1.1 This Drug-Free Workplace Policy is established in compliance with the Drug-Free Workplace Act of 1988 (41 U.S.C. §8101–8106), which requires federal contractors and grantees to maintain a drug-free workplace as a condition of receiving federal contracts or grants. The policy is also designed to comply with applicable state and local drug-free workplace laws, the Controlled Substances Act (21 U.S.C. §801 et seq.), and the regulations of the U.S. Department of Transportation (49 CFR Part 40) where applicable to safety-sensitive positions. The Organization is committed to maintaining a workplace that is free from the unlawful manufacture, distribution, dispensation, possession, or use of controlled substances, and to providing a safe, healthy, and productive working environment for all employees.

1.2 This policy applies to all employees of the Organization who perform work under, in connection with, or at a workplace where work is performed under any federal contract or grant subject to the Drug-Free Workplace Act of 1988. The Organization extends the scope of this policy to all employees across all locations, regardless of whether they are directly engaged in federally funded work, to ensure consistent standards and a uniformly safe working environment. The policy covers all Organization-owned, leased, or managed premises, Organization vehicles, and any off-site location where the employee is performing work on behalf of the Organization. Contractors, subcontractors, and temporary staff performing work on Organization premises or in connection with federal contracts shall be contractually required to maintain equivalent drug-free workplace standards.

1.3 In compliance with the requirements of the Drug-Free Workplace Act of 1988, the Organization shall publish this policy statement and distribute it to every employee engaged in the performance of any federal contract or grant, notifying them that the unlawful manufacture, distribution, dispensation, possession, or use of a controlled substance is prohibited in the Organization's workplace, and specifying the actions that will be taken against employees who violate this prohibition. The Organization shall establish a drug-free awareness program to inform employees about the dangers of drug abuse in the workplace, the Organization's policy of maintaining a drug-free workplace, the availability of drug counselling, rehabilitation, and employee assistance programs, and the penalties that may be imposed upon employees for drug abuse violations occurring in the workplace.

2.1 In accordance with the Drug-Free Workplace Act of 1988, the unlawful manufacture, distribution, dispensation, possession, or use of a controlled substance, as defined in Schedules I through V of the Controlled Substances Act (21 U.S.C. §812), is strictly prohibited in the Organization's workplace. Additionally, reporting to work, performing duties, operating Organization vehicles or equipment, or representing the Organization while under the influence of any controlled substance that impairs the employee's ability to perform their job safely and effectively is prohibited. This prohibition extends to the misuse of prescription medications, including the use of prescription drugs not prescribed to the employee, the use of prescribed medications in a manner inconsistent with the prescription, and the failure to notify the employer of the use of prescription medications that may affect job performance or safety.

2.2 Employees are prohibited from engaging in any drug-related criminal activity, including the manufacture, sale, purchase, transfer, or possession of illegal drugs or controlled substances, whether on or off the Organization's premises, where such activity results in a criminal conviction that could affect the employee's ability to perform their job, the safety of colleagues, clients, or the public, or the Organization's reputation, contractual obligations, or ability to maintain federal contracts or grants. A conviction for a drug-related offence occurring in the workplace shall be reported by the employee as required under the notification provisions of this policy. The Organization reserves the right to take appropriate disciplinary action, up to and including termination, for off-duty drug-related criminal conduct where it has a demonstrable nexus to the employee's employment.

2.3 The Organization reserves the right to conduct searches of Organization-owned property, including desks, lockers, file cabinets, Organization vehicles, and common areas, where there are reasonable grounds to believe that prohibited controlled substances are present on the premises in violation of this policy. Searches shall be conducted by the Security department or an authorised representative, with the involvement of the HR department, and shall be documented in writing. Personal belongings brought onto Organization premises, including bags, containers, and personal vehicles parked on Organization property, may be subject to search with the employee's consent. Employees who refuse to consent to a search of personal belongings may be subject to disciplinary action. All searches shall be conducted in compliance with applicable federal and state constitutional protections and privacy laws.

3.1 In accordance with Section 8102 of the Drug-Free Workplace Act of 1988, each employee engaged in the performance of any federal contract or grant shall, as a condition of employment, agree to abide by the terms of this policy and shall notify the Organization in writing of any criminal drug statute conviction for a violation occurring in the Organization's workplace no later than 5 calendar days after such conviction. The notification shall be made to the employee's manager and the HR department. Upon receiving such notification, the Organization shall notify the contracting or granting agency within 10 calendar days of receiving the employee's notice, in compliance with the requirements of the Act. Failure by an employee to provide timely notification of a conviction shall itself constitute a violation of this policy and grounds for disciplinary action, including termination.

3.2 In accordance with the Drug-Free Workplace Act of 1988, within 30 calendar days of receiving notice of an employee's criminal drug statute conviction for a workplace violation, the Organization shall take appropriate personnel action against the employee, up to and including termination, or shall require the employee's satisfactory participation in a drug abuse assistance or rehabilitation program approved for such purposes by a federal, state, or local health, law enforcement, or other appropriate agency. The determination of whether to pursue disciplinary action, rehabilitation, or a combination of both shall be made by the HR department in consultation with Legal Counsel, taking into account the nature of the offence, the employee's role, their performance and disciplinary history, the safety implications of their position, and the Organization's obligations under applicable law and its federal contracts or grants.

3.3 All employees shall sign a written acknowledgement confirming that they have received, read, and understood this Drug-Free Workplace Policy; that they agree to abide by the terms of the policy as a condition of their employment; that they agree to notify the Organization of any criminal drug statute conviction for a violation occurring in the workplace within 5 calendar days of such conviction; and that they understand the disciplinary consequences of violating this policy. The signed acknowledgement shall be maintained in the employee's personnel file. New employees shall complete the acknowledgement as part of the onboarding process. Existing employees shall be required to execute a new acknowledgement whenever the policy is materially amended. Failure or refusal to sign the acknowledgement shall not exempt the employee from the requirements of this policy but may itself be treated as grounds for disciplinary action.

4.1 The Organization may conduct drug testing in compliance with applicable federal and state laws, including the Department of Transportation regulations (49 CFR Part 40) for employees in safety-sensitive positions. Testing categories include pre-employment testing for candidates who have accepted a conditional offer of employment for designated positions; reasonable-suspicion testing based on documented, specific, objective observations by a trained supervisor; post-accident testing following a workplace accident or incident where drug use may have been a contributing factor; random testing for employees in positions designated as safety-sensitive under DOT regulations or other applicable federal or state requirements; return-to-duty testing for employees who have completed a substance abuse rehabilitation program; and follow-up testing for employees who have returned to duty following treatment. All testing shall be conducted by a SAMHSA-certified laboratory using approved testing methodologies and chain-of-custody procedures.

4.2 All positive test results shall be reviewed and verified by a qualified Medical Review Officer (MRO) before any disciplinary or administrative action is taken. The MRO shall contact the employee to determine whether there is a legitimate medical explanation for the positive result, such as a valid prescription for the detected substance. If the MRO determines that a legitimate medical explanation exists, the test shall be reported as negative. If the positive result is verified by the MRO, the employee shall be notified and shall have the right to request a confirmatory test of the split specimen at a second SAMHSA-certified laboratory at the employee's expense, which shall be reimbursed if the confirmatory test is negative. The employee shall have 72 hours from notification of the verified positive result to request a split specimen test.

4.3 An employee's refusal to submit to a drug test that is required under this policy, failure to appear at the designated collection site within the prescribed timeframe, failure to provide an adequate specimen without a verified medical explanation, submission of a specimen that is determined to be adulterated, substituted, or tampered with, or any other conduct that obstructs or undermines the integrity of the testing process shall be treated as equivalent to a verified positive test result. Refusal or obstruction shall be subject to the same disciplinary consequences as a verified positive test, up to and including immediate termination. The employee shall be immediately removed from safety-sensitive duties and shall not be permitted to perform any functions subject to DOT regulations or federal contract requirements until the matter is resolved. The incident shall be documented in writing and maintained in the employee's personnel file.

5.1 The Organization provides access to an Employee Assistance Program (EAP) that offers confidential assessment, short-term counselling, and referral to specialised substance abuse treatment providers. Employees who voluntarily self-refer to the EAP for assistance with a substance abuse problem before the occurrence of a policy violation, a workplace incident, or a positive drug test shall not be subject to disciplinary action solely on the basis of their self-disclosure, provided they comply with the recommended treatment plan, meet ongoing performance and safety expectations, and do not engage in further policy violations. Self-referral does not exempt an employee from the consequences of prior conduct or from any ongoing testing requirements. The Organization shall also provide information about community-based substance abuse treatment and counselling resources as part of its drug-free awareness program.

5.2 Violations of this Drug-Free Workplace Policy shall result in disciplinary action proportionate to the nature and severity of the violation, up to and including immediate termination of employment. Mandatory termination shall apply for the sale, manufacture, or distribution of controlled substances in the workplace, a second verified positive drug test, and refusal to participate in or complete a required rehabilitation program. For a first-time verified positive test, the Organization may, in its discretion and depending on the circumstances, offer the employee the opportunity to retain employment conditioned upon successful completion of a rehabilitation program, execution of a last-chance agreement, and submission to follow-up testing for a period of not less than 24 months. The Organization shall report all required information to the applicable contracting or granting federal agency within the timeframes mandated by the Drug-Free Workplace Act of 1988.

5.3 This policy shall be reviewed comprehensively at least once every 12 months by the HR department in consultation with Legal Counsel, the Safety department, and the Organization's federal contracts and grants management function. Reviews shall ensure continued compliance with the Drug-Free Workplace Act of 1988, the DOT testing regulations (49 CFR Part 40), applicable state and local drug-free workplace and drug testing laws, and any changes in the Organization's federal contracting or grant portfolio that may affect the policy's scope or requirements. All employees shall receive drug-free workplace awareness training as part of the onboarding process and on an annual basis thereafter, covering the requirements of this policy, the dangers of drug abuse, the available employee assistance resources, and the disciplinary consequences of policy violations. Supervisors shall receive additional training on reasonable-suspicion identification and documentation. Training records shall be maintained by the HR department and made available for review during federal contract or grant audits.