1.1 This Substance Abuse Policy establishes the Organization's expectations regarding the use, possession, distribution, and misuse of alcohol, illegal drugs, controlled substances, prescription medications, and other intoxicating substances in connection with employment. The policy is designed to promote a safe, healthy, and productive work environment, protect the well-being of all employees and third parties, ensure compliance with applicable laws and regulations, and provide a supportive framework for employees who acknowledge substance-related difficulties and seek assistance. The Organization recognises that substance abuse is a treatable condition and is committed to balancing compassion and support with the legitimate need to maintain workplace safety and performance standards.

1.2 This policy applies to all employees, officers, directors, contractors, temporary staff, interns, and visitors while on Organization premises, in Organization vehicles, at work-related events and functions, and during working hours, including periods of remote work. The policy applies regardless of the individual's location when the substance use affects or could reasonably be expected to affect their job performance, workplace safety, the Organization's reputation, or the safety of others. For positions that are designated as safety-sensitive, additional requirements, including pre-employment and random testing where legally permissible, may apply as specified in the relevant role-specific addendum.

1.3 The HR department shall be responsible for administering this policy, providing guidance to managers and employees, coordinating referrals to the Employee Assistance Program, managing any testing processes in compliance with applicable law, and ensuring that all substance-related matters are handled with confidentiality, sensitivity, and respect for the individual's dignity. The HR department shall work in partnership with the Organization's occupational health provider and the Employee Assistance Program to ensure that employees have access to appropriate assessment, treatment, and rehabilitation services. All records related to substance abuse disclosures, testing, and treatment shall be maintained separately from the general personnel file and accessed only by authorised personnel on a strict need-to-know basis.

2.1 Employees shall not report to work, perform their duties, operate Organization vehicles or equipment, or represent the Organization in any capacity while under the influence of alcohol, illegal drugs, controlled substances not prescribed to the individual, or any substance, including prescription or over-the-counter medication, that impairs their ability to perform their role safely, competently, and effectively. An employee shall be deemed to be under the influence when their physical or mental faculties are observably impaired, or when the results of a lawfully administered test exceed the thresholds established by the Organization or applicable law. Employees who are prescribed medication that may affect their performance or safety shall notify their manager and the HR department in confidence so that appropriate temporary adjustments can be made.

2.2 The use, possession, sale, transfer, distribution, or manufacture of illegal drugs or controlled substances not prescribed to the individual on Organization premises, in Organization vehicles, or during any work-related activity is strictly prohibited. This prohibition extends to drug paraphernalia and any substance that is illegal under applicable federal, state, or local law. Violations of this provision shall result in immediate disciplinary action, which may include summary dismissal, and may also be reported to appropriate law enforcement authorities. The Organization reserves the right to conduct searches of Organization premises, lockers, desks, vehicles, and bags where there are reasonable grounds to believe that prohibited substances are present, in compliance with applicable search and privacy laws.

2.3 The consumption of alcohol during working hours, on Organization premises, or at client sites is prohibited unless expressly authorised by senior management at Organization-sponsored events, client entertainment functions, or business meals. Where alcohol is provided at authorised events, employees are expected to consume responsibly, remain professional in their conduct, and ensure they are fit to perform any subsequent duties, including driving, operating equipment, or returning to work. The Organization shall ensure that non-alcoholic alternatives are readily available at all events where alcohol is served. Managers are responsible for monitoring the consumption of alcohol at events under their authority and for intervening where an employee's conduct becomes unsafe, inappropriate, or disruptive.

3.1 The Organization may conduct substance testing in accordance with and to the extent permitted by applicable federal, state, and local laws. Testing may be conducted in the following circumstances: pre-employment testing for candidates who have accepted a conditional offer for safety-sensitive positions; reasonable-suspicion testing where a trained manager or supervisor has documented specific, objective observations indicating that an employee may be under the influence of a prohibited substance; post-incident testing following a workplace accident, injury, or near-miss where substance impairment may have been a contributing factor; and return-to-duty and follow-up testing for employees who have completed a rehabilitation program and are returning to work. All testing shall be conducted by a certified laboratory using validated methodologies, and chain-of-custody procedures shall be strictly followed.

3.2 Reasonable-suspicion testing shall be initiated only where a trained manager or supervisor has observed and documented specific, objective facts and circumstances that would lead a reasonable person to believe that an employee is under the influence of a prohibited substance. Observable indicators may include, but are not limited to, slurred speech, impaired coordination or balance, unusual behavior or mood swings, the odour of alcohol or drugs, bloodshot or glazed eyes, disorientation, or a marked decline in performance or attentiveness. The observing manager shall document their observations in writing and consult with the HR department before directing the employee to undergo testing. The employee shall be relieved of their duties and provided with transportation to the testing facility and home. No employee shall be permitted to drive themselves if there are reasonable grounds to believe they are impaired.

3.3 Employees who refuse to submit to a substance test that is lawfully required under this policy, who fail to appear at the designated testing facility within the prescribed timeframe, who attempt to tamper with, adulterate, or substitute a test sample, or who obstruct or refuse to cooperate with the testing process shall be deemed to have committed a policy violation equivalent to a positive test result. Such refusal or obstruction shall be subject to disciplinary action up to and including termination of employment. The HR department shall inform the employee of the consequences of refusal before the test is administered and shall document the refusal or obstruction in writing. Employees shall have the right to request a confirmatory test of a split sample where a positive result is reported.

4.1 The Organization encourages employees who are experiencing substance-related difficulties to seek help voluntarily and proactively. The Organization's Employee Assistance Program provides confidential assessment, short-term counselling, and referral to specialised treatment providers at no cost to the employee. Employees who voluntarily self-refer to the EAP before their substance use results in a policy violation, a workplace incident, or a positive test shall not be subject to disciplinary action solely on the basis of their disclosure, provided they comply with the recommended treatment plan and meet ongoing performance and safety expectations. Self-referral does not exempt an employee from the consequences of conduct that has already occurred or from the requirement to comply with all provisions of this policy going forward.

4.2 Employees who undergo substance abuse treatment, whether through voluntary self-referral or as a condition of continued employment following a policy violation, may be eligible for a reasonable period of leave under the Organization's sick leave, medical leave, or disability accommodation policies, subject to applicable law. Upon completion of treatment, the employee shall participate in a structured return-to-work program developed by the HR department in consultation with the treatment provider and the employee's manager. The return-to-work program may include a return-to-duty substance test, a written last-chance agreement specifying the conditions of continued employment, a schedule of follow-up testing for a defined period, periodic check-ins with the HR department and the EAP, and any workplace accommodations recommended by the treatment provider that are reasonable and consistent with the Organization's operational needs.

4.3 All information relating to an employee's substance abuse disclosure, testing results, treatment participation, and rehabilitation progress shall be treated as strictly confidential medical information and shall be protected in accordance with applicable privacy, disability, and medical records laws. Such information shall be maintained in a separate, secure file, distinct from the employee's general personnel record, and shall be accessible only to those with a legitimate need to know, including the HR representative managing the case, the employee's treating provider, and, where necessary, the employee's direct manager to the extent required to implement workplace adjustments. Unauthorised disclosure of substance abuse information shall constitute a serious policy violation and may result in disciplinary action. The Organization shall ensure that any external testing laboratories, EAP providers, and treatment facilities are contractually bound to equivalent confidentiality standards.

5.1 Violations of this policy shall result in disciplinary action proportionate to the nature, severity, and circumstances of the violation. A first-time positive test result or incident of impairment may, depending on the circumstances and the employee's willingness to engage with treatment, result in a formal written warning, mandatory EAP referral, and a last-chance agreement rather than immediate termination. However, certain violations, including the sale, distribution, or manufacture of illegal drugs on Organization premises, reporting to work impaired in a safety-sensitive role, causing a workplace accident or injury while impaired, and refusal to submit to a required test, shall be grounds for immediate termination. Repeat violations following a last-chance agreement shall also result in termination. All disciplinary actions shall be documented and reviewed by the HR department for consistency and legal compliance.

5.2 This policy shall be reviewed comprehensively at least once every 12 months by the HR department in consultation with Legal Counsel, the occupational health provider, and the EAP. Reviews shall assess the policy's effectiveness based on incident data, testing results, EAP utilization rates, and feedback from managers and employees. All employees shall receive substance abuse awareness training as part of the onboarding process and on an annual basis. Training shall cover the key provisions of this policy, the prohibited conduct and potential consequences, the available support and rehabilitation resources, the signs and symptoms of substance impairment, and the employee's rights and obligations under applicable law. Managers and supervisors shall receive additional training on reasonable-suspicion documentation, the referral process, and their role in supporting employees who are undergoing treatment.