committed to a work environment in which all individuals are treated with respect and dignity. Each employee has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits unlawful discriminatory practices, including harassment. Therefore, Sun River Health expects that all relationships among persons in the workplace will be professional and free of bias, prejudice, and harassment. Sun River Health provides and requires completion of annual training on this topic. It is the policy of Sun River Health to ensure equal employment opportunity without discrimination or harassment based on all protected characteristics under the law, including but not limited to race, color, religion, gender, sexual orientation, gender identity, national origin, age, disability, genetic information, marital status, and status as a covered veteran. Sun River Health is committed to maintaining a workplace free of harassment, and to taking action to end such behavior if it occurs. Employees are responsible for respecting the rights of Sun River Health’s employees, volunteers, students, patients, and family members by refraining from harassing conduct and for promptly reporting actual or potential violations of this policy.

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Harassment Defined Harassment based on any characteristic or status protected by law is strictly prohibited. Under this policy, harassment includes speech (either verbal or written) or conduct that denigrates or shows hostility or aversion toward an individual or group of people on the basis of race, color, religion, gender, sexual orientation, gender identity, national origin, age, disability, military or veteran status, marital status, citizenship status, genetic information or status as a member of any group protected by law, and that has the purpose or effect of creating an intimidating, hostile or offensive work environment; has the purpose or effect of unreasonably interfering with an individual’s work performance; or otherwise adversely affects an individual’s employment opportunities. Harassing conduct includes using epithets, slurs or negative stereotyping; engaging in threatening, intimidating or hostile acts; telling denigrating jokes; and sharing written or graphic material that denigrates or shows hostility or aversion toward an individual or group on walls or elsewhere on Sun River Health’s premises or circulated in the workplace, on the Sun River Health’s time or using Sun River Health’s equipment via email, phone (including voice messages), text messages (or SMS), tweets, blogs, social networking sites or other means. Sexual harassment constitutes discrimination and is illegal under federal, state, and local laws. For the purposes of this policy, sexual harassment includes unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature under any of the following conditions: when submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment; when submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; or when such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment. No supervisor or other employee shall threaten or suggest, either directly or by implication, that another employee’s or applicant’s refusal to submit to sexual advances will adversely affect that person’s employment, work status, evaluation, wages, advancement, assigned duties, work shifts, or any other condition of employment or career development. Similarly, no employee shall promise, imply, or grant any preferential treatment for another employee or applicant for engaging in sexual conduct. Neither submission to, nor rejection of, sexual advances will affect an employee’s terms or conditions of employment. Sexual harassment may include a range of subtle and not-so-subtle behaviors and may involve individuals of the same or different gender. Depending on the circumstances, these behaviors may include, but are not limited to: •

Unwanted sexual advances or requests for sexual favors

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• • • • • • • • • • •

Sexual or derogatory jokes, comments, or innuendo Unwelcomed physical interaction Insulting or obscene comments or gestures Offensive email, voicemail, or text messages Suggestive or sexually explicit posters, calendars, photographs, graffiti, or cartoons Making or threatening reprisals after a negative response to sexual advances Visual conduct that includes leering, making sexual gestures, or displaying of sexually suggestive objects or pictures, cartoons, or posters Verbal sexual advances or propositions Physical conduct that includes touching, assaulting, or impeding or blocking movements Abusive or malicious conduct that a reasonable person would find hostile, offensive, and unrelated to the organization’s legitimate business interests Any other visual, verbal, or physical conduct or behavior deemed inappropriate by Sun River Health

Sun River Health will not permit any employee, regardless of gender/gender identity, to sexually harass another employee in any way. Sun River Health will not tolerate such activity from anyone, including all levels of employees (supervisors and non-supervisors alike), applicants for employment, interns (whether paid or unpaid), volunteers, contractors, vendors, and visitors. Actions will be taken against individuals engaging in sexual harassment, as well as against supervisory and management employees who knowingly allow such behavior to continue, up to and including termination of the employment or contracting relationship. The prohibition against sexual harassment applies equally regardless of whether the harasser and the victim are of the same or different gender/gender identity. Investigations and Enforcement Sun River Health encourages the prompt reporting of complaints or concerns. Early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment. Any employee, volunteer, student, or thirdparty providing services in the workplace who believes that they have been subject to any prohibited forms of retaliation or harassment, including sexual harassment, or who witnesses or otherwise becomes aware of others being subjected to such conduct, is expected to promptly (ideally, within 24 hours) report the incident(s) to Human Resources, the employee’s immediate supervisor or any Chief/Vice President or on the designated Complaint Form. In accordance with applicable law, a complaint form is provided with this policy; however, employees are not required to use that form to bring a matter to the Sun River Health’s attention. Rather, an employee may lodge a complaint verbally as described above or in

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writing, in any manner sufficient to provide notice to Sun River Health of the employee’s concerns. Additionally, Sun River Health encourages individuals who believe they are being subjected to such conduct to promptly advise the offender that their behavior is unwelcome and request that it be discontinued. Often, this action alone will resolve the problem. Supervisors and managers who receive a complaint of, or otherwise learn of, information that suggests this policy may have been violated are required to promptly (ideally, within 24 hours) forward that complaint to Human Resources. After receiving notification of a complaint, Sun River Health will promptly and thoroughly investigate the complaint by interviewing employees with information relevant to the complaint. Sun River Health will keep complaints confidential to the extent possible while still fulfilling its obligation to investigate and end any harassing conduct. Employees must cooperate and provide truthful and complete information in an investigation. To maintain workplace safety and the integrity of its investigation, Sun River Health may suspend employees, either with or without pay, pending the outcome of the investigation. If Sun River Health determines that an employee’s conduct has violated this policy, it will take steps to ensure the conduct is effectively addressed. Violations of this policy will be considered a form of employee misconduct, and any employee found to have harassed another individual in violation of this policy will be subject to appropriate disciplinary action, up to and including termination of employment. Any supervisor or manager who knowingly allows harassment to continue will likewise be subject to appropriate disciplinary action, up to and including termination of employment. Employees who make bad-faith false complaints of harassment, discrimination or retaliation may be subjected to appropriate disciplinary action, up to and including termination. Policy Against Retaliation Retaliation against an individual for reporting harassment or discrimination, or for testifying or assisting in any investigation or proceeding related to a claim of harassment or discrimination, is a serious violation of Sun River Health’s policy and, like harassment or discrimination itself, will be subject to disciplinary action up to and including termination. Prohibited retaliation includes any adverse employment action, including but not limited to discharge, discipline, or demotion, motivated by the employee’s lodging of a good-faith complaint, participation in the investigation of such a complaint, or opposition to incidents of workplace harassment. Acts of retaliation should be reported immediately and will be promptly investigated and addressed.

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Please note that an adverse employment action is not retaliatory merely because it occurs after an employee reports harassment or assists in an investigation. An adverse employment action is not retaliatory unless it was motivated by the employee’s report of harassment or participation in an investigation. After having reported harassment or assisted in an investigation, employees continue to be subject to the Sun River Health’s workplace policies, procedures, and expectations. Employees who report harassment or assist in an investigation will not be immune from corrective action motivated by legitimate factors unrelated to retaliation. Additional Resources While these policies are intended to curb inappropriate behavior before it constitutes a violation of applicable law, harassment, discrimination, and retaliation prohibited by this policy may also violate federal, state, and/or local law. All employees have a legal right to a workplace free from unlawful harassment, including sexual harassment. In addition to the internal complaint process described in this policy, employees may also choose to pursue legal remedies with federal, state and/or local agencies, as well as to seek relief in the courts. An individual may be entitled to certain legal remedies, which can include monetary damages and/or injunctive relief, in connection with a legal or administrative action to adjudicate a claim of sexual harassment. Among other agencies, the Federal Equal Employment Opportunity Commission, the New York State Division of Human Rights, and the New York City Commission on Human Rights, investigate and prosecute complaints of prohibited harassment, discrimination, and retaliation in employment. If you think you have been harassed or discriminated against, or that you have been retaliated against for complaining or participating in an investigation, you may file a complaint with the appropriate agency. The location of the nearest office and other information can be found by visiting the agency websites, including https://www.eeoc.gov/; https://dhr.ny.gov/; and https://www1.nyc.gov/site/cchr/index.page

Workplace Violence Policy The safety and security of employees is of vital importance to Sun River Health. Threats or acts of violence, including intimidation, harassment, and/or coercion, that involve or affect Sun River Health employees, or which occur on Sun River Health’s premises, will not be tolerated. The prohibition against threats and acts of violence applies to all persons involved in the operation of Sun River Health including, but not limited to, employees and other personnel, contract and temporary workers, consultants, contractors, patients, vendors, visitors, and anyone else on Sun River Health’s premises.

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Workplace Violence Defined Workplace violence is any conduct that is sufficiently severe, offensive, or intimidating to cause an employee to reasonably fear for his or her personal safety or the safety of his or her family, friends, associates, and/or property such that employment conditions are altered or a hostile, abusive, or intimidating work environment is created. Examples of workplace violence include, but are not limited to, the following: •

•

Threats or acts of violence or physical force occurring on Sun River Health’s premises, regardless of the relationship between Sun River Health and the parties involved in the incident Threats or acts of violence or physical force occurring off Sun River Health’s premises involving someone who is acting in the capacity of a representative of Sun River Health Threats or acts of violence or physical force occurring off Sun River Health’s premises involving an employee of Sun River Health as a victim if Sun River Health determines that the incident may lead to an incident of violence on Sun River Health’s premises Threats or acts of violence resulting in the conviction of an employee or agent of Sun River Health, or of an individual performing services for Sun River Health on a contract or temporary basis, under any criminal code provisions relating to violence or threats of violence which adversely affect the business interests of Sun River Health

Specific examples of conduct that may be considered threats or acts of violence under this policy include, but are not limited to, the following: •

•

• • • •

Any act of physical, verbal, or emotional abuse, force, violence, or intimidation, including, but not limited to, hitting, shoving, or other such aggressive conduct, directed toward another individual or his or her family, friends, associates, or property Any actual or veiled threat of physical, verbal, or emotional abuse, force, violence, intimidation, or other aggressive conduct, directed toward another individual or his or her family, friends, associates, or property Any pattern of coercive behavior that involves any act or threat of abuse, force, violence, intimidation, or other aggressive conduct Any act of physical, verbal, or emotional abuse that one person uses to control or intimidate another or others Harassing or threatening communications (including, without limitation, phone calls, e-mails, text messages, and the like) Bullying, harassing, or threatening behavior, including, without limitation, physical aggression, and verbal threats, that causes another person to fear for his or her personal safety or the safety of his or her family, friends, associates, and/or property

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• • • • • •

Surveillance or stalking Fighting Possession of, and/or advocating illegal use of, guns, firearms, bombs, or weapons Threats or attempts to commit suicide Intentional destruction or threats of destruction of Sun River Health property Enlisting, coercing, or asking others to do any of the above, and/or aiding others in doing any of the above

Weapons Prohibited in the Workplace Sun River Health strictly prohibits employees or any person providing services to or visiting Sun River Health or located on Sun River Health premises from possessing weapons of any kind at the workplace. The workplace includes any property owned or leased by Sun River Health or occupied by groups of Sun River Health employees or persons providing services to Sun River Health. Unless such prohibition is contrary to local law, this specifically includes parking areas and Sun River Health vehicles. This policy prohibits the possession of concealed weapons as well as weapons carried openly. Complaint Procedure Any employee who sees, hears, or learns of any conduct or statement that seems threatening or suspicious, any conduct that violates this policy, and/or any weapons on Sun River Health’s premises, must immediately report such conduct or statement to his or her supervisor or to Human Resources. If there is an immediate risk or imminent threat of violence, serious harm, or life-threatening conduct, the employee should report this immediately to 911, local police, or law enforcement. If an employee is experiencing domestic problems or abuse - or knows of co-workers who are experiencing domestic problems or abuse – the employee is strongly encouraged to report these matters as well, so Sun River Health can help, if possible. Similarly, if an employee obtains a restraining or protective order against another person, or an employee is the subject of a restraining or protective order, the employee must immediately report this to Human Resources. Sun River Health will immediately investigate any complaints of actual, threatened, or suspected violence, and will take appropriate action. Sun River Health will not tolerate any retaliation against anyone who, in good faith, reports any of the above types of matters or who cooperates in the investigation of such report.

Confidentiality By virtue of their affiliation with Sun River Health or by virtue of attending a Board or Committee meeting, employees and staff may have access to confidential or proprietary information of Sun River Health and its affiliates, which may not be readily available to competitors or the public, and which if disclosed would likely cause significant harm to

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Sun River Health or its affiliates (“Confidential Information”). Confidential and proprietary information includes, but is not limited to: Sun River Health’s business plan or strategies, trade secrets, patient lists, patient health data, risk management, quality improvement, personnel and payroll information learned in the course of one’s job duties, pricing, computer codes, methods of doing business, the identity and whereabouts of Sun River Health’s projects and prospects, vendor agreements, medical records, pricing plans, material lists, accounting and financial documents, personnel files, computer files, and such information of any of Sun River Health’s subsidiaries, affiliates or agents, which, if disclosed to competitors, could be used in a manner that would be damaging to Sun River Health. All information communicated at management sessions or other closed sessions of the Board of Directors is also Confidential Information. In addition, the Board of Directors or CEO may determine that other information, including information shared in Board of Directors’ meetings and committee meetings, is confidential or proprietary on a case-by-case basis. Confidential Information may not be disclosed outside Sun River Health without appropriate written authorization from the Board (for Board members and other individuals who may be authorized to be present at Board meetings) or from the CEO (for employees); or used for personal gain or for the benefit of a third party. Employees may only disclose confidential business information within Sun River Health for legitimate business purposes required in the performance of their jobs and as expressly authorized. Employees are expected to exercise reasonable care to avoid the inadvertent disclosure of confidential information. Employees are bound by and required to comply with the confidentiality provisions contained in agreements executed between Sun River Health and other organizations. Employees and Board members shall be required to maintain the confidentiality of Confidential Information consistent with this Confidentiality Policy indefinitely after their term of Board membership, employment, contract, or other affiliation with Sun River Health ends. All staff and employees, including consultants, shall be required to sign a Confidentiality Agreement, or in such other form as the Health Center Board may adopt, whereby such individual expressly agrees to comply with confidentiality policies and agreements.

HIPAA Compliance As required under the Health Insurance Portability and Accountability Act of 1996 (known as HIPAA), any information about Sun River Health patients that is requested by an outside person for unauthorized purposes will not be released, except by court order, to anyone other than the patient or legal guardian or the executor or administrator of a deceased patient unless Sun River Health has prior written consent. All such requests must be handled in accordance with Sun River Health’s approved policies and

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procedures. Any employee or contractor found to have violated this policy shall immediately be barred from any further contractual relationship and additional action may be taken with their employer as determined by law. Be aware that there are both civil and criminal penalties associated with violation of HIPAA. All employees/contractors will ensure all reasonable efforts to maintain the confidentiality of information that is provided to them or to which they have access; this includes, but is not limited to: • • • • •

Ensuring passwords to access the electronic records of patients are protected and not shared with any other individuals Access to electronic records is actively terminated by logging out at the end of the session Records that are printed or copied are kept in protected areas to ensure that unauthorized viewing is not permitted Records are appropriately shredded Access to information for contractors is governed and detailed by the Business Associate agreement between Sun River Health and the corporate entity

Sun River Health complies with the applicable provisions of HIPAA, which provides participants in the medical plan with certain rights related to Continuity of Coverage, Special Enrollment Rights, and Privacy Rights. We have designated the Director of Corporate Compliance as the organization’s “Privacy Officer.” Employees who have any questions regarding HIPAA or their compliance obligations should immediately speak with their supervisor.

Attendance and Punctuality To maintain a productive work environment, Sun River Health expects employees to be reliable and to be punctual in reporting for scheduled work. Based on your scheduled work hours, you are expected to begin your work assignments at the start of your scheduled time and remain actively involved with work responsibilities through the end of your scheduled time, except for meal and rest breaks. Employees are expected to be ready for work and log in to e-time at the beginning of their shift. Any start time outside of this window must be pre-approved by your supervisor. Scheduled time not worked may be charged to the appropriate time-off bank or non-exempt employees will not be compensated for time missed. Employees are not permitted to take time off without pay if they have available PTO or SST except where such leave is required by law or permitted by policy. In addition, Sun River Health reserves the right to require employees to use accrued PTO or SST to ensure that minimum FTE hours are met.

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Reporting Absences Some departments may have specific timeframes and processes for reporting an absence. In general, if you are unexpectedly unable to work as scheduled, you must contact your supervisor at least one (1) hour prior to your scheduled starting time or, in extenuating circumstances, as soon as possible. It is anticipated that you will make this call yourself unless you are involved in an emergency or cannot physically make the call. You must speak directly to your supervisor. If you cannot reach them personally, you may leave a voicemail for them, but then you must also try to reach another supervisor or designee to speak to someone directly. Please provide your reason for being late or absent, and when you expect to return so that appropriate coverage can be coordinated. During any absence of more than one day it is expected that you will keep in touch with your supervisor regarding your estimated return to work. If it is estimated that you will not be able to return to work for at least three (3) or more consecutive days, please discuss with your supervisor or Human Resources whether a leave of absence is necessary. Certification After more than three (3) unscheduled, consecutive days absent, you may be required to provide a physician’s certification establishing that you were ill or injured and advising of your ability to return to work. However, you may be required to provide substantiation of absence of less than three (3) days when there is any question regarding the validity of the reason provided for the need for leave. Upon your return, should any work restrictions be recommended by your physician, the certification should document the nature and period of the limitations. The Return-to-Work Certification template is available on the HR tab of Sun River Health’s intranet. Voluntary Separation Employees with an unscheduled absence of three (3) or more consecutive workdays who fail to contact their supervisor will be considered to have abandoned their job and resigned without notice, and their employment will be terminated immediately.

Appearance Appearance, grooming, and personal hygiene are important as they have a direct impact on patients, clients, families, and community members’ impressions of Sun River Health. Employees are expected to report to work well groomed, neat, clean, and dressed according to the requirements of their position. An employee’s dress is an important aspect to self-expression. Sun River Health promotes a dress code policy that is inclusive of the various communities that make up its workforce. Sun River Health supports employees wearing their natural hair texture or styling with protective hairstyles (including braids, locks, and twists) and does not

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prohibit the wearing of attire, clothing, or facial hair in accordance with the requirements of an employee’s religion. Sun River Health encourages employees to present themselves through their dress in a manner that is in accordance with their gender identity and gender expression. Cultural norms around male and female dress are not required of any staff member; each employee is encouraged to dress in such a way that most authentically expresses their gender identity. The safety and health of employees and patients is of critical importance. Any attire that has the potential to jeopardize the safety or health of any employee or person associated with Sun River Health will not be permitted. This includes daggling jewelry, slippery, open-toe or unsupportive shoes, excessively long fingernails and other items that may at the sole discretion of Sun River Health may create a health or safety concern. Some departments may have dress code guidelines in accordance with the specific role (i.e., community engagement, clinical staff, and leadership). Employees should consult with their supervisor for further guidance on acceptable work attire. The following is a list of examples (although not all-inclusive), of clothing and attire that is not permitted: o Jewelry or piercings that restrict movement or could create a safety issue o Tattoos that are visibly obscene or offensive and any facial tattoos o Skin-tight, revealing, sheer, or provocative clothing o Ripped, torn, or frayed clothing o Jeans o Mesh tops, shirts or dresses that expose underclothes and/or body parts o T-shirts with any images other than the Sun River Health logo o Shorts or miniskirts o Sweat tops and/or bottoms o Leggings unless accompanied by a top that covers both hips and thighs (at end of hand on side) o Tank tops, spaghetti straps, halter tops (unless continuously covered by a sweater or jacket) o Low cut dresses, shirts and/or tops that expose the abdominal or chest area o Slippers, flip flops, open-toe shoes and other footwear that is slippery or unsupportive o Baseball caps During work hours, or when representing Sun River Health, we expect that employees will promote an inclusive and welcoming atmosphere by presenting an appearance conducive to Sun River Health’s patient-centered environment and healthcare services. Employees who are not properly dressed may be asked to leave work so that they may

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resolve the issue. In such circumstances, non-exempt employees will not be entitled to compensation for this time away from work. Employees who need an exception to grooming and dress requirements because of a disability or for sincerely held religious beliefs, should contact Human Resources. Sun River Health will provide accommodations in accordance with applicable law.

Substance-Free Workplace Substances such as drugs and alcohol can create serious risks of physical harm and safety to our employees and patients, and at times the public. Sun River Health is committed to ensuring a substance-abuse-free working environment for all its employees. Violation of this policy will subject employees to disciplinary action up to and including termination of employment. All employees are prohibited from using, consuming, possessing, distributing, purchasing, selling, attempting to sell, dispensing. or cultivating alcohol, illicit drugs, or other intoxicants at any time in any amount while on the job, on Sun River Health property, and while operating Sun River Health equipment or vehicles. “Illicit drugs” includes all drugs, narcotics, and intoxicants for which possession or misuse is illegal under federal law as well as prescription medication for which the individual does not have a valid prescription. The deliberate use of prescription medications and/or over-thecounter drugs in a manner inconsistent with dosing directions, and/or in a manner which may result in impairment, is considered illicit drug use. In addition, the use of chemical intoxicants for other than a legitimate and therapeutic purpose is considered illicit drug use. All employees are also prohibited from reporting to work under the influence of illicit drugs. Employees are also prohibited from reporting to work while under the influence of any substance, whether legal or illegal, that adversely affect the employee’s job performance including his/her ability to safely perform assigned duties or poses a risk to Sun River Health property. If an employee is taking medication that may impair his or her ability to safely perform the employee’s job duties, the employee must advise his or her supervisor. The employee does not need to disclose the type of medication taken or any medical condition. Sun River Health will provide reasonable accommodations for lawful drug use in accordance with applicable law. Should employees be arrested or charged in connection with any drug-related activity, on or off the job, employees you must notify your supervisor or Human Resources by the next regular workday. The matter will be reviewed, taking into consideration several areas such as the severity of the charges, present job assignments, your work record, and the impact of the arrest on Sun River Health.

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Sun River Health may occasionally authorize alcoholic beverages at approved functions. In those situations, employees who are of legal age may consume a modest amount of alcohol, provided that an employee’s conduct and demeanor remain appropriate and professional and provided that the employee does not thereafter drive or otherwise engage in any activity which is illegal or hazardous, or to professionally represent Sun River Health. Drug and Alcohol Testing Conditional Offer: Applicants extended a conditional offer of employment may be required to take and pass a drug test before beginning work. A refusal to submit to a drug test or a positive confirmed drug test will result in a withdrawal of the offer of employment. Reasonable Suspicion: Employees may be required to submit to drug/alcohol screening whenever Sun River Health has a reasonable suspicion that they are under the influence of drugs or alcohol while working. Reasonable suspicion may arise from, among other factors, supervisory observation, coworker reports or complaints, results of drug searches or other detection methods, employee’s appearance or an odor of drugs or alcohol. Post-Accident: Employees whose acts appear to have caused or contributed to a serious accident may be required to submit to post-accident testing as part of the investigation. Random. Employees in safety sensitive positions may be tested on an unannounced random basis. Employees will be selected for random testing by a computerized random number program matched to employee ID numbers. Consent: No alcohol test will be administered, sample collected, or drug test conducted on any sample without the written consent of the person being tested. However, a person’s refusal to submit to a proper test will be viewed as insubordination and will subject the person to disciplinary action, up to and including termination. Collection, Chain-of-Custody, Testing Methods: Employees asked to take a reasonable suspicion drug and/or alcohol test will be transported to the collection site for testing and then transported home pending receipt of test results. Employees will be placed on administrative leave without pay pending the results of the test. If the test results are negative, the employee will be compensated for any wages lost due to the leave, unless a suspension without pay is justified under another policy. All drug tests will be performed by a laboratory certified by the U.S. Department of Health and Human Services to perform federal workplace testing. Breath and/or saliva tests may be used to detect the presence of alcohol. An alcohol test will be considered positive if it shows the presence of .02 percent or more alcohol in an individual’s system.

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Notification: Any individual who tests positive for drugs will be contacted by a Medical Review Officer (“MRO”) (a health care professional with an expertise in toxicology) before the result is reported and given an opportunity to provide any legitimate reasons they may have that would explain the positive drug test. If the individual provides an explanation acceptable to the MRO that the positive drug-test result is due to factors other than the consumption of illegal drugs, the MRO will order the positive test result to be disregarded and will report the test as negative to Sun River Health. Otherwise, the MRO will verify the test as positive and report the result. An individual who tests positive for drugs may request, within three days of being notified of the positive result, that his or her sample be sent to an independent certified laboratory for a second confirmatory test, at his or her own expense, although we may suspend, transfer, or take other appropriate action against such employee pending the results of any such re-test. Confidentiality: All records relating to positive test results, drug and alcohol treatment, and employee medical information shall be kept confidential, and disseminated to and within Sun River Health only on a need-to-know basis. Such records will be kept in secure files separate from personnel files. Test results will not be released outside Sun River Health without the written consent of the tested individual, or as otherwise may be required by law or legal process. Self-Reporting Sun River Health strongly encourages employees who believe they have a problem with alcohol or drugs – legal or illegal – to seek assistance before a violation of this policy is found. For those employees who self-identify a substance-abuse problem to Sun River Health, sources of help may be provided, including referral to EAP and/or scheduling and leave accommodations to assist the employee in obtaining assistance. Individuals who seek help voluntarily will not be subject to discipline on that basis, but employees should understand that substance abuse concerns will not excuse or protect employees from the consequences of poor performance or policy violations. Employees who may have concerns about substance abuse therefore are encouraged to seek assistance promptly.

Electronic Resources and Applications Computer, E-Mail, Voice Mail, Internet, Texting, Conferencing, and other Social Media applications Some employees may have access to desktops computers, laptop computers, servers, computer networks, email systems, software, handheld computers, printers, cellular phones, smartphones, wireless routers, data storage, computer accounts, telephone services, voicemail, or other electronic software and hardware that is owned, leased, used, maintained, moderated, or otherwise operated by Sun River Health (collectively

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referred to as “Electronic Systems”). In addition, some employees may have access to the Internet to assist the employee in performing their job duties. Electronic Systems, and all communications and information transmitted by, received, or stored on Electronic Systems are the property of Sun River Health. Although Sun River Health’s Electronic Systems are provided primarily for business purposes, employees may use them for occasional, personal, non-business purposes, such as short, personal calls/text messaging and connection to the Internet, during non-working time. Non-business use may not involve excessive use of bandwidth (e.g., transmitting excessively large files like pictures, audio and video files, or other attachments that may disrupt server performance) or otherwise interfere with the efficient functioning of Sun River Health’s systems. In addition, employees’ non-business use should not interfere with the business activities of employees who are on working time. No Expectation of Privacy There is no expectation of privacy in any message, file, data, document, facsimile, or any other kind or form of information transmitted to, received from, or stored on Electronic Systems. The use of, creation, or change of any password, code, or any method of encryption, or the capacity to delete or purge files or messages, whether authorized by Sun River Health, similarly does not give an employee any expectation of privacy in any message, file, data, document, communication, facsimile, or other kind or form of information. Any file, data, document, facsimile, or any other kind or form of information transmitted to, received from, or stored on any Electronic Systems is considered the property of Sun River Health. Authorized representatives of the organization may periodically monitor equipment utilization and investigate suspected or improper use of systems. They may also access/disclose current or archived private electronic employee messages or files at any time at the organization’s discretion. This may be done to protect system security, fulfill Sun River Health obligations, detect any transgressions, comply with the legal process while protecting organization rights and property or for any other lawful reason. Sun River Health complies with applicable state and federal laws regarding privacy protection and employee rights. Employees should have no expectation of privacy when using Sun River Health’s Electronic Systems. Use Guidelines Employees must not display, transmit or store any illegal, unethical, or pornographic images or messages using Electronic Systems. Any display, transmission or storage of sexually explicit images, messages, or cartoons, ethnic or racial slurs or epithets, or any other material that might be construed as harassing or disparaging of others on the grounds of race, national origin, sex, age, religion, disability, sexual orientation, gender/gender identity or any other characteristic protected by applicable law is strictly prohibited.

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Employees must contact the IT department regarding the need to install any software programs. Downloading of internet material has both legal and practical implications. Electronic Systems provide access to material protected by copyright, trademark, patent, trade secrets and/or export law. Employees may not assume, merely because information is available on an electronic information system to which Sun River Health has access, that it may be downloaded or further disseminated. It is the responsibility of each employee to ensure that any use of any material from Electronic Systems will not violate any trademark, copyright license or other intellectual property right of a third party or any applicable law. If an employee is unsure as to whether the downloading or use of such material violates the rights of any third party or any applicable law, the employee should not download or use such material until receiving approval from his/her line manager. Use of unlicensed programs or copying of licensed programs or other copyrighted material is strictly prohibited as well as downloading of non-work-related material, such as games and screensaver programs. Use of Electronic Systems must be achieved only by using your authorized login and/or password identification(s). No person should attempt to gain access to another person’s electronic mail, voicemail, or computer files unless expressly authorized to do so by the person whose file is being accessed, or by an authorized representative of Sun River Health. To maintain the security of Electronic Systems, employees may not disclose system passwords to any other person besides an authorized representative. Doing so could result in a security breach. All files should be checked using a current virus protection program and should be properly saved and backed up. Employees must comply with all HIPAA regulations regarding the safeguarding of patient information. This includes using secure and encrypted communications when transmitting PHI externally. Dissemination of PHI, Sun River Health intellectual property, and sensitive/classified data is monitored and prohibited unless authorized. Employees are responsible for practicing due diligence when reviewing emails that could be phishing attacks. Employees must immediately terminate use of Sun River Health telephone, voicemail, computer systems and email upon separation of employment from the organization. All equipment and information must be returned to your supervisor on or before your last day of employment. Not returning Sun River issued equipment could lead to the withholding of all, or a portion, of any PTO balance pay out upon separation.

Cell Phones, Smart Phones, and Other Data Devices Employees should exercise the same discretion in using personal cell phones and smart phones as they do with Sun River Health phones. Ring tones should be turned off and personal calls should be made during lunch and break times. Cell phones and smart phones (including texting and web browsing) should not be used while on duty or in and

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around patients. Due to significant patient and employee privacy concerns, camera, and video functions are not allowed to be used where confidential information may be located. Sun River Health will comply with applicable laws regarding the protection of privacy and employee rights. For safety and liability reasons, you may not use a cell phone or smart phone for Sun River Health business while driving a vehicle. You must pull over to the side of the road and park before using a cell phone or smart phone for business purposes or you must utilize a hands-free device.

Social Media As in other areas, social media is a way that employees have the privilege of representing Sun River Health to the world. On LinkedIn, as well as other platforms, many refer to and promote their place of employment as a regular aspect of their lives and identities. We strongly encourage and endorse this practice, as we see employees as our foremost ambassadors to the public. Social media, as an increasingly pervasive set of platforms for people of all ages and backgrounds, is an important and growing part of this representation. Sun River Health owns and operates multiple social media platforms. Staff are welcomed and encouraged to follow and connect with these ongoing. Because work is only one part of life, Sun River Health recognizes that there is crossover on social media platforms to non-work areas. Sun River Health respects the legal rights of its employees and understands that their time outside of work is their own. However, employees who engage in social media activity should be mindful that their social media activity, even if done off premises and while off-duty, could affect Sun River Health’s brand, and legitimate business interests. This information should guide the discretion of staff in social media use. Please also see Social Media Guidelines, below. We encourage staff to be positive and responsible citizens in the digital realm as in all others: as ambassadors of the organization, as stewards and advocates of the public health, and as champions of the patients and communities we serve. Some readers may mistakenly view an employee as a de facto spokesperson for Sun River Health. Consequently, social media activity is a legitimate and proper focus of policy for Sun River Health. It is important that we protect the privacy interests of our patients. For example, the information posted could be Sun River Health’s confidential business information, place Sun River Health or its patients in an unfavorable position or reveal information about a patient from which reveals their identity. Social media activity includes all types of postings on the Internet, including but not limited to, postings on social networking sites (such as Facebook, Instagram, TikTok,

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Snapchat, LinkedIn, and Tumblr); blogs and other on-line journals and diaries; bulletin boards and chat rooms; microblogging, such as Twitter; and postings of video or audio on media-sharing sites, such as YouTube or Flickr. Social media activity also includes permitting, or failing to remove, posts by others where the employee can control the content of posts, such as on a personal page or blog. This Social Media Policy provides guidance on responsible social media activity by employees. This Policy does not and cannot cover every possible social media activity. For this reason, Sun River Health relies on the common sense and good judgment of its employees to ensure that social media activity is undertaken responsibly. Employees with questions regarding this Policy should seek guidance from Human Resources. Application This policy applies to all employees and to social media activity that relates in any way to Sun River Health’s business, employees, patients, or vendors, or that identifies an employee’s affiliation with Sun River Health (other than as an incidental mention of place of employment in personal social media activity unrelated to Sun River Health). It applies to social media activity when on or off duty, while using Sun River Health’s Electronic Systems or employees’ personal electronic resources, and whether employees post anonymously or using a pseudonym. Unless specifically authorized, employees are prohibited from using Sun River Health’s Electronic Systems to engage in social media activity or from otherwise engaging in social media activity during working hours. However, since many staff members do in fact engage in social media use on behalf of Sun River Health during business hours, these authorizations are regularly provided. If you are aware of a particular opportunity for the organization on social media, you are encouraged to contact the Communications Department directly. Social Media Guidelines Sun River Health values its established reputation and good will relationships. These are important corporate assets. When employees engage in social media activity that identifies the employee as an employee of Sun River Health, or in any way relates to Sun River Health, employees should bear that in mind and follow the guidelines listed below: • •

Social media activity is subject to all the policies in Sun River Health’s Resource Guide Unless an employee has received prior authorization from the Communications Department, employees are not authorized to speak on Sun River Health’s behalf and should not represent or suggest in any social media activity that they are authorized to speak on Sun River Health’s behalf, or that Sun River Health has reviewed or approved the content. If that is not obvious from content or context of a post, the employee should specifically state, “The views expressed in this post are my own. They have not been reviewed or approved by Sun River Health.” This

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•

• •

•

is a common practice utilized by organizations throughout the world, including non-profit organizations Employees should use available privacy filters or settings to block any inappropriate, unprofessional, or overly personal information about you from coworkers, patients, or vendors who may have access to your social media activity Employees may not use Sun River Health’s logo, trademark, or proprietary graphics without prior approval from our Communications Department Due to patient privacy, employees cannot take photographs or videos of patients without their consent and authorized by Sun River Health Communications Department Employees cannot photograph or video Sun River Health’s confidential or proprietary information (please refer to the confidentiality policy contained in this Resource Guide for more information) To reduce the risk of identity theft, stalking, and similar criminal conduct, employees should not disclose personally identifying information (such as telephone numbers, Social Security numbers, credit or debit card numbers or financial account numbers) of Sun River Health’s employees, patients, or vendors. Employees also should not post images or video of Sun River Health’s employees, patients, or vendors without their prior permission

The following guidelines also apply to your social media activity: •

•

Any employee may reject, without fear of retaliation, any request from any other employee that, if accepted, would permit access to a restricted social media page — such as a friend or connection request Employees may not use their Sun River Health e-mail address to register for any social media account or site, or as an identifier needed to participate in any social media activity, except to engage in social media activity authorized by Sun River Health and for Sun River Health’s business purposes Employees should use only approved social media channels — and not personal social media sites or pages — to conduct Sun River Health’s business. Without prior approval from Sun River Health, social media should not be used to arrange business meetings, communicate with patients, or to search for information about current or prospective employees All requests for references or recommendations received through social media activity must be handled in accordance with Sun River Health’s policy on responding to these requests

Addressing Concerns You are more likely to resolve concerns about work by speaking directly with your coworkers, manager, or other management-level personnel than by posting them on the Internet. You should consider using available internal resources, rather than social media activity, to resolve these types of concerns. If you decide to express concerns in social

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media, avoid using any content that reasonably could be viewed as malicious, obscene, threatening or intimidating; that includes recklessly or knowingly false statements about employees, patients, or vendors; or that might constitute harassment or bullying. Accountability Sun River Health will, in its discretion, review social media activity to the fullest extent permitted by applicable law. If you engage in social media activity anonymously or using a pseudonym, Sun River Health will, in appropriate circumstances, take steps to determine your identity. Employees will be held accountable for engaging in social media activity that violates this Policy. Failure to comply with this Policy may lead to discipline, up to and including termination of employment, and if appropriate, Sun River Health will pursue all available legal remedies. Sun River Health also may report suspected unlawful conduct to appropriate law enforcement authorities. Sun River Health will not construe or apply this Policy in a manner that improperly prevents employees from communicating with each other about wages, hours or other terms and conditions of employment.

Solicitation and Bulletin Boards Solicitation Employees are prohibited from soliciting or promoting support for any cause or organization during his or her working time or during the working time of the employee or employees at whom such activity is directed, except for causes and/or organizations that align with the Sun River Health mission as determined by Human Resources or the Philanthropy Department. Employees may not distribute or circulate any written or printed material in work areas at any time, or during his or her working time or during the working time of the employee or employees at whom such activity is directed. Off-duty employees are not permitted in work areas. Under no circumstances will non-employees be permitted to solicit or to distribute written material for any purpose on Sun River Health property. As used in this policy, “working time” includes all time for which an employee is paid and/or is scheduled to be performing services for Sun River Health; it does not include breaks, meals, or time during which an employee is not performing and is not scheduled to be performing services or work for Sun River Health. This policy applies equally to use of Sun River Health’s electronic equipment. Bulletin Boards Important Sun River Health information and notices and items of general interest are continually posted on the bulletin board located in the break room or lunchroom.

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Employees should review it often as its content changes from time to time. Only approved Sun River Health postings are permitted on the board.

Business Ethics Sun River Health is dedicated to respecting and obeying all applicable laws, including the laws of the cities and states in which we operate. All employees are expected to follow the letter and spirit of applicable laws, rules, and regulations; conduct business ethically and honestly; and remain sensitive to Sun River Health’s patients being served. Any illegal, dishonest, or unethical actions or conduct of employees will not be tolerated. Employees are also prohibited from conducting Sun River Health business with any person or organization connected with illegal or unethical activities. To comply with these ethical considerations, you are encouraged to make every effort to demonstrate honesty, integrity, and fairness in the performance of your duties by: •

Reporting practices or conditions that may violate any law, rule, regulation, safety standard, Sun River Health policy, or the Code of Business Conduct to the appropriate levels of management • Providing information required by federal, state, and/or local government agencies in a timely, accurate manner, according to applicable laws, rules, and regulations • Providing government agencies or other authorized investigative bodies with oral or written statements that are truthful and factual • Never using Sun River Health’s resources, facilities, or supplies for personal business, without written permission from senior management • Never accepting inducements or favors from vendors or prospective vendors that may influence Sun River Health or its clients to use a particular product or service • Forgoing any business opportunity that requires unethical or illegal activity, even if the opportunity or circumstances may appear to be an “acceptable” industry practice • Avoiding agreements or other actions that may unfairly restrain trade or reduce competition

False Claims Act It is the policy of Sun River Health that all personnel (including employees, management, physicians, consultants, contractors, and other agents) shall comply with all applicable laws governing false claims, including the Federal False Claims Act, the Program Fraud Civil Remedies Act, and New York State’s False Claims Act. Sun River Health and applicable law prohibits all personnel from “knowingly”:

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• • • •

•

Presenting a false or fraudulent claim for payment or approval to any government entity or health care program, including Medicare or Medicaid Making, using, or causing to be made a false record or statement to get a false or fraudulent claim paid or approved by a government entity or health care program Repaying less than what is owed to a government entity Deliberate concealment of any material fact or other fraudulent scheme or device to attempt to obtain, or to obtain, payments for services or supplies furnished under the New York State Medical Assistance Program Conspiring to defraud the government through one of the actions listed above

For purposes of this policy and pursuant to applicable law, “knowingly” means the individual: has actual knowledge of the information; acts in deliberate ignorance of the truth or falsity of the information; or acts in reckless disregard of the truth or falsity of the information. Under this policy and applicable law, a specific intent to defraud is not required to prove that the law has been violated. Examples of a false claim include, but are not limited to: • •

• • •

Submitting a claim for a service that was not provided or documented Upcoding (assigning a service code that results in charging a higher reimbursement amount than appropriate) or under/down coding (assigning a service code that results in charging a lower reimbursement than appropriate) Billing under the wrong provider number Billing multiple payers for the same service Making a false record or statement to cause a claim to be paid or approved

Potential Liability A person or entity found guilty of violating Federal False Claims Act is obligated to repay all the falsely obtained reimbursement and will be liable for a civil penalty of $11,181 to $22,363, plus three times the amount of actual damages sustained by the government because of the prohibited conduct for each violation of the Act and the cost of prosecution. In addition to being liable for damages and civil penalties, violating the Federal False Claims Act can subject a person or entity to exclusion from participation in Federal health care programs, such as Medicare and Medicaid. New York State also imposes criminal prosecution for violations of New York State’s False Claims Act’s laws and regulations. Such person may be guilty of a Class A misdemeanor unless that act constitutes a violation of a provision of the Penal Law. It is also a crime, under the New York State Penal Law, to commit “health care fraud.” Such occurs, when, with intent to defraud a private or public health plan (including, e.g., Medicaid or an HMO), a person or entity knowingly and willfully provides materially false information or omits material information for the purpose of receiving payment for health care items or services that the person or entity is not otherwise entitled to receive. The severity of the

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penalty for committing this crime corresponds to the amount of payment wrongfully received from a single health plan in a one-year period. Any employee found to be in violation of this policy or applicable law will be subject to disciplinary action up to and including immediate termination of employment as well as possible legal action. Whistleblower Protections and Open Lines of Communication – (888) 692-6675 The Federal False Claim Act and New York State’s False Claims Act prohibits employers from retaliating against employees, management, physicians, consultants, contractors, and other agents who file or participate in the prosecution of a whistleblower suit. Individuals who are discharged, demoted, suspended, threatened, harassed or in any way discriminated against in the terms and conditions of employment by their employer for reporting violations of the applicable law are entitled to recover all relief necessary to make the individual whole. Employees, management, physicians, consultants, contractors, and other agents are expected to report any known or suspected violations of these acts to their supervisors, the Chief Compliance Officer, or the Corporate Ethics Hotline. Sun River Health’s Compliance Officer may be contacted to answer any compliance-related questions or receive reports of any compliance-related concerns. Sun River Health also maintains a “hotline” which is available for reporting any compliance concerns. Reports can be made anonymously. The number for the hotline is 1(888) 692-6675 or 1(888)-MY-COMPLY. Sun River Health will immediately investigate, and if appropriate, delay the submission of claims when any compliance issues (e.g., improper coding) are brought to its attention internally (from auditing or from registered complaints by internal staff) or externally (from state and/or federal agencies). Sun River Health will cooperate fully with state and/or federal agencies investigating any potential compliance concern. Sun River Health provides training and orientation to all employees on appropriate coding procedures. Staff are expected to comply with the procedures provided in training. Notice to Employees The New York Whistleblower Law prohibits employers from retaliating against employees, former employees, and independent contractors for disclosing or threatening to disclose, to a supervisor or public body, any conduct that they reasonably believe violates any law, rule or regulation, executive order, or any judicial or administrative decision, ruling, or order; or that they reasonably believe constitutes a substantial and specific danger to the public health or safety.

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If you believe that SRH is engaging in any conduct that constitutes a violation of any law, rule or regulation, executive order, or any judicial or administrative decision, ruling, or order, or a substantial and specific danger to the public health or safety, please bring it to the immediate attention of your supervisor or Human Resources.

Conflicts of Interest Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. A conflict of interest arises whenever the interests of a person compete with or has the potential to compete with the best interests of Sun River Health. A conflict is presumed to exist if a person with an interest can control or influence the transaction or arrangement in which they have such interest. Sun River Health is a Department of Health and Human Services (“DHHS”) grantee and is also required to comply with applicable DHHS regulations regarding conflicts of interest. Pursuant to DHHS regulations, no employee, officer, or agent shall participate in the Health Center’s selection, award or administration of any contract or grant, sponsored or paid in whole or in part with Federal funds, if a real or apparent conflict of interest would be involved. Such a conflict would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization that employs or is about to employ any of the parties indicated herein, has a financial or other interest in the firm selected for an award. The officers, employees, and agents of the recipient shall neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to sub-agreements. Employees are expected to devote their best efforts and attention to the performance of their jobs. Employees are also expected to use good judgment, to adhere to high ethical standards, and to avoid situations that create an actual or potential conflict between the employee’s personal interests and the interests of the Sun River Health. Employees must refrain from taking part in, or exerting influence over, any transactions in which their own interests may conflict with the best interests of Sun River Health. Employees must never use their position with Sun River Health, or any of its patients, for private gain, to advance personal interests or to obtain favors or benefits for themselves, their family or any other individuals, corporations, or business entities. Examples of potential conflicts of interest include, but are not limited to: •

•

Any kind of financial interest (other than nominal ownership in a publicly traded Sun River Health) in any competitor, vendor or related organization which does or seeks to do business with Sun River Health Any business arrangement with a competitor, vendor or other outside organization that does or seeks to do business with Sun River Health

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•

• •

Any kind of fiduciary relationship (e.g., Board member or trustee) with a competitor, vendor or other outside organization that does or seeks to do business with Sun River Health A personal relationship with an individual who has a business, financial or fiduciary relationship as defined above. A personal relationship means a relationship based on family, friendship, or romance Any interest in a Sun River Health through publicly traded stocks, bonds, or mutual funds available to the public shall not constitute an interest, provided the ownership or investment interest is less than one percent of such Sun River Health’s shares Offering or accepting money, gifts, and gratuities, except that employees may accept gifts of nominal value, (i.e., cookies, homemade scarf etc.) Using business or financial information learned or Sun River Health resources for personal gain

If a conflict of interest may occur, you should discuss the situation to your supervisor or the CEO immediately so that appropriate steps can be taken and to ensure the employee does not violate this policy. Affirmative Disclosure Requirements: It is the policy of Sun River Health that interests shall be fully disclosed by any individual regardless of whether a conflict of interest is determined to exist. Annual Disclosures: Sun River Health requires annual disclosure of: (1) all interests which may create an actual or potential conflict of interest, and (2) where applicable, provide a statement suggesting how such conflict could be avoided or mitigated. Other Disclosures: Completion of a Disclosure Form does not relieve individuals of the obligation to comply with this Conflict-of-Interest policy regarding disclosure of interests that may arise after the filing of the Disclosure Form Procedures for Addressing the Conflict of Interest Sun River Health will strive to resolve the matter in a manner acceptable to Sun River Health and the employee wherever feasible and warranted and to the extent permitted by law.

Gifts No Sun River Health employees may solicit or accept gifts, gratuities, favors or anything of value from any current or potential patient, vendor, or contractor of Sun River Health or any current or potential party to a sub-agreement with Sun River Health. Every Sun River Health employee must decline or return any gift, greater than $25.00 in value, and notify the CEO of such gift. Sun River Health will terminate any employee found to have offered or accepted a bribe to secure funding or other benefits from Sun River Health.

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A “gift” means anything of value, except for promotional materials of little or nominal value such as pens, calendars, mugs, and other items intended for wide distribution and not easily resold. Gifts include (but are not limited to): personal gifts, such as sporting goods, household furnishings and liquor; social entertainment or tickets to sporting events; personal loans or privileges to obtain discounted merchandise, and the like.

Reporting Suspected Ethical and Legal Violations It is the responsibility of every employee to comply with our expectations regarding appropriate organizational conduct, including reporting any potential ethical and legal violations. Knowingly failing to report may result in disciplinary action against the individual who failed to report the misconduct or violation. Sun River Health employees can file internal, confidential, and anonymous complaints concerning questionable practices or actions without fear of retaliation. This includes refusal to obey an order that would require an employee to violate applicable law. If an employee reports what their believes, in good faith, involves a violation of applicable law, the employee will be protected from retaliation even if the allegations turn out to be incorrect or unsubstantiated. Sun River Health will also comply with any applicable state or local whistleblower protection laws and will not discharge, demote, suspend, threaten, harass, or otherwise discriminate in the terms or conditions of employment because of a good faith report. Sun River Health will promptly investigate all claims of discrimination against an employee who filed a good faith report (i.e., a “whistleblower”) and take appropriate and effective remedial action. All reports of illegal and dishonest activities should be promptly submitted to Human Resources or the Chief Executive Officer. Also, reports can be made to the Compliance Hotline at 1(888) 692-6675 or 1(888) MY-COMPLY.

Relationships with Patients The relationship we establish with each patient is for the benefit of the patient. Any association or involvement between an employee and a patient which may be disruptive or detrimental to the provider-patient relationship, or any attempt to use the patient to advance the self-interest of an employee, is expressly prohibited. Staff should not provide patient care to family members and any potential conflicts should be disclosed to your supervisor.

Employees as Patients of Sun River Health One of the benefits of working for Sun River Health is the opportunity to use our high quality and convenient urgent care, primary medical, behavioral, and dental services. Employees can use any one of our locations and request a provider. Providers can

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either accept an employee as a patient or refer the employee to a more appropriate provider. Benefits • Sun River Health is a high-quality provider, with many locations and a broad range of services for youand your family • There are reduced co‐pays for those enrolled in Sun River Health medical insurance program whenaccessing care at Sun River Health locations Considerations as a patient • Will I be comfortable talking to my co‐worker about complex medical or behavioral health drugs? Or answering screening questions about sexual health and substance use? • Will I be comfortable receiving physical exams? • Will I be comfortable with co‐workers potentially being aware of my medical issues by virtue oftheir job responsibilities? • Should I choose a primary care provider at a site where I don’t work? Considerations as a Clinician We recognize that defining appropriate boundaries will be critical when you care for a staffmember as a patient. Some things to consider: •

• •

• • • •

If the care you are providing a staff member patient might be compromised by your personal or professional relationship with them, consider, in advance, how you will recognize this. How will you communicate this? Patients are often non‐adherent with clinician recommendations, but we don’t see themevery day. How will you address your patient’s health behaviors when you are able to observe them every day? If a staff member patient discloses information regarding their substance use that impactstheir job, you must protect patient confidentiality and HIPPA guidelines. Please remember that staff members have additional options for support through our EmployeeAssistance Program (EAP) Colleagues and co-workers who become patients may request special treatment—care outside best clinical guidelines. How will you address this and communicate your need to follow the evidence? If for these or other reasons you feel uncomfortable providing medical care to your colleagues or coworkers, we support you to tell them you cannot serve as their providerand help them find another suitable option If, after reviewing the key questions above, a staff member chooses to be a patient, we mustcare for them based on the best clinical guidelines If while caring for one of our staff, you have questions or concerns regarding the appropriateness of the relationship or disclosure of medical

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information orany other issue, please consult with your Site Medical Director or Regional Medical Director Process Reminders • As a staff member, you are not permitted to review your own medical record utilizing your eCWaccount access. As with all patients, you are entitled to a complete copy of your medical record and can request that following current procedures • You may not request, nor should clinicians provide hallway consults on staff health questions or results from tests. Scheduled appointments, phone requests, or portal requests should be used to best address questions or follow up • You must log out of e‐time for the duration of any medical appointments and use sick time • Clinicians may decline to provide care to any staff member for any reason, except in a medical emergency • Clinicians must use scheduled appointments and regular patient communication channels toprovide medical treatment advice, prescriptions, and test results • You may choose to have your primary care provider at one location and utilize same day orurgent care services at another location

Relationships with the Public Sun River Health pledges to provide all our patients with professional service at every step. Regardless of your position, as an employee of Sun River Health, you are our ambassador. Each one of us is responsible for ensuring that our visitors and the public feel comfortable and welcome at our organization. It is possible that you will be approached by a member of the outside media (e.g., newspaper, television, radio, etc.), market researchers and others regarding Sun River Health business. Sun River Health enjoys a friendly and supportive relationship with the TV, print, radio, and online media to promote and encourage our mission and the public health. We are eager to connect with media professionals and to help support their work of bringing awareness to the patients and communities we serve. If you are contacted by a member of the media, including reporters, film or television producers or directors, journalists or journalism students, or other media professionals or professionals in training, you should direct the individual to Communications Department in a timely manner. To ensure consistency in our message delivery, employees are not authorized to speak to the media on Sun River Health’s behalf. However, we actively seek and train staff members in media training to diversify and

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broaden our public voice. If you are interested in such work, you should contact the Communications Department. When answering the telephone, identify the organization along with your name in a professional and courteous manner.

Dispute Resolution Procedure Questions or problems may arise concerning duties, working conditions, interpretations of policy, or personal problems that may occur that affect work performance. The Problem Resolution Procedure has been established so that employees and management have a process to address concerns and resolve problems in a fair and efficient manner. The process consists of the following steps: Step One: An employee should discuss the nature and cause of the issue or problem with the employee’s immediate supervisor. Step Two: If a satisfactory resolution is not reached in step one, the employee may submit the issue or problem in writing to the employee’s next level of management. Step Three: If a satisfactory resolution is not reached in step two, the employee may submit the issue or problem in writing to the Chief Human Resources Officer or designee. Retaliation against an employee who utilizes the dispute resolution procedure is prohibited and will be appropriately addressed.

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SECTION 4 EMPLOYEE SUPPORT SERVICES Suggestion Program Sun River Health welcomes feedback from all staff, including regarding how to innovate and improve our services and experiences for staff, patients, and communities alike. If you have an idea for an innovation, you can send an email to ThatsaGoodIdea@sunriver.org or submit the idea via the Intranet. All submissions are reviewed by a team of Sun River Health senior leaders, and responses are provided within 48 hours. If your idea is selected and implemented by the organization, you can earn $100.

Workforce Wellness Program The Workforce Wellness Program at Sun River Health offers all staff the opportunity to participate in interactive activities that promote wellness across its eight dimensions. Each quarter, a new Workforce Wellness Challenge is announced to all staff. Throughout each month, a series of activities and prompts are shared. Staff who participate in the Challenge can earn fun Sun River Health prizes. With questions, contact Wellness@sunriver.org.

Care Team Sun River Health recognizes that staff may find themselves in crisis and emergency situations, and the Care Team was developed in 2019 to provide confidential financial support to these individuals. Any staff member who has completed their probationary period can request confidential financial assistance for eligible emergencies by completing a brief form available on the Sun River Health Intranet. The Care Team reviews every request and responds to the individual within 48 hours. Awards up to $500 are provided to staff whose requests are approved, and the award is provided in the next available pay period via direct deposit. For more information about The Care Team, award eligibility and guidelines, and more, search “The Care Team” on the Intranet.

Employee Recognition Programs Planetree Institute As part of Sun River Health’s Planetree Institute, several employee recognition awards are provided to staff who embrace and uplift a person-centered care spirit and model. The following reflect our Planetree Awards and the frequency of their selection: • Planetree Spirit Award: Three staff, one representing each of our regions, are selected each month to earn a Planetree Spirit Award for the ways that they

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demonstrate a spirit of person-centered care and go above and beyond in service to their colleagues, patients, clients, and others who they serve Planetree Outstanding Leadership Award: Up to three staff, representing each of our regions, are selected monthly to earn a Planetree Outstanding Leadership Award for the ways that they demonstrate person-centered leadership and work to uplift the employees and teams they serve Planetree Innovation Award: One individual or a team of staff are selected each quarter to earn a Planetree Innovation Award for a results-driven innovation project that addresses one of Sun River Health’s key performance areas and that has demonstrated successful improvement for the organization, our staff, our patients, and/or the communities we serve Planetree Community Spirit Award: Up to one team is selected per month to earn a Planetree Community Spirit Award for their outstanding commitment to supporting and improving the community around them. Previous award winners have planted sustainable community gardens, hosted community baby showers, supported community residents with access to COVID-19 vaccines, and more

All staff are eligible to nominate a colleague for these awards, and nomination forms can be found on the Sun River Health Intranet. A staff member can be nominated for an award after they have completed their probationary period. Staff who are selected to earn a Planetree Award receive a commemorative plaque and other recognition depending on the award and are celebrated in a virtual recognition ceremony hold each quarter led by Sun River Health’s Planetree Institute and the organization’s senior leadership team. Another aspect of the Employee Recognition Program at Sun River Health is our Acts of Kindness program. For those moments when a staff member goes above and beyond to provide exceptional person-centered service, staff and patients can share a brief ballot reflecting the service of the individual staff member. Ballots can be emailed to ActsofKindness@sunriver.org or can be submitted via ballot boxes available in many of our health center locations. Ballots are collected and consolidated each month, and an all-staff email is sent every quarter that includes all the submissions. Up to three individuals who were recognized in the submissions may be selected per quarter.

Employee Service Recognition Program To recognize employees who have worked for Sun River Health for significant amounts of time, Sun River Health has an Employee Service Recognition Program. Eligible employees will be honored on an annual basis and will receive recognition of their service to the organization.

Schwartz Rounds

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Since 2018, Sun River Health has collaborated with The Schwartz Center for Compassionate Health Care to dedicate a time for staff to come together for collective restoration, and to offer empathy and compassion for each other. These gatherings are a time and space to honor and appreciate the courage, presence, and support of our community together with conversations on topics of racism and injustice, isolation, navigating family relationships, loss, and meaningful self-care. These sessions are centered around relevant, lively, and open conversations approached with kindness, confidentiality and a judgement-free environment that reenergizes participants and reminds us of the importance of compassion in our lives and work. These Rounds are a safe space for all to express our feelings and gain comfort in knowing that we have colleagues with whom we can share our experiences wholeheartedly. Invitations with conversation themes are sent to all before each gathering and we support and host smaller sessions and specific topics as needed – we welcome you to join!

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SECTION 5 GENERAL INFORMATION Employee Records Sun River Health maintains individual employee records which generally include your employment application, certifications, performance appraisals, and other documents related to your employment at Sun River Health. If any medical information is received, it will be maintained confidentially and provided to management staff except as needed and authorized. Employees are responsible for ensuring that your employee records are current by notifying your supervisor and Human Resources as well as updating your information in Oracle with any relevant changes in your personal information. This is important for benefit programs and beneficiary designation purposes, as well as to be able to reach someone in the case of an emergency. Changes to your name, address, telephone number, marital status, number of dependents, and emergency contact information should be reported. Your scholastic achievements, certification and licensure status are also important records that should be updated periodically. Sun River Health is committed to protecting the privacy of its current and former employees. Only an authorized representative of Sun River Health will respond to requests for earnings information, work history, and other confidential information, upon receipt of your written authorization. Requests for employment verification should be referred to Human Resources.

Protection of Employee Information Sun River Health will not, unless required by other applicable law publicly post or display an employee’s Social Security number; visibly print a Social Security number on any identification badge or card (including time cards); place a Social Security number in files or documents with unrestricted access; communicate an employee’s personal identifying information (Social Security number, home address/telephone number, personal e-mail address, Internet name/password, parent’s surname prior to marriage, or drivers’ license number) to the general public; or permit any unlawful disclosures of an employee’s Social Security number.

Sun River Health Physical Property You will be provided with the necessary equipment to effectively perform your job duties, and you are responsible for the handling and care of this equipment “as though it were your own.” This includes maintaining it and protecting it from possible theft or damage and avoiding equipment misuse and abuse. Should your assigned equipment become damaged or lost, you must advise your supervisor immediately. Equipment loss or

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damage, negligent or deliberate, may result in disciplinary action. If you leave the organization, the equipment must be promptly returned; otherwise, the cost of the equipment may be deducted from your PTO balance payout. Additionally, organization supplies, postage, letterhead, logos, and slogans are property of Sun River Health and must only be used for authorized purposes.

Workplace Searches Desks, lockers, and other storage devices are provided for the convenience of employees but remain the sole property of Sun River Health. They, as well as any articles found within them, can be inspected by any agent or representative of Sun River Health at any time, either with or without prior notice. In addition, to ensure the safety and security of employees and patients, and to protect our legitimate business interests, we reserve the right to question and inspect or search any employee or other individual entering onto or leaving Sun River Health premises or job sites. The inspection or search may include any packages or items that the individual may be carrying, including briefcases, handbags, knapsacks, shopping bags, et cetera. These items are subject to inspection and search at any time, with or without prior notice. Sun River Health also may require employees while on the job or on the premises to agree to reasonable inspection of their personal property and/or persons. The individual may be requested to self-inspect their personal property or person by displaying the contents of any packages and/or turning out their pockets, etc., in the presence of a representative of Sun River Health, typically a management employee of the same gender. By accepting employment with Sun River Health, employees agree to submit to workplace searches.

Employee Identification Badges, Access Cards and Keys Employees will be issued an identification badge, access cards, and/or keys that will provide access to organization offices, cabinets and/or lockers. These identification badges, access cards, and keys should only be used to gain access for authorized reasons. The identification badge must always be worn by all employees while on duty and be visible to patients and visitors. Employees must immediately notify their supervisor regarding any lost or stolen identification badge, access cards or keys. You must return your identification badge, access cards and keys by your last working day or when requested by your supervisor. Identification badges are provided by the HR Department. If you have concerns or need changes to your ID badge, please reach out directly to HR.

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Housekeeping Good work habits and a neat place to work are essential for job safety and efficiency. Frequently, patients, vendors, and other employees visit our office, and we must always be neat and orderly. This presents a professional image that will continue to earn the confidence and trust of others. Better organization enhances patient service. You are expected to keep your desktop and workspace organized, and to always maintain your work materials in good order. It is also important to clean up any common areas after you have used them, such as the break room, copy room or the reception area. Please report anything that needs repair or replacement to your supervisor as soon as possible.

Recycling To help protect the environment, please recycle and reduce waste whenever possible. All workspaces are equipped with separate recycling containers for paper (mixed paper, newspaper, and copy paper) and glass and aluminum products.

Intranet Sun River Health believes in the importance of keeping our employees well-informed about our organization. Therefore, Sun River Health has established an organization intranet to keep all employees up to date about organization news and job opportunities, and educated regarding our organization mission, goals, policies, and processes. We will also communicate any time-sensitive information to our employees through email. Sun River Health has the expectation that all staff members will regularly check the intranet and their email for notices, alerts, and other information. Intranet content is created by individual staff departments and is maintained and moderated by the Communications Department. Staff departments provide Intranet Authors, who are trained in content creation and uploading by the Communications Department. Intranet Authors are identified by department leads for training. If you are interested in becoming and Intranet Author, please speak to your supervisor.

Health, Safety and Security Sun River Health is committed to providing a safe, secure, and sound work environment; however, this is a shared responsibility of all employees of Sun River Health. Safe personal work habits and continuous awareness of potential hazards and safety rules/practices are major factors in reducing accidents and serious injury. If you become aware of any hazard, unsafe condition, or situation that may affect Sun River Health property/equipment or endanger the life or health of another, you should immediately notify your supervisor or

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the Practice Manager. Employees are required to use certain safety equipment where indicated.

Infectious/Communicable Disease Plan (IPC) Sun River Health has an extensive Infection Prevention and Control (IPC) Plan which applies to all employees, contract personnel, medical personnel, students, and volunteers who deliver patient services either directly or indirectly. Sun River Health strives to align the goals and purposes of its IPC plan with relevant regulatory and accreditation requirements of the CDC, OSHA, NYSDOH/NYCDOH and the recent DOL NYC Hero Act - Model Airborne Infectious Disease Exposure Prevention Plan. The goal and purpose of the DOL NYC Hero Act is to protect employees against exposure and disease during an airborne infectious disease outbreak. This plan goes into effect when an airborne infectious disease is designated by the New York State Commissioner of Health as a highly contagious communicable disease that presents a serious risk of harm to the public health. This plan is subject to any additional or greater requirements arising from a declaration of a state of emergency due to an airborne infectious disease, as well as any applicable federal standards. Click on the link to view the entire Hero Act document. (Add link here) The overall purpose of the Sun River Infection Prevention and Control Plan is to reduce the transmission and acquisition of healthcare acquired infections (HAI’s) for patients and employees such as: • • •

Blood borne pathogen disease via mucous membrane, cutaneous and/or parenteral exposure Respiratory illnesses – active pulmonary/laryngeal tuberculosis, SARS-COV2 (COVID-19) Communicable diseases – measles, varicella, etc.

Goals of the Sun River Health IPC plan includes: •

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Assess and identify risks then implement infection control processes to reduce the incidence of communicable diseases with high prevalence within communities served Monitor and enhance employee compliance to the IPC plan through orientation, ongoing virtual in-service training, mandatory competency assessments and auditing processes, proper use of personal protection equipment (PPE) relative to role and direct and non-direct care responsibilities Minimizing the risk of communicable disease public health exposures – ensuring staff roles and responsibilities in responding to exposures are clearly defined and acknowledged; monitoring patient immunization status, enforcing organization’s policies on staff immunizations, and maintaining strict adherence to cleaning and

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disinfection protocols for medical equipment, devices and supplies used in medical and dental procedures Provide formal and informal education to healthcare workers, patients, administrative and support staff; strategies include Intranet updates for staff, town hall discussions, patient education at each visit, educate and encourage use of patient portal, educational posters in patient waiting areas

The current IPC plan can be accessed through the SHR Intranet; links that provide guidance on general infection control issues, COVID-19 specific updates, employee specific questions regarding proper use and re-use of PPE, are included. Employees can direct confidential, clinical questions to Employee Health at employeehealth@sunriver.org. Should you ever have symptoms of an infectious or communicable disease, or a jobrelated exposure to one, it is essential you report it to your manager and Human Resources Department so you can be referred for examination and evaluation. Should it be determined you have a communicable disease that could have been transmitted to patients or other staff, you will be relieved from work and referred to your provider for treatment. You must submit a medical clearance form from your provider before you can return to work. If your position requires medical evaluations, you must complete this requirement in a timely manner as a condition of continuing employment.

Injury Reporting For the safety of all, it is imperative that you observe and practice all safety practices so that injuries can be prevented. If you have any safety-related questions, please speak up and let us know so that we may assist. Any work-related accident or injury, no matter how minor, must be reported to your supervisor and Human Resources immediately. Staff injury reporting forms are located on the HR tab of the intranet. If you do not report the matter promptly, it may impact your ability to quality for workers’ compensation benefits.

Hazard Communication Information A hazard communication program has been established for the following purposes: • • • •

To teach employees about the hazards of chemicals To protect employees from hazardous chemicals To reduce the risk of exposure To inform employees about the chemicals they work with

Material Safety Data Sheets (MSDS) are basic communication tools that provide detailed information on chemical products and how to use the products safely and are available to all employees.

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Smoke-Free Workplace Smoking and vaping (e-cigarettes) is prohibited in all Sun River Health locations and vehicles. Smoking and vaping is prohibited at and near all building entrances. Smoking and vaping is permitted outside the building in designated areas only.

Fire Prevention and Protection It is important to be prepared for fire or other emergencies. Offices are equipped with fire extinguishers and there are alternate escape routes to use in case of fire or other emergencies. Also, offices maintain alarm systems. The location of fire-fighting equipment and the stairwells will be posted on our bulletin board. To prepare for an emergency, employees should take an opportunity to review the location of exits and emergency equipment before an emergency happens.

Emergency Evacuation If the emergency fire alarm system is activated, all employees are to evacuate the building. Employees are required to be familiar with all alarm codes and to respond accordingly. In the event of an emergency, you should keep the following common-sense precautions in mind: • • • • •

Treat any alarm or drill as if it is a real emergency Do not attempt to collect work or personal items before leaving the building Use the stairs and not the elevator in the event of an emergency Close any windows or interior doors if time permits After evacuating the building, leave the immediate area; do not stand immediately in front or nearby the building. Meet at the designated spot so that management can verify that all employees have safely exited the building

If the emergency alarm was not sounded for a fire, but for another type of threat (biological, chemical, etc.), determine if you should stay put, “shelter-in-place” or get away. Under all circumstances, please remember that safety and preservation of life should always come first.

Emergency Operations Guidelines – Inclement Weather, Power Failure and Other Circumstances We make every effort to keep our services and operations open and operational during all scheduled hours to serve our patients and support our staff. Unanticipated full day or early closings or late openings may occur because of circumstances such as inclement

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weather, power failure, or environmental hazards. During these closures, there may be a need for some employees to provide essential services. If such an emergency should occur during non-working hours, notification of a site-closing or delay will be made via text message, telephone and/or email whenever possible, but it is the employees’ responsibility to confirm their work expectations with their immediate supervisor. If employees are unable to report to their normal work location, they may be required to report to another location or to work remotely. Work Reporting and Pay Guidelines If your department and/or work location remains open during any emergency/inclement weather conditions, you are expected to report for work. If you are unable to report to work on time (at the scheduled opening), need to leave work early (prior to the scheduled closing time), or are unable to report to work at all that day because of emergency/weather conditions, notify your supervisor and you will use PTO based on your regularly scheduled hours for that time off. In the event a department and/or work location opens late or closes early, employees who arrived to work at the beginning of the adjusted shift and working until the end of the adjusted shift will be paid for their regularly scheduled hours for that day.

Visitors Only visitors who are properly authorized are permitted on Sun River Health premises and should check in at the reception desk. This helps to protect our employees, patients and property, guard confidential information against theft, and reduce potential distractions and disturbances. Likewise, employee family and friends should be discouraged from visiting employees at work.

Remote Working Arrangements (RWA) Sun River Health has established and maintains remote working arrangements that support the operations and meet the performance expectations of the organization. Sun River Health considers Remote Working Arrangements (RWA) as a viable flexible work option for certain employees and positions but may not be viable for other employees and positions. A remote work arrangement is not a universal employee benefit or entitlement. Rather, it is an alternative working arrangement that providesorganizational flexibility to meet the operational needs of Sun River Health. Sun River Health can manage RWAs for all employees including the right and responsibility to initiate, terminate or modify the schedule of any RWA with any employee at any time with or without advance notice. RWAs may be established with a regular ongoing schedule, an intermittent schedule or on a project or as needed basis

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Definitions A remote work location is a designated and approved worksite, other than a Sun River Health owned and/or operated administrative or clinical site, that supports productive work and provides an environment, connectivity, and security appropriate to the work effort. This may include an employee's (or relative/friend of an employee) residence, a specific area at a telecommuting center, co-working site, or another approved location. Program Requirements Remote working arrangements are established in several ways: •

•

As a job requirement as determined by department management and Human Resources. Employees may be required to work remotely for a variety of business reasons as determined by Sun River Health. Circumstances which may require a “reasonable work accommodation” as determined by Human Resources.

Eligibility All remote working arrangements must be initiated by department management and be approved by the Chief Human Resources Officer. Management may decline an employee’s request for a remote arrangement or modify or end an RWA at any time. Employees are expected to remain aware of and comply with all Sun River Health policies and procedures as well as all applicable federal, state, and local laws and regulatory requirements. Employees participating in RWAs are expected to: •

• • •

Have consistent access to internet and cell service and ability to connect to organizational platforms such as Sun River Health email, eCW, eTime, ADP, Oracle, Coupa, etc. Maintain a safe and healthy work environment free from significant disruption or distraction from work responsibilitiesincluding regular dependent care. Establish and maintain an environment that minimizes risks to business and patient information. Agree to periodic inspection of remote work locations by department management with reasonable advance notice.

Schedules, Hours of Work, Pay, and Leave In general, supervisors have the responsibility to establish work schedules including standard (fixed) and alternate work schedules,that meet patient care and business needs; are consistent with the nature of the work being performed and are consistent with the

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nature and frequency of interaction necessary with those internal and external to the organization. The employee's availability should be equivalent to being on-site, i.e., accessible via email, instant messaging, or phone with minimal delay. Employees must be accessible during scheduled work hours to the supervisor and others with whom they are required or expected to interact and to remain fully engaged during that time. Any extended times of unavailability must be communicated to the supervisor in advance. There may be days or times when theemployee is required to be in a designated location, such as for required meetings. Hourly (non-exempt) employees will clock in and out of eTime and be paid for all time worked including overtime. No employee may work overtime without approval by their supervisor. Salaried (exempt) employeeswill enter their standard work hours in eTime. All employees will use Paid Time Off (PTO) for all scheduled time off. SST will be used in accordance with Sun River Health policy. Employee with RWAs will only be reimbursed for travel from one Sun River Health owned/operated location to another Sun River Health owned/operated location or client location to which they are assigned during their workday. Employees will not be reimbursed for travel to or from their remote work location and a Sun River Health owned/operated location as this is considered normal commuting. As Sun River Health is domiciled in the state of New York, Sun River Health will follow all interstate individual tax reporting and filing requirements. Sun River Health will not be liable for any adverse individual tax consequences based on decisions made by employees. Employees and Sun River Health are expected to comply with the employment and benefit laws based on the location of the RWA. This includes employee benefits, paid leave, workers’ compensation, and other work-related regulations. Any unique local considerations will be identified and agreed upon prior to initiating an RWA. •

• •

Workers’ Compensation - An employee’s workspace in his/her home will be considered an extension of Sun River Health’s workspace and is covered by Sun River Health Workers’ Compensation Policy and may be responsible under the WC policy for job-related accidents that occur in a remote workspace during the employee’s working hours. The organization is not liable for non-work-related loss, destruction, or damage of property or injuries to other people (family, friends, visitors, etc.) that may occur in or to the remote work location. Healthcare Benefits – Available in all contiguous states with notification to the carriers. Unemployment Compensation – Sun River Health and employee is coveredin any state following notification of the states’ unemployment fund and Sun River Health’s unemployment administrator.

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Paid Family Leave and Earned SST – Sun River Health may have to contribute to a state and/or local agency to provide for employee’scoverage under Paid Family Leave and/or Earned SST requirements.

Equipment and Supplies Employees will be provided with and are expected to use Sun River Health phones and laptops for Sun River Health related business as determined by department management and the Information Technology Department. Such equipment remains the sole property of Sun River Health and all data and information transmitted on Sun River Health equipment is subject to storage, review, and retrieval by Sun River Health. Employee’s use of personal technology equipment must be reviewed and approved with the IT Department. In general, IT will not be responsible for maintaining or supporting personal technology equipment. All Sun River Health equipment and materials must be kept secure, preferably in a designated work area, and not be made accessible to others. Employees are expected to and responsible for maintaining the confidentiality of all organizational and patient data and information by use of equipment and work area security, passwords, encryption, and other security measures. Office supplies needed for remote working such as paper, tablets, pens, envelopes, calculators, etc. should be ordered through the Sun River Health Procurement Department. Any purchases outside the normal procurement processmust be approved in advance by department management. Delivery of supplies will normally be made to a Sun River Health location. Generally, employees will be responsible for providing their own office fixtures and furniture such chairs, desks, cabinets, etc.Sun River Health may choose to purchase certain equipment for a RWA based on an operational requirement or special accommodation. Employees are responsible for maintaining and paying for consistent internet and cell service necessary for performing job duties..These expenses will not be reimbursed by Sun River Health. Sun River Health may choose to provide certain equipment for a RWA based on an operational requirementor special accommodation. All Sun River Health equipment and materials must be returned to Sun River Health immediately,uponits request, and immediately upon separation from employment. Failure toreturn equipment promptly and in satisfactory operating condition as requested may result in a deduction to an employee’s PTO balance to cover the cost of the non-returned or damaged equipment.

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SECTION 6 COMPENSATION AND PAY PRACTICES Employment Classifications Employees are classified using the two methods described below. Salary and Pay Status Employees are designated as exempt or non-exempt pursuant to applicable federal and state wage and hour laws. This classification is based on salary and job duties of the position. • •

Exempt – not eligible for overtime pay under the specific provisions of the Fair Labor Standards Act (FLSA) and applicable state laws Non-exempt - eligible for overtime pay under the specific provisions of the FLSA and applicable state laws

Employment Status and Benefits Eligibility Employees are also classified based on their regularly scheduled hours and status with Sun River Health. The classification of employees and number of scheduled hours may vary according to location. This classification is used for benefits eligibility and staff management purposes. • •

•

Union employees will be subject to the terms and conditions of the collective bargaining agreement Regular full-time – regularly scheduled to work at least 35 hours per week. The number of full-time hours may vary depending on the specific site. Generally, regular full-time employees are eligible for benefits subject to the terms, conditions, and limitations of each benefit program Regular part-time – regularly scheduled to work between 21 to less than 35 hours per week. Regular part-time employees may be eligible for some employee benefits, subject to the terms, conditions, and limitations of each benefit program Flexible part-time – scheduled to work less than 21 hours per week. Flexible parttime employees are not eligible for any employee benefits except those required by federal, state, or local law Per Diem – performs work on an “as needed” basis. Per diem employees are not eligible for any employee benefits except those required by federal, state, or local law Temporary – Employees whose duration of employment with Sun River Health is limited to a specific number of hours, days, weeks, or months to be worked. Employees in this category are not eligible for any employee benefits, except those required by federal, state, or local law

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Contract, Agency Staff, or Independent Consultant – those who are working on Sun River Health premises but are employed by another organization that has a business relationship with Sun River Health

Payroll Process Unless otherwise required by law, you will be paid on a bi-weekly schedule. The official pay period begins at 12:00 a.m. on a designated Sunday, continues to 11:59 p.m. on the second Saturday of the pay period, and consists of 14 (fourteen) consecutive, 24-hour days. Your paycheck will include earnings for the work performed through the end of the prior payroll period. For example, if you are paid on Friday, on the 27th day of the month, your paycheck or direct deposit statement will have your earnings for the work performed from the 8th through 21st of the month. If the normally scheduled payday falls on an organization-recognized holiday, every effort will be made to have your paycheck or direct deposit statement available on the workday preceding the holiday. All paycheck and employment earnings will be made by direct deposit to either your checking or savings account at the financial institution of your choice. Sun River Health strongly encourages employees to enroll in direct deposit as the most secure, rapid, and efficient way of receiving your pay. Employees will have online access to statement of wages, deductions, and taxes.

Wage Disclosure Protection Sun River Health, consistent with New York law, will not take an adverse employment action or retaliate against an employee for inquiring about, discussing, or disclosing the employee’s wages or the wages of another employee where prior permission has been obtained. Nothing in this policy shall require an employee to disclose their wages in response to any inquiry. Further, nothing in this policy shall be construed to permit an employee who has access to the wage information of other employees as part of such employee’s essential job functions, to disclose the wages of such other employees to individuals who do not otherwise have access to such information, unless such disclosure is in response to a complaint or charge, or in furtherance of an investigation, proceeding, hearing or action under New York law, including an investigation conducted by Sun River Health

Paycheck Deductions and Garnishments In accordance with applicable federal, state, and local laws, Sun River Health will make certain automatic deductions from your paycheck. When you are hired, and periodically as needed, you will complete a W-4 withholding exemption certificate to determine the amount of wages withheld for state and federal income taxes. Deductions may also be

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made for social security (FICA), state unemployment insurance, Medicare, elected insurance premiums or other miscellaneous payroll deduction plans. Employees who elect voluntary deductions must provide written authorization. Sun River Health is required by law to honor legal garnishments of an employee’s wages. Upon notification of a wage garnishment from the court, you will be notified, and the required funds will be deducted from your paycheck. Generally, exempt employees will be paid their regular bi-weekly salary. However, there are circumstances in which a salary deduction may occur. Deductions from an exempt employee’s salary are permitted in the following circumstances: • •

• • • •

When an employee is absent from work for one or more full days for personal reasons other than sickness or disability For absences of one or more full days due to sickness or disability if the deduction is made in accordance with a bona fide plan, policy, or practice of providing compensation for salary lost due to illness For penalties imposed in good faith for infractions of safety rules of major significance For unpaid disciplinary suspensions of one or more full days imposed in good faith for workplace conduct rule infractions In the employee’s initial or terminal week of employment if the employee does not work the full week For unpaid leave taken by the employee under the federal Family and Medical Leave Act.

Sun River Health may require an exempt employee to use available vacation or SST, as a replacement for salary, when the employee takes less than a full day off from work.

Overtime Although it is Sun River Health’s general practice that all work conducted by non-exempt employees be completed during the regular workday, conditions may arise that may require you to work overtime. Overtime assignments will be distributed as equitably as practical to all employees qualified to perform the required work. If you are non-exempt and work overtime, you will be eligible for overtime pay at one and one-half times your regular hourly rate of pay for all hours worked over forty (40) in a work week. Overtime pay is based upon actual hours worked; all forms of paid time off such as vacation, sick, personal, legal holidays and any other non-working time will not be considered time worked for the purposes of calculating overtime. All overtime must be approved in advance by your supervisor unless there is an extreme emergency or an exceptional, warranted circumstance. Employees who work overtime

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without receiving prior authorization will be paid for the time worked but may be subject to disciplinary action,

Designated Holiday Work Pay Hourly (non-exempt) employees who are required to work on one of the designated Sun River Health holidays will be paid at 1.5 (one and a half) times their regularly hourly rate of pay.

Work Schedules Regular operating hours for each site may vary depending upon business and patient needs and therefore work schedules for employees vary throughout the organization. Your supervisor will advise you of your individual work schedule and site’s operating hours. Employees are expected to be ready for work at the commencement of their shift. Any start time outside of this window must be pre-approved by your supervisor. Staffing levels and business needs may require variations in starting and ending times, as well as variations in the total hours that may be scheduled each day and week. When business needs cannot be met during regular working hours, employees may be scheduled to work additional hours. Whenever possible, advance notification of these assignments will be provided. Additionally, some employees may be required to work or remain on call on weekends and on holidays when Sun River Health is closed for services. In New York City, any employee who requests a temporary schedule change in accordance with New York City’s Temporary Schedule Change Law will be granted – at Sun River Health’s sole discretion – either the schedule change requested, or an unpaid leave of absence for the duration of the schedule change. In any calendar year, employees will not be entitled to more than two business days’ worth of schedule changes or unpaid leave of absence under this policy.

Time Records It is the policy of Sun River Health to comply with the requirements of the FLSA and all applicable laws and regulations in compensating all employees and in compensating non-exempt employees for regular hours and overtime hours worked. Therefore, daily, all non-exempt employees must properly login and logout of the electronic timesheet application to ensure proper tracking of and payment for all hours worked. Exempt employees must login and logout of the electronic timesheet on a pay period basis and record any paid time off or SST. All employees are expected to confirm that their time record is a true and accurate accounting of actual time worked. Sun River Health prohibits non-exempt employees from working “off the clock.” For this policy, “off the clock” work is where an employee works for Sun River Health and does not accurately record their time in the organization’s approved time record. It is a violation of

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Sun River Health’s policies for anyone to instruct or encourage another employee to work “off the clock,” to incorrectly report hours worked, or to alter another employee’s time records. If anyone directs or encourages an employee to incorrectly report hours worked, or to alter another employee’s time records, the employee must report the incident immediately to their supervisor and/or to Human Resources. If the supervisor is the employee whom the employee believes is violating this policy, then the employee must report the incident to Human Resources.

Duty to Review Paycheck and Report Errors All employees are required to review their paycheck for errors. If an employee believes that a mistake has been made, an improper deduction has been taken, or notices any other discrepancies or errors, they must immediately report this information to the Payroll Department. Reports will be promptly investigated and if an error has occurred, Sun River Health will correct the error as soon as administratively possible.

Meal Periods Employees working a shift of more than six hours will be provided at least 30 unpaid minutes for a meal between 11:00 a.m. and 2:00 p.m. Employees working a shift that starts before 11:00 a.m. and continues past 7:00 p.m. will be provided an additional unpaid meal period of at least 20 minutes between 5:00 p.m. and 7:00 p.m. Employees working a shift of more than six hours between 1:00 p.m. and 6:00 a.m. will be provided an unpaid meal period of at least 45 minutes midway through the shift. Your supervisor is responsible for approving the scheduling of this time. Non-exempt (hourly) employees must clock in and out for all unpaid meal break periods. In addition, when scheduling and operations allow, employees may be permitted one or two brief (10 to 15 minutes) paid break periods during a full workday. Supervisors will schedule meal and break periods to accommodate operational requirements. To ensure proper infection prevention protocols, employees are not permitted to eat in clinical areas.

Lactation Breaks Employees have a right to request a lactation room and reasonable break times to express milk. Employees may use unpaid break time or mealtime each day to express breast milk for a nursing child for up to three years following childbirth. Each break shall generally be no less than twenty minutes. Employees can elect to take shorter breaks but will not be required to do so. An eligible employee who intends to take breaks under this policy should notify her manager of her intent to do so in advance of returning to work following childbirthrelated leave. An employee may begin work before the regularly scheduled start of her

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shift or continue working past the regularly scheduled end of her shift to make up any time used for lactation breaks. An employee who chooses to do so should speak with her manager in advance to make appropriate arrangements. In addition to speaking with her direct supervisor, an employee may submit a written request for access to a lactation room and break time attendant to the use of such a room by sending an e-mail to your supervisor or Human Resources. The company will respond to such a request as soon as practicable within five business days. Sun River will, on an as-needed basis, identify a private room that complies with applicable law for the purpose of expressing breast milk. If the provision of such a room would otherwise constitute an undue burden on the company, the company will engage in good faith in a cooperative dialogue with the requesting employee to arrive at a reasonable accommodation. Should two or more individuals need to use the lactation room on a given day, the original requester will maintain her time slot(s) and the next available time slot will be given to the employee(s) making subsequent requests. Sun River is committed to enforcing this policy and prohibiting retaliation against employees who request or take break time under this policy, or who file a related complaint. If an employee feels that the employee or someone else may have been subjected to conduct that violates this policy, they should report it to their supervisor or Human Resources.

Compensation Philosophy We believe that it is in the best interest of both Sun River Health and our employees to fairly compensate our workforce for the value of the work provided. It is our intention to use a compensation system that considers the essential duties and responsibilities of the position, and relevant salary survey data. Available financial resources, various business factors and our commitment to provide fair and equitable wages are also factored into our compensation system. Our compensation philosophy and salary administration program are also reviewed on a regular basis, and we will make changes as may be needed. Please refer any compensation-related questions or issues to your supervisor or Human Resources.

Performance Pay Increases Performance pay increases may be given to an employee to recognize the employee’s performance and achievement of objectives. The employee’s annual performance appraisal, budgetary guidelines and other relevant factors as determined by Sun River Health serve as the basis for determining a performance pay increase (refer to section 2.16- Performance Appraisals). There is no guarantee that any employee will receive a performance or other pay increase.

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On-Call Requirement Several positions may require employees to be scheduled for on-call duty. Employees may attend personal functions and participate in personal activities while on-call, however they must be reachable via phone or email and prepared to respond to organizational needs. Employees that cannot be contacted or cannot respond immediately to such calls must notify their supervisor before the beginning of their oncall duties.

Business Expense Reimbursement Our travel reimbursement policy is based on federal guidelines for which expenses are reimbursable and which qualify as tax deductible business expenses. Reimbursement will generally be approved for business-related mileage, meals, hotels, and other reasonable and necessary business expenses. Expense forms must be completed, and receipts must accompany every travel expense where receipts are available. The process to submit for reimbursement are located on the organization’s intranet. All travel and related expenses must be pre-approved by your supervisor before they are incurred.

Use of Personal or Sun River Health Vehicles for Business There may be times that employees use their own personal vehicle or a Sun River Health -owned vehicle for Sun River Health business. In these situations, it is important that employees adhere to the following general guidelines: • •

• • • •

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Employee must have a current and valid driver’s license and must advise Sun River Health if they do not have one If employees receive tickets for moving or non-moving violations in a Sun River Health vehicle, they must report it immediately to their supervisor or Human Resources Employee must have at least the minimum level of personal automobile insurance coverage as required by law Employee must observe all traffic laws and use appropriate safety precautions, including use of seat belts Employee must pull over to the side of the road and park before using a cell phone for business purposes unless using an appropriate hands-free device Employee must immediately report any accident or personal injury from a vehicular accident to their supervisor, Human Resources, and their insurance Sun River Health, and follow all applicable procedures and guidelines. Employee must also submit appropriate staff incident forms Employees may not operate a vehicle for Sun River Health business if they are in under the influence of drugs or alcohol or are in any way “unfit for duty”

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• •

Employees must report all damage, defects or other condition that affects the vehicle’s operation or safety immediately to their supervisor Employees may only allow individuals on Sun River Health business to ride in an organizational “fleet vehicle”

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SECTION 7 EMPLOYEE BENEFIT PROGRAMS Benefits Overview There is a lot more to working at Sun River Health than your specific responsibilities, salary and the pride involved in being a part of a successful organization. Included in your “total compensation” is the value of the benefit dollars Sun River Health contributes to help you provide security for you and your family. Sun River Health makes contributions to major benefit plans that create a substantial level of financial security on an immediate and longer-term basis. Some benefits, such as Social Security, Workers’ Compensation, Disability and Unemployment Compensation, cover you in the manner prescribed by law. Other benefits, such as health insurance and paid time off, are provided as part of our philosophy to attract, retain, and motivate a capable team of employees. This portion of the Resource Guide contains a general description of the benefits for which employees may be eligible. It is not intended to, and does not, provide all the details of these benefits. This Resource Guide does not change or otherwise interpret the terms of the official plan documents. Summary Plan Descriptions (SPDs), and other information that explains the coverage of certain benefit plans in greater detail, are available for your review and are located on HR Intranet. Actual plan documents are the final authority on all matters relating to benefits provided through the plan. Eligibility for coverage or benefits under any such plan or plans shall be determined in accordance with the plan provisions. The following benefit descriptions are not all inclusive, and Sun River Health reserves the right to change, modify, or terminate benefits, plans, and carriers in its sole discretion, in accordance with applicable laws and regulations. Sun River Health reserves the right and authority, in its sole and absolute discretion, to administer, apply and interpret the benefit plans described herein, and to decide all matters arising in connection with the operation or administration of such plans, as permitted by law.

Paid Time Off Benefit (PTO) Paid Time Off (PTO) promotes a flexible approach to time off by combining vacation, legal holidays, and personal days into a single bank of time. PTO provides you with the flexibility to use your time off to meet your personal needs in accordance with your regular work schedule. It is the employee’s responsibility to manage their paid time off. You will earn and accrue a specified amount of PTO each pay period worked according to the designated Accrual Schedule to be used for vacation, legal holidays, school activities, personal business or emergencies and leaves of absence. Sun River Health may require you to use any unpaid PTO during disability or family medical leave, or any other leave of absence.

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Eligibility All regular full-time employees and regular part-time employees working at least twentyone (21) hours per week are eligible for to accrue PTO. Employees are required to use available PTO when taking time off from work. Requests for time off and use of PTO is subject to management approval. PTO must be scheduled and approved in advance unless an emergency exists. Accrual PTO is accrued on a per pay period basis beginning on an employee’s date of hire or transfer into a benefits-eligible position. PTO is accrued during the period of active work status and will not accrue while on leave of absence. PTO accrued hours will be reflected in an employee’s electronic time record. Once you have successfully completed the first ninety (90) days of employment, you will be eligible to use that time. All accrued hours are available for use in the pay period following the pay period in which they are accrued. The amount of PTO accrued is determined by position title, length of service and FTE (authorized scheduled work hours). Increases in an individual employee’s accrual rates based on years of service if applicable, will occur on the first day of the pay period in which the employee's anniversary date falls. Regular full-time and part-time employees working at least twenty-one (21) hours per week are eligible to use up to a maximum forty (40) hours of unaccrued PTO (go negative 40 hours) after 90 days of employment with approval of Human Resources Use of PTO PTO may be used immediately for designated legal holidays on which an employee’s work site is closed for business. Other than legal holidays, an employee must successfully complete his/her 90-day Introductory Period, to be eligible to use accrued PTO. An employee is required to use PTO hours according to his or her regularly scheduled workday/workweek and exempt or non-exempt status. • •

Non-exempt (hourly) employees must use PTO in a minimum of quarter hour (15 minute) increments Exempt (salaried employees) must use PTO in a minimum of one-half day increments

Payment of PTO PTO is paid at an employee's regular hourly pay rate and is not included as work time for purposes of overtime calculation.

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Designated Legal Holidays Each year, Sun River Health will publish a list of the specific dates on which each designated holiday will be recognized. If an employee is scheduled to work on a legal holiday on which his/her work site is closed, accrued PTO must be used in an amount equivalent to the number of hours that employee would normally be scheduled to work on that day. If an employee is not normally scheduled to work on a designated legal holiday, they are not required to use PTO for payment for that day. Hourly (non-exempt) employees who are required to work on one of the designated Sun River Health holidays will be paid at 1.5 (one and a half) times their regularly hourly rate of pay. Sun River Health is scheduled to be closed for most operations on the following legal holidays although some departments may be required to be open to meet patient access expectations: New Year’s Day Martin Luther King, Jr. Day Memorial Day Independence Day Labor Day Thanksgiving Day Christmas Day Maximum Accrual and Carryover Employees may accrue a maximum PTO balance of up to 1.25 times their annual PTO accrual amount. Once an employee’s PTO balance reaches 1.25 times the annual accrual amount, PTO time will stop accruing until PTO is used and reduced below the maximum permitted amount. There is no limit to the annual carryover amounts other than the maximum accrual amount described above. Separation from Employment and Payout Accrued PTO may not be used in lieu of proper notice of resignation. Accrued and unused PTO will be paid out upon resignation from employment, or upon transfer to a nonbenefit eligible position if proper advance notice has been provided. Employees who do not provide and work through proper advance notice or who are terminated from employment for disciplinary reasons are not eligible to receive payment for unused PTO. To receive payment for your accrued and unused PTO balance following resignation, you must provide and work satisfactorily through the following notice periods:

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•

Employees may not take PTO (unless previously approved) or SST during the notice period. Any employee who is out ill may be requested to extend their notice period by the number of days is out ill.

Sick and Safe Time (SST) Sick and Safe Time (SST) is an accrued benefit that may be used for personal illness or injury including doctor’s appointments, care for the illness of a family member and other reasons as outlined below and permitted by law. All employees are eligible to accrue SST. Accrual SST is accrued on a per pay period basis beginning on an employee’s date of hire or transfer into a benefits-eligible position. SST is accrued during the period of active work status and will not accrue while on leave of absence. SST accrued hours will be reflected in an employee’s electronic time record. Employee may take SST upon accrual and there is no waiting period after commencement of employment. Benefit Eligible Employees All regular full-time employees are eligible for paid SST accrued per pay period for a maximum of 12 days accrued per twelve months of employment. Part-time employee’s accrual is pro-rated based on their position’s FTE (regularly scheduled hours of work). Regular full-time and part-time employees working at least twenty-one (21) hours per week are eligible to use up to a maximum forty (40) hours of unaccrued STT (go negative 40 hours) after 90 days of employment with approval of Human Resources Non-Benefit Eligible Employees Sun River Health employees are who are not eligible based on their employment status to accrue the standard SST as outlined above will accrue one (1) hour of SST for each thirty (30) hours worked up to a maximum of fifty-six (56) hours of SST per twelve (12) months of employment. This includes per diem, temporary and summer intern staff.

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Use of SST An employee is required to use SST according to his/her regularly scheduled workday/workweek and exempt or non-exempt status. • •

Non-exempt (hourly) employees must use SST in a minimum of one-hour increments. Exempt (salaried employees) must use SST in a minimum of one-half day increments.

Eligible employees may use SST for absences from work due to: •

•

The employee’s or family member of the employee’s mental or physical illness, injury, or health condition, regardless of whether such illness, injury, or health condition has been diagnosed or requires medical care at the time that the employee requests such leave The employee’s or family member of the employee’s diagnosis, care, or treatment of a mental or physical illness, injury, or health condition, need for medical diagnosis, or need for preventive care Closure of employee’s place of business by order of a public official due to a public health emergency or the employee’s need to care for a child whose school or childcare provider has been closed by order of a public official due to a public health emergency The employee or family member being a victim of any act or threat of domestic violence, a family offense, sexual offense, stalking or human trafficking and the employee’s need to: obtain services from a domestic violence shelter, rape crisis center, or other services program; participate in safety planning, temporarily or permanently relocate, or take other actions to increase the safety of the employee or employee’s family members; meet with an attorney or other social service provider to obtain information and advice on, and prepare for or participate in any criminal or civil proceeding; file a complaint or domestic incident report with law enforcement; meet with a district attorney’s office; enroll children in a new school; attend civil or criminal court dates related to any act or threat of domestic violence, unwanted sexual contact, stalking, or human trafficking; or to take any other actions necessary to ensure the health or safety of the employee or the employee’s family member or to protect those who associate with or work with the employee

“Family member” is defined as a child, (biological, adopted, or foster child; legal ward; child of an employee standing in loco parentis); spouse (current or former, and regardless of whether they reside together); domestic partner (current or former, and regardless of whether they reside together); parent; child or parent of employee’s spouse or domestic partner; grandchild; grandparent; sibling (half, adopted, or step sibling); any other

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individual related by blood to the employee; or any other individual whose close association with the employee is the equivalent of a family relationship. Where applicable, SST will run concurrently (at the same time) with any other leave (i.e., FMLA). Where such need is foreseeable, employees should provide reasonable advance notice of the intention to use SST in a manner that does not unduly disrupt Sun River Health’s operations. Where such need is not foreseeable, employees are encouraged to provide notice of the need for SST as soon as practicable. Notice shall be provided to the employee’s supervisor or Human Resources. Employees shall, in good faith, determine how much SST they need to use, except that the minimum increment for the use of SST is four hours per day and, if more time is needed, then the employee can use SST in 15-minute increments. For an absence of more than three consecutive workdays, Sun River Health may require reasonable documentation of the need for SST. Failure to provide such documentation upon request may result in disciplinary action. Documentation signed by a licensed health care provider indicating the need for SST shall be considered reasonable documentation Employees shall not be required, as a condition of taking SST, to disclose the details relating to an employee’s or a family member’s medical condition or details relating to an employee’s or a family member’s status as a victim of family offenses, sexual offenses, stalking, or human trafficking. Furthermore, health information about an employee or an employee’s family member, and information concerning an employee’s or a family member’s status or perceived status as a victim of family offenses, sexual offenses, stalking, or human trafficking obtained solely for the purposes of utilizing sick or safe leave shall be treated as confidential and shall not be disclosed except by the affected employee, or with the written permission of the affected employee or as required by law. Misuse of SST is subject to disciplinary action. Misuse of SST, includes but is not limited to repeated use of unscheduled SST on or adjacent to regularly scheduled days off, holidays, vacation or pay days; taking leave on days when other leave has been denied; or a pattern of taking leave on days when the employee is scheduled to work a shift or perform duties perceived as undesirable. Payment of SST SST is paid at an employee's regular hourly pay rate and is not included as work time for purposes of overtime calculation.

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Carryover Employees may carryover accrued, unused SST into the next calendar year. There is no maximum SST balance or amount of SST that can be carried over into the next calendar year. Separation from Employment Accrued but unused SST will not be paid out upon termination of employment for any reason or transfer into a non-benefits eligible position.

Safe Time Leave (Westchester County Employees) All employees who work for more than 90 days in a calendar year in Westchester County who are victims of domestic violence or victims of human trafficking are entitled to take up to 40 hours of paid safe time leave in any consecutive 12-month period to attend/testify in a criminal and/or civil court proceeding relating to domestic violence or human trafficking or to move to a safe location. This safe leave is in addition to sick leave provided for Westchester County employees. Where such need is foreseeable, employees shall make a good faith effort to provide notice to Sun River Health in advance and shall make a reasonable effort to schedule the use of safe time leave in a manner that does not unduly disrupt Sun River Health’s operations. Where such need is not foreseeable, employees are encouraged to provide notice of the need for sick leave as soon as practicable. Notice shall be provided to Human Resources. Sun River Health may require an employee to provide reasonable documentation of the need for safe time leave, including a court appearance ticket or subpoena, a copy of a police report, an affidavit from an attorney involved in the court proceeding relating to the issue of domestic violence and/or human trafficking, or an affidavit from an authorized person from a reputable organization known to provide assistance to victims of domestic violence and victims of human trafficking (such as My Sisters’ Place). Employees must record safe time in the timekeeping system. Pay for safe time leave will not be counted as hours worked for the purpose of calculating overtime pay. Employees may only use safe time leave for authorized reasons. Employees using safe time leave for unauthorized reasons or who have demonstrated a pattern of abusing safe time leave may be denied the right to use safe time leave in the future. Where applicable, safe time shall run concurrently with any other leave (i.e., FMLA or New York State Paid Family Leave).

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Voting Time Leave Employees will be given up to two hours paid as regular work hours to vote in federal, state, and local elections. Employees must inform their supervisor at least two days before the election of the intention to take paid voting leave. Sun River Health reserves the right to select the hours the employee is excused to vote and may require that the requested time off be taken at the start or the end of the employee’s shift.

Jury Duty and Witness Duty Leave Sun River Health encourages employees to fulfill their civic responsibilities by serving on jury duty or as a witness when required. If you are summoned for jury or witness duty, please present the summons/notice to your supervisor immediately. It is anticipated that you will report to work during your regular scheduled working hours except when your presence is required for jury or witness duty. Non-exempt employees will be paid the first $40.00 of their wages for the first three (3) days of jury or witness duty, provided, however, that regular full-time non-exempt employees who have completed 90 days of service are eligible to receive up to a maximum of ten (10) paid days per calendar year for jury and witness duty. Any days in addition to those reimbursed may be paid using PTO. Exempt employees continue to receive their salary while on jury duty, in accordance with applicable law. Jury and witness duty pay is calculated using your base pay rate at the time of leave multiplied by the number of hours you are regularly scheduled to work during that time.

Crime Victim Leave Eligible employees may take time off from work, without pay or using their PTO to comply with a subpoena to testify in a criminal proceeding (including time off to consult with the district attorney); to give a statement at a sentencing proceeding; to give a victim impact statement at a pre-sentencing proceeding; or to give a statement at a parole board hearing. An employee is eligible for time off under this policy if they are the victim of the crime at issue in the proceedings; the victim’s next of kin; the victim’s representative if the victim is deceased because of the offense; a “Good Samaritan”; or pursuing an application or the enforcement of an order of protection as provided under relevant law. For purpose of this policy, a “Good Samaritan” is someone who acts in good faith to apprehend a person who has committed a crime in his or her presence, to prevent a crime or an attempted crime from occurring, or to aid a law enforcement officer in effecting an arrest. A victim’s representative is a person who represents or stands in the place of another person, including but not limited to, an agent, attorney, guardian, conservator, executor, heir, or parent of a minor.

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An employee must notify his or her supervisor of the need to take a leave under this policy no later than the day before the absence. In addition, the employee must provide the supervisor with verification of his or her service upon request.

Bereavement Leave Bereavement leave is available to regular full-time employees and to regular part-time employees working at least 21 hours, pro-rated based on their regular schedule, who have completed the first ninety days of employment. Employees who wish to take time off due to the death of an immediate family member should notify their supervisor as soon as possible before the leave commences. An employee may be excused and may be paid up to a maximum of three (3) consecutive business days in the event of a death of an immediate family member. Prior supervisory approval is necessary for the use of nonconsecutive time-off. For this policy, members of the immediate family include spouses, same-sex committed partner, parents, brothers, sisters, children, grandchildren, grandparents, parents-in-law and children, parent or other relative of same-sex committed partner. Documentation supporting the relationship may be required. Bereavement pay is calculated using your base pay rate and is not included as work time for the calculation of overtime

Family and Medical Leave Act Sun River Health provides eligible employees up to 12 weeks of unpaid family or medical leave within a rolling 12-month period. Sun River Health also provides eligible employees up to twenty-six (26) weeks of unpaid Military Caregiver Leave in a rolling 12-month period. To be eligible for family and medical leave, an employee must have been employed by the Sun River Health for at least twelve (12) months prior to the date requested for leave to begin (which need not be consecutive); have worked at the Sun River Health for at least 1,250 hours during the 12-month period immediately preceding the commencement of the leave; The 12-month period is measured backward from the date the employee begins using FMLA leave. Reasons for Taking Leave An eligible employee may be granted a Family or Medical Leave of Absence for the following reasons: •

The birth, adoption, or foster care placement of an employee’s child. The leave must conclude within one year of birth or placement. For purposes of this policy, this shall be referred to as “bonding leave”

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•

To provide care for the employee’s child, spouse, domestic partner, or parent who has a serious health condition. “Parent-in-law” is not included. For purposes of this policy, this shall be referred to as “family care” The serious health condition of the employee that prevents the performance of the essential functions of his or her position. This includes time covered by shortterm or long-term disability, or worker’s compensation benefits Active-Duty Leave - Any qualifying exigency arising out of the fact that the spouse, or a son, daughter, or parent of the employee is on active duty (or has been notified of an impending call or order to active duty) in the Armed Forces in support of a contingency operation Military Caregiver Leave - For a spouse, son, daughter, parent, or nearest blood relative to provide care for a member of the armed forces who is undergoing medical treatment, recuperation, or therapy, is otherwise in outpatient status, or is otherwise on the temporary disability retired list, for a “serious injury or illness”

Spouse means a husband or wife as defined or recognized under state law for purposes of marriage in the state where the employee resides, including common law marriage or same sex marriage in states where these marriages are recognized. Notice and Certification When the need for leave is for family care, a serious health condition or military caregiver leave employees are required to provide: •

•

• •

30 days advance notice when the need for the leave is foreseeable, or such notice as is both possible and practical if the leave must begin in less than 30 days (normally this would be the same day the employee becomes aware of the need for leave or the next business day) Notice within the time prescribed by Sun River Health’s normal absence reporting policy when the need for leave is not foreseeable, unless unusual circumstances prevent compliance, in which case notice is required as soon as is otherwise possible and practical When the leave relates to medical issues, a completed Certification of Health-Care Provider form within 15 calendar days (for Military Caregiver Leave, an invitational travel order or invitational travel authorization may be submitted in lieu of a Certification of Health-Care Provider form) Periodic recertification (upon request) Periodic reports during the leave

When leave is for planned medical treatment, employees must try to schedule treatment so as not to unduly disrupt Sun River Health’s operations. Employees must contact their supervisor or Human Resources prior to scheduling planned medical treatment.

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In some circumstances, employees may be required to submit a medical recertification in connection with an absence. For example, Sun River Health may request recertification if the employee requests an extension of leave; the circumstances of the employee’s condition as described by the previous certification change significantly (e.g., the employee’s absences deviate from the duration or frequency set forth in the previous certification; the employee’s condition becomes more severe than indicated in the original certification; the employee encounters complications); or Sun River Health receives information that casts doubt upon the employee’s stated reason for the absence. In addition, recertification may be required in connection with an absence after six months have passed since the original certification, regardless of the estimated duration of the serious health condition necessitating the need for leave. Any recertification requested shall be at the employee’s expense. At Sun River Health’s expense, it may also require a second or third medical opinion regarding an employee’s own serious health condition or the serious health condition of the employee’s family member. In some cases, Sun River Health may require a second or third opinion regarding the injury or illness of a “Covered Servicemember.” Employees are expected to cooperate with the Sun River Health in obtaining additional medical opinions that Sun River Health may require. When the need for leave is for military emergency leave, employees are required to provide: • •

•

As much advance notice as is reasonable and practicable under the circumstances A copy of the covered military member’s active-duty orders when the employee requests leave and/or documentation (such as Rest and Recuperation leave orders) issued by the military setting forth the dates of the military member’s leave A completed Certification of Qualifying Exigency form within 15 calendar days, unless unusual circumstances exist to justify providing the form later.

All certification forms are available from Human Resources. Failure to Provide Certification and to Return from Leave Absent unusual circumstances, failure to comply with these notice and certification requirements may result in a delay or denial of the leave. If an employee fails to return to work upon expiration of leave and the employee has not obtained an extension of the leave, Sun River Health may presume that the employee does not plan to return to work and will terminated their employment. Guidelines for Taking Leave If both spouses work for Sun River Health and are eligible for leave under this policy, the spouses will be limited to a total of 12 workweeks off between the two of them when the leave is for family care, a serious health condition or active-duty leave. If both spouses

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work for Sun River Health and are eligible for leave under this policy, the spouses will be limited to a total of 26 workweeks off between the two when the leave is for military caregiver leave or a combination of military caregiver leave, active duty leave and/or family leave. An employee may take his or her leave in one continuous block of time. Alternatively, the employee may request to be placed on an intermittent or reduced leave schedule, where the employee would work less than the regular work week according to a pre-arranged schedule or work a reduced workday. Intermittent and reduced schedule leave is only permitted when based on a certified medical necessity. Intermittent or reduced schedule leaves for family care reasons must be agreed upon by both the employee and the employee’s supervisor. If leave is taken intermittently or on a reduced schedule basis due to foreseeable planned medical treatment, Sun River Health may require the employee to transfer temporarily to an available alternative position with an equivalent pay rate and benefits, including a part-time position, to better accommodate recurring periods of leave. Compensation and Benefits During Leave Generally, FMLA Leave is unpaid. However, you may be eligible to receive benefits through State-sponsored or Sun River Health -sponsored wage-replacement benefit programs. If you are eligible to receive these benefits, you may also choose to supplement these benefits with the use of accrued PTO and/or SST leave, to the extent permitted by law and Sun River Health policy. All such payments will be integrated so that you will receive no more than your regular compensation during this period. If you are not eligible to receive any of these wage-replacement benefits, Sun River Health may require you to use accrued PTO and/or SST to cover some or all the FMLA Leave. The use of paid benefits will not extend the length of a FMLA Leave. Health Care Benefits During Leave Sun River Health will continue making contributions for your group health benefits during your leave on the same terms as if you had continued to work. This means that if you want your benefits coverage to continue during your leave, you must also continue to make any contribution payments that you are now required to make for yourself or your dependents. Employees taking Bonding Leave, Family Care Leave, Serious Health Condition Leave, and Military Emergency Leave will generally be provided with group health benefits for a 12-work week period. Employees taking Military Caregiver Leave may be eligible to receive group health benefits coverage for up to a maximum of 26 workweeks. In some instances, you may be required to repay Sun River Health for premiums it paid to maintain health coverage if you fail to return to work following a FMLA Leave.

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If you are on a FMLA Leave but are not entitled to continued paid group health insurance coverage, in some circumstances you may continue your coverage under the Sun River Health plan in conjunction with federal and/or state COBRA guidelines by making monthly payments to Sun River Health for the relevant premium. Please contact Human Resources for further information. Your length of service as of the leave will remain intact, but accrued benefits such as vacation and sick leave will not accrue while on an unpaid FMLA Leave. Job Reinstatement Under most circumstances, you will be reinstated to the same position held at the time of the leave or to an equivalent position with equivalent pay, benefits, and other employment terms and conditions. However, you have no greater right to reinstatement than if you had been continuously employed rather than on leave. For example, if you would have been laid off had you not gone on FMLA leave, or if your position has been eliminated during the FMLA leave, then you will not be entitled to reinstatement. Prior to being allowed to return to work, employees wishing to return from a leave for their own serious health condition must submit an acceptable release from a health care provider that the employee may return to work, with or without accommodations. For an employee on intermittent FMLA leave, such a release may be required if reasonable safety concerns exist regarding the employee’s ability to perform his or her duties, based on the serious health condition for which the employee took the intermittent leave. “Key employees,” as defined by law, may be subject to reinstatement limitations in some circumstances. If you are a “key employee,” you will be notified of the possible limitations on reinstatement at the time you request a leave. Fraudulent Use of FMLA Prohibited An employee who fraudulently obtains Family and Medical Leave from Sun River Health is not protected by FMLA’s job restoration or maintenance of health benefits provisions. In addition, Sun River Health will take all available appropriate disciplinary action against such employee due to such fraud. Additional Information Regarding FMLA A Notice to Employees of Rights Under FMLA can be found on the Sun River Health Intranet.

New York Paid Family Leave (PFL) Paid Family Leave (PFL) is available to employees in New York who work for 20 hours or more per week for 26 or more consecutive weeks of employment, and to those who have

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worked fewer than 20 hours per week but have worked for 175 days in a 52 consecutive week period. Note that employees who are ineligible to receive benefits under this policy may opt out of having to make payroll contributions funding such benefits by contacting Human Resources for more information. Eligible employees will be entitled to up to 12 weeks per year of PFL under this policy. When appropriate, an eligible employee may take paid leave under this policy on an intermittent basis, in increments of no less than one full day of work. All paid leaves of absence under this policy must conclude within one year (365 days) of the date of the qualifying event, if not sooner, depending on usage and reason(s) for leave. An eligible employee may use PFL for any of the following reasons: •

•

To care for a close relative with a serious health condition. “Close relatives” are limited to spouses, domestic partners, children, parents, parent’s in-law, grandparents, and grandchildren. A “serious health condition” is an illness, injury, impairment, or physical or mental condition that involves either (1) inpatient care or (2) continuing treatment or continuing supervision by a health care provider. The law also treats bone marrow and organ donation (and recovery from same) as serious health conditions bond with the employee’s newborn, newly adopted, or newly placed child within the first 12 months after childbirth, adoption, or placement of an adopted or foster child. However, employees may not take paid family leave for their own prenatal condition(s) To spend time with a spouse, child, domestic partner, or parent either on active duty or who has been notified of an impending call or order to active duty, or to serve as a caregiver for a qualified veteran of the armed services with a serious injury or illness. However, paid family leave may not be used for an employee’s own serious health condition or qualifying military event

In addition, employees may request the use of PTO (under the applicable policy within this Resource Guide) prior to the birth, adoption, or placement of their foster child to prepare for such life events. Please be advised that to the extent permitted under applicable law, leave under this policy will run concurrently with all other leave entitlements for which the employee is eligible (i.e., FMLA leave). When the need for PFL is foreseeable, eligible employees must provide Sun River Health with no less than 30 days’ notice in advance of the date on which the leave is to begin. If the need for leave is not foreseeable, the employee must provide notice as soon as practicable. Employees who wish to take PFL should seek information and appropriate forms and other documents from Human Resources Benefits Team.

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Please note that employees may not use PFL while they are collecting workers’ compensation benefits and not working, or during any period for which they collect temporary disability benefits. PFL under this policy will be paid in the amount required under applicable New York law. Although eligible employees will be compensated by Sun River Health’s PFL insurance carrier for time away from work during their PFL under this policy, by law, such compensation will be at a level less than an employee’s regular rate of pay. For more information on exactly how much compensation you will be eligible to receive during PFL, please contact Human Resources Benefits Team. Eligible employees may, at their discretion, use available PTO and/or SST time. If an employee’s available PTO and/or SST is applied to any portion of his or her PFL, the employee will receive 100% of his or her average daily wage directly from Sun River Health and will be charged one day of PTO time and one day of PFL for each day during which PTO and/or SST time and PFL run concurrently. No employee will be eligible to receive more than 100% of his or her average daily wage for any day of PFL. Sun River Health will provide full compensation directly to the eligible employee for any day of PFL during which the employee utilizes PTO time; in that circumstance, any PFL payment from Sun River Health’s insurance carrier will be directed to Sun River Health as partial reimbursement for that day of PFL. PFL under this policy is job-protected, meaning that Sun River Health will make a good faith effort to reinstate the employee to the same position or an equivalent position for which they qualify with comparable pay, benefits and other terms and conditions of employment, provided such position is necessary and available.

Blood Donation Leave Sun River Health permits employees who work an average of 20 or more hours per week an unpaid leave or using their PTO of up to three hours per calendar year during their regular work schedule, for off-premises blood donation. Employees seeking leave to donate blood must give reasonable notice to their supervisors of at least three working days prior to taking leave for blood donation, and employees must provide documentation to their supervisors immediately after such leave is taken.

Bone Marrow Donation Leave Sun River Health permits employees who work an average of 20 or more hours per week an unpaid leave or using their SST or PTO if they seek to undergo a medical procedure to donate bone marrow. The total length of the leave for each employee will be determined by the physician but may not be longer than twenty-four work hours without Sun River Health approval. An employee who seeks leave under this section must provide verification from a physician of the purpose and length of the leave.

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COVID-19 Vaccine Leave Sun River Health provides employees with a leave of absence paid for at the employee’s regular rate of pay for a sufficient period, not to exceed four hours per vaccine injection, to be vaccinated for COVID-19. Sun River Health provides an additional leave of absence paid for at the employee’s regular rate of pay for a sufficient period, not to exceed four hours per vaccine injection, for each of an employee’s children for each COVID-19 vaccine injection. For purposes of clarity, vaccine leave under this policy is in addition to leave provided for under the PTO policy. Employees are protected under the law from retaliation for requesting or obtaining leave under this policy.

Military Leave of Absence Both state and federal law provide employees with the right to take leave to serve in the military. Sun River Health complies with all applicable laws governing military leave. Employees who believe they may need military leave or would like more information, should contact Human Resources.

Military Spouse Leave Sun River Health permits employees who work an average of 20 or more hours per week an unpaid leave of absence of up to ten days when their spouse is on military leave. To be eligible, the employee must be the spouse of a member of the United States armed forces, national guard, or reserves who has been deployed during a period of military conflict (to a combat zone of operations or a combat theater) and is on leave. An employee who seeks leave under this section may be required to provide documentation to support his/her request for leave. An employee’s other leave benefits (for example, vacation and SST) will not be affected by this policy. For purposes of this policy, “period of military conflict” means a period of war declared by the U.S. Congress, or in which a member of a reserve component of the armed forces is ordered to active duty.

Volunteer Emergency Responder Leave Eligible employees will be allowed time off from work to perform duties as a volunteer firefighter or member of a volunteer ambulance service during a declared state of emergency, unless providing the leave would impose an undue hardship on Sun River Health’s business operations. To be eligible for leave under this policy, employees must have previously provided Sun River Health with written documentation from the fire department or ambulance service notifying the organization of the employee’s status as

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a volunteer firefighter or volunteer ambulance service member, or the employee’s volunteer duties must be related to the declared emergency. Leave under this policy will be unpaid for non-exempt employees, except that employees may elect to use any other applicable paid leave to which they are entitled. Sun River Health may request certification of the need for leave in the form of a notarized statement from the head of the fire department or ambulance service setting for the period that the employee’s volunteer services were required.

Personal Leave of Absence Regular full-time employees with at least one (1) year of service may be eligible for an unpaid Personal Leave of Absence, at the sole discretion of Sun River Health. Regular parttime, flexible part-time, per diem, or other types of employees are not eligible for a personal leave of absence. This type of leave may be taken for a variety of personal reasons. A request for personal leave should be made in writing to Human Resources as soon as possible. All accrued paid time off must be taken before unpaid personal leave begins. The approval and the length of personal leave permitted will depend on various factors, such as Sun River Health’s business needs, workload, and staffing requirements during the requested period and will be agreed upon on a case-by-case basis. A personal leave of absence may affect an employee’s insurance coverage or accruals for benefits purposes. During an unpaid leave of absence, paid time off will not accrue. For more information regarding benefits during a personal leave, contact Human Resources. When a personal leave ends and, Sun River Health will try to place the employee in the position held before the leave of absence, or a comparable position for which the employee is qualified, if available. However, Sun River Health cannot guarantee that the employee will be reinstated to his or her prior position or any other position. If an employee does not return to work promptly at the end of a personal leave of absence, Sun River Health will assume that the employee has resigned, unless the employee has communicated with Sun River Health and obtained an extension of his or her leave. Additionally, employees are not permitted to engage in other work while on personal leave, unless pre-approval is obtained by the employee’s Department Head as well as the CEO.

Educational Leave of Absence Sun River Health encourages its employees to attend programs, seminars and courses that will be of benefit to them and to the performance of their job. Educational leave requests must be submitted for approved by the applicable Department Head as well as Human Resources before enrolling in a program. Educational Leave is unpaid time;

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however, employees may use accrued PTO for payment during this leave. Approval for an Educational Leave does not guarantee that the employee will be able to return to the same position, hours and rate of pay held at the time of the leave.

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SECTION 8 EMPLOYEE BENEFIT PROGRAMS – HEALTHCARE BENEFITS Health Care Benefits Overview Maintaining good health is important to you, your family, and Sun River Health. No one likes to be sick, but you may at times be faced with an illness or injury that requires treatment. Regular full-time employees are eligible for the benefits described in this section as soon as the employee meets the respective eligibility requirements. Regular part-time employees are eligible for some benefits described in this section if they meet the minimum requirements of the respective plan and are in a benefit eligible status. The Resource Guide contains a general description of the benefits for which employees may be eligible and is not intended to and does not provide all the details of these benefits. This Resource Guide does not change or otherwise interpret the terms of the official plan documents. For more details regarding Sun River Health’s health and welfare programs, and the Sun River Health Summary Plan Descriptions, please contact Human Resources.

Medical, Prescription and Dental Coverage Medical, prescription and dental insurance benefits are available to full-time and parttime employees who are in a benefit eligible status and regularly scheduled to work at least 21 hours per week, in accordance with the terms of such benefit plans. These benefits are effective on the first of the month following 30 days of employment. Employee contributions vary based on the salary level, benefit coverage selected, and whether you add coverage for your spouse or dependents.

Consolidated Omnibus Budget Reconciliation Act (COBRA) Under federal COBRA regulations, Sun River Health will offer continued health insurance coverage of up to eighteen (18) months if you resign, are terminated, or if your work hours are reduced, resulting in loss of health coverage for yourself and/or covered dependents. Eligible dependents may extend coverage up to thirty-six (36) months in the event of death, divorce, legal separation, enrollment for Medicare benefits or when a child ceases to be eligible for coverage as a dependent. Those wishing to continue coverage under COBRA, will be charged the full insurance premium (including the portion regularly paid by the organization and your regular contribution.) An additional 2% fee for administrative costs may also be added in accordance with applicable law. Payment will be made directly to Sun River Health or the third-party administrator as notified. Election of continued coverage must be confirmed within sixty (60) days of receiving the notice of eligibility documentation and the initial

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payment is due within forty-five (45) days of the benefit election. Failure to pay premiums within the required timeframes will result in termination of benefits. Human Resources will inform you of these options should you decide to leave Sun River Health or should your work hours be reduced to a non-benefit status. However, in the event of a divorce, legal separation, or loss of dependent eligibility, you or your dependent is responsible for contacting Human Resources to discuss your continuation or conversion rights.

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SECTION 9 INSURANCE AND DISABILITY INCOME PROTECTION Short-Term Disability Income Protection (STD) Should an employee become physically unable to work due to a non-work-related injury or illness, regular full-time employees and part-time employees in a benefit eligible status and regularly scheduled to work a minimum of 21 hours per week are eligible to receive short-term disability insurance paid for by Sun River Health. This program provides disability coverage after you have been disabled for a certain amount of time, as set forth in the plan documents. Disability claim forms may be obtained from Human Resources. Some employees be eligible for State sponsored disability benefits. Sun River Health shares the cost of this protection with the employee. All employees are covered by this benefit. Eligibility and benefit amounts are determined by New York State. Sun River Health short term disability benefits will supersede State disability benefits. To the extent permitted by law, employees may supplement disability benefits with PTO and SST but in no case will their salary on leave exceed 100% of their weekly rate of pay. While on short term disability there will be no accrual of PTO or SST.

Long-Term Disability Income Protection (LTD) Should an employee become physically unable to work due to a non-work-related injury or illness, regular full-time employees and part-time employees in a benefit eligible status and regularly scheduled to work a minimum of 21 hours per week are eligible to receive short-term disability insurance paid for by Sun River Health. This program provides disability coverage after you have been disabled for a certain amount of time, as set forth in the plan documents.

Life Insurance and Accidental Death and Dismemberment Insurance (AD&D) Regular full-time employees and part-time employees in a benefit eligible status and regularly scheduled to work a minimum of 21 hours per week are eligible to receive basic life and AD&D insurance paid for by Sun River Health. Coverage amounts vary based on annual base salary. Coverage will begin on the first of the month following the completion of 30 days of employment. It is imperative that the appropriate beneficiary forms be competed upon initial enrollment in the life and AD&D insurance. Any changes in beneficiary should be communicated immediately.

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Workers’ Compensation Insurance Workers’ Compensation insurance is provided to all employees and individually contracted staff by Sun River Health and provides benefits such as weekly income and medical expense reimbursement for covered work-related injuries. Sun River Health and employee is coveredin any state following notification of the states’ unemployment fund and Sun River Health’s unemployment administrator. If you incur an accident while at work, you are required to immediately report it to your supervisor and complete an incident report. Failure to do so may disqualify you from benefits to which you may be entitled under the Workers’ Compensation plan. You may choose to use PTO while you wait for a decision on the approval of a Workers’ Compensation claim.

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SECTION 10 RETIREMENT PROGRAMS 403(b) and 401(k) Retirement Plans Sun River Health offers eligible employees the opportunity to contribute to a 403(b) or 401(k) retirement plan, which allows them to benefit from tax-deferred growth of investments and earnings. Employees may choose to have a percentage deducted from their earnings on a pre-tax basis as of date of hire, up to the maximum allowed as governed by plan and IRS limits. Employees are 100% vested in their voluntary deferrals to the plan as of their start date in the 403(b) or 401(k)plan. Employees may also rollover eligible retirement funds from prior employers into Sun River Health’s 403(b) or 401(k) plan.

Employer Contribution Sun River Health may choose to make a nonelective contribution to eligible employees the first (1st) calendar quarter after completing one (1) year of service and 1,000 hours of paid work time. To receive this contribution, you must be employed on the last day of the plan year. The amount of the nonelective contribution, if any, will be determined each plan year and announced to all eligible participants.

Domestic Partner Coverage Sun River Health extends the same benefits to domestic partners as are offered to the spouses of legally married employees, and likewise the same benefits to the children of domestic partners as to the children of legally married employees. To take advantage of this extended coverage, the domestic partnership will need to be documented. To document a domestic partnership, employees will need to demonstrate that the partners: • • • • • • •

Are at least 18 years of age Are competent to make domestic partnership decisions Are not legally married to anyone Are not related in a manner that would prohibit legal marriage Do not have any other domestic partners Have lived together for at least one year Intend to be life partners

Employees will also need to provide supporting financial documents, including joint mortgage or lease statements, joint bank account statements, proof of joint ownership of a vehicle or other property, etc.

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Individuals in a documented domestic partnership must notify Human Resources within 30 days if a domestic partnership is terminated. Registering a domestic partnership may have tax and legal implications that should be reviewed prior to the registration process. Please speak with your attorney or tax advisor for more information.

Section 125 Plan Sun River Health offers its employees an option to enroll in a Section 125 plan. A Section 125 plan is a benefit plan that allows you to make contributions toward premiums for certain qualified benefits on a pre-tax basis rather than an after-tax basis. These qualified benefits may include health, dental, flexible spending accounts, transit check and other voluntary insurance programs. Under this plan an employee’s qualified expenses are deducted from gross pay before income taxes and social security taxes are calculated. Your gross pay will be reduced by an amount equal to your contributions for the respective qualified benefit premiums. Once employees have enrolled in a Section 125 plan, they may not make any changes to the pre-tax contributions until the next open enrollment date, except in limited circumstances.

Flexible Spending Accounts – Health Care and Dependent Care Sun River Health offers its employees an option to enroll in Flexible Spending Accounts for health care and dependent care expenses. Flexible spending accounts are Section 125 cafeteria plans that allow employees to have money deducted from their paychecks on a pre-tax basis and placed into accounts that can be used to pay un-reimbursed medical and dependent care expenses. Types of medical expenses generally covered include medical, vision or dental exams, copayments, and deductibles, as well as other eligible out-of-pocket expenses. Types of dependent care expenses generally covered include care for dependent children under 13 (if you use dependent care to work), or care for a disabled spouse or dependent.

Professional Liability Insurance Sun River Health carries Professional Liability Insurance for our organization and its employees at no cost to employees. This insurance coverage provides for the cost of legal representation for our organization and staff functioning in their work-related positions from potential lawsuits from external parties in addition to situations involving malpractice.

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Employee Assistance Program – 1-800-252-4555 All Sun River Health employees are eligible to receive the services of our Employee Assistance Program (EAP) immediately upon hire. The program offers employees, their covered family members, and members of employees’ household confidential counseling and referral services for a wide range of issues including: • • • • •

Stress Depression Marital or family problems Emotional problems Alcohol and/or drug-related problems

In addition to counseling and referral services, EAP also provides legal and financial planning services. Employees, covered family members and household members may contact an Employee Assistance Program specialist at any time, 24 hours a day, 7 days a week at 1-800-2524555. EAP specialists can provide problem assessment, short-term counseling and referral to the appropriate public or private services. Any services provided by the EAP are strictly confidential and information provided by those seeking assistance may only be released by that person through a written authorization, in accordance with applicable federal or state laws, except if the EAP is a mandated referral. Consultation services with an EAP specialist is provided at no cost. If additional services or treatment is necessary, the EAP specialist can provide referrals and can review coverage under your health insurance.

Fitness Activity Reimbursement Program Sun River Health encourages employee to participate in a variety of physical fitness programs to promote personal health and wellbeing. The Fitness Activity Reimbursement Program is intended to provide to support employees in their fitness endeavors. Sun River Health encourages employees to participate in variety of physical fitness programs designed to promote personal health and wellbeing. After one (1) year of service, all active benefits eligible full-time and part-time employees will be reimbursed up to a maximum of $150.00 per program year. The program year begins November 1 st of each year and ends October 31st of the following year. To receive reimbursement from this program, employees must be in an active status at the time of payout in early December.

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Eligibility All active benefits eligible full-time and part-time employees with at least one (1) year of service prior to the expense being incurred are eligible to apply for reimbursement of qualified fitness activity expenses of up to $150.00 annually. This Fitness Activity Reimbursement payment is considered taxable income. Eligible program and activity expenses Examples of programs and activities that are eligible for reimbursement may include gym membership, fitness classes and lessons (i.e., martial arts, Pilates, yoga, swimming, tennis, dance class, boxing and kickboxing, golf, Zumba, strength training, personal training), and race registration Fees, i.e., 5k, 10k, marathon, triathlon, cycling. Examples of programs and activities that are not eligible for reimbursement include but are not limited to massage therapy, chiropractor, country clubs/golf club membership, food, and beverage (i.e., juicecleanse, Nutrisystem), purchase of fitness equipment (i.e., weights, shoes, exercise videos, fitness wearables), activities and/or gym memberships for dependents.

Tuition Reimbursement Program Sun River Health encourages employees to pursue further education and professional development. The Tuition Reimbursement Program is intended to provide financial assistance for eligible employees enrolled in a degree education program through an accredited college or university related to the mission and activities of Sun River Health. Eligibility All active benefits-eligible full-time and part-time employees with one (1) year ofservice as of the start of a course(s) are eligible to apply for reimbursement of qualified tuition expenses. Employees must be in a benefit eligible status during the entire educational program/course includingat time of payment. If there is a change in employment status (i.e., fulltime to part-time or vice versa) during the academic year, reimbursement maximums will be based upon the employment status at the time of enrollment for the course. Criteria to be Considered for Tuition Reimbursement The following requirements must be met to qualify for tuition reimbursement: •

Employees must obtain a pre-approval from Human Resources prior to the start date of thecourse(s)

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•

• •

Course(s) must begin after the employee has met the eligibility requirements; meaning being ina benefits-eligible status, having completed 1 year of service and in an “active” work status and not on a leave of absence at the time of taking the course Course(s) must meet the requirements outlined under the “Approved Courses” section belowincluding being required for the completion of a degree Employee must receive a course grade of “B” or better or Pass for Pass/Fail course

Qualifying Course and Expense Criteria Courses eligible for reimbursement must meet the following criterion: • • • •

Courses must be offered by an accredited college, university, or technical school Courses must earn degree credits towards Associates, Bachelors, Masters, Doctoral, technical degree, or clinical license status Coursework may be completed through traditional classes or through nontraditionalprograms such as on-line or other distance learning programs Coursework must be related to the business of Sun River Health and /or job function

Expenses Eligible for Reimbursement Fulltime employees may be reimbursed for 100% of eligible out of pocket expenses for all credit hours satisfactorily completed, up to a maximum of $2,000 per calendar year. Part-time benefit eligible employees are reimbursed for 60% of eligible out of pocket expenses for all credit hours satisfactorily completed, up to a maximum of $1,200 per calendar. This tuition reimbursement payment is not considered taxable income. Eligible expenses included: • Tuition and/or registration fees • Textbooks or other required course materials • Lab fees Course and expenses that do not qualify for reimbursement include: • • • • • •

Certification or accreditation courses, workshops, seminars taken to meet job requirementsbut not taken toward the completion of a college degree Review courses taken in preparation for testing and exams College entrance and qualifying exams (ACT, SAT, GRE, LSAT) Non credited courses Equivalence exams; life experience credits Standardized tests to earn college credit by examination offered by the College

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• • • • •

Level Examination Program (CLEP) or other exams that waive a requirement Tools or supplies other than the required course materials Meals, lodging and transportation Fees for parking, cancellation, student activities, library, course changes, etc. Any expenses covered by a student loan, grant, scholarship, or any other form of financial aid

Voluntary Benefits Sun River Health may offer a selection of employee paid voluntary benefits through an external carrier; eligible employees may choose to participate at their discretion and at their cost. Eligibility may vary based on the type of voluntary benefit chosen.

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SECTION 11 EMPLOYEE SEXUAL AND OTHER HARASSMENT COMPLAINT FORM If you are aware of conduct which you believe violates Sun River Health’s policy against sexual and other harassment, you are encouraged to complete this form and submit it promptly to the Chief Executive Officer, Chief Operations Officer, or Human Resources. You are not required to use this form to report suspected violations of Sun River Health policy. You may instead report the situation verbally or in another manner if you are more comfortable doing so. Please be as specific as possible in responding to the following questions, to facilitate Sun River Health’s investigation of the events giving rise to your concerns. 1. Your full name, job title, and primary work location 2. Your supervisor’s name 3. Please identify the individual(s) against whom this complaint is made, and their relationship to you (e.g., supervisor, subordinate, coworker, or third party) 4. Date(s) conduct in question occurred 5. Is the conduct continuing? Yes No 6. Please describe the conduct or incident(s) that is the basis of this complaint and your reasons for concluding that the conduct constitutes a violation of Sun River Health policy. Please use additional sheets of paper if necessary and attach any relevant documents or evidence 7. Have you previously complained about the conduct that you have described in response to Question #6 above? If so, to whom did you complain, and when? 8. Please list the name and contact information of any witnesses or individuals who may have information related to your complaint 9. Please provide a phone number and/or email address at which you can be reached regarding this matter By signing and submitting this complaint form, you certify that the information you have provided above is true and accurate to the best of your knowledge. Providing knowingly false information in connection with a complaint may result in corrective action. Date: ____________________ Signature: ________________

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EMPLOYEE ACKNOWLEDGMENT By signing below, I acknowledge that I have received and read a copy of Sun River Health’s Resource and Guidelines for Employees (Resource Guide). I understand that the policies set forth certain terms and conditions of my employment as well as the duties, responsibilities, and obligations of employment with Sun River Health. I agree to abide by and be bound by the rules, policies and standards set forth in the Resource Guide. This Resource Guide supersedes any prior resource guide, handbook, policies, memos, and notices of Sun River Health and should only be considered as general guidelines and information. To meet the needs of our clients and respond to the ever-changing environment in which we work, Sun River Health may at any time amend, supplement, modify, deviate from, or eliminate one or more of the benefits or policies described in this Resource Guide, or any other employment benefits, procedures, or policies (except for the at-will employment policy set forth below), with or without prior notice, at the sole discretion of Sun River Health most effectively. We will make every effort to communicate any changes to you in a timely manner. Actual plan documents are the final authority on all matters relating to benefits. Eligibility for coverage or benefits shall be determined in accordance with the plan provisions and applicable law. At-Will Employment This Resource Guide does not constitute a contract of employment and does not guarantee any fixed terms and conditions of employment. There is no promise of any kind by the organization contained in this Resource Guide; your employment is based on a voluntary employment-at-will relationship. Accordingly, this Resource Guide does not constitute a guarantee that your employment will continue for any specified period or end only under certain conditions, and nothing in this booklet constitutes an express or implied contract of employment or warranty of any benefits. This means that you retain the right to terminate your employment with Sun River Health for any reason and at any time. Likewise, Sun River Health reserves the right to end your employment at any time, with or without cause and with or without notice. No one has the authority to bind Sun River Health to any agreement contrary to the foregoing except the CEO or designee. Any such agreement must be in writing and signed by the CEO or designee and the employee(s) to whom the agreement applies or the employee(s) authorized representative.

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Interpretation Nothing in this Resource Guide will be interpreted in a manner inconsistent with applicable federal, state, and local laws. Employees who work in positions covered by a collective bargaining agreement will receive a copy of the applicable collective bargaining agreement from the union representative and should note the employee rights and responsibilities contained in that agreement. In the event of a conflict between a provision of this Resource Guide and the collective bargaining agreement, the terms of the collective bargaining agreement shall govern. Nothing in this Resource Guide is intended to unlawfully restrict an employee’s right to engage in any of the rights guaranteed them by Section 7 of the National Labor Relations Act, including but not limited to, the right to engage in concerted protected activity for the purposes of their mutual aid and/or protection. Nothing in this Employee Handbook will be interpreted, applied, or enforced to interfere with, restrain or coerce employees in the exercise of their Section 7 rights. ___ (Initial) I acknowledge that I have read and understand the Electronic Resources Policy. To the extent I have any questions, I shall contact the Human Resources Department. ___ (Initial) I acknowledge that I have read and understand the Sexual and Other Harassment is Prohibited Policy. To the extent I have any questions, I shall contact the Human Resources Department. ____________________________ Employee Signature

___________________ Date

____________________________ Print Name

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Sun River Health Employee Handbook

Articles inside

DisciplinaryAction

Sexual and Other Harassment is Prohibited

Workplace Violence Defined

Americans with Disabilities Act

Separation from Employment

Policy Against Retaliation

Investigations and Enforcement