JUNE 2018

EMPLOYEE HANDBOOK
 WHAT TO EXPECT ON YOUR FIRST DAY

You are required to acknowledge receipt of this handbook. Please read and understand it (or ask questions
if you do not fully understand any provision) on your first day of work, or upon receipt of this handbook.

Specific information about your job and the chain of command is provided below for your reference. This
page should be left in your handbook and kept with you for future reference.

Your Job Title ______________________________________________________

Your Immediate Supervisor ___________________________________________

Your Department ____________________________________________________

Your Department Director _____________________________________________

Your Executive Director ______________________________________________

Your Human Resources Director _______________________________________

Your Director of Nursing _____________________________________________

Your Business Office Director _________________________________________

Your Environmental Services Director ___________________________________

Your Dietary Services Director _________________________________________

Your Marketing Director ______________________________________________

Your Activities Director ______________________________________________

Your First Pay Day __________________________________________________

Your Work Phone Number ____________________________________________

INSPIRIT SENIOR LIVING

EMPLOYEE HANDBOOK
JUNE 2018
Welcome to Inspirit Senior Living. Our
community is more than beautiful
surroundings and state-of-the-art care.

IT IS people.

INSPIRIT SENIOR LIVING

EMPLOYEE HANDBOOK
JUNE 2018
 EMPLOYEE HANDBOOK

CONTENTS
SECTION 1 SECTION 4
INTRODUCTION STANDARDS OF CONDUCT AND
EMPLOYEE PERFORMANCE
1.1 Welcome
1.2 Employee Handbook 4.1 Anti- Harassment and Discrimination
1.3 Open Door Policy 4.2 Attendance
1.4 Changes in Policy 4.3 Discipline and Standards of Conduct
1.5 Employment-At-Will 4.4 Dress Code
1.6 Arbitration Policy 4.5 Safety
1.7 Speaking for the Community 4.6 Loitering
4.7 Substance and Abuse
SECTION 2 4.8 Workplace Searches
EMPLOYMENT POLICIES 4.9 Internet, Email and Computer Use Policy
4.9 Social Media Policy
2.1 Employee Classifications 4.10 Cell Phone Policy
2.2 Equal Employment Opportunity & Americans
with Disabilities Act. SECTION 5
2.3 Confidentiality EMPLOYEE BENEFITS AND SERVICES
2.4 Employment of Minors
2.5 Employment of Relatives 5.1 Generally
2.6 Introductory Period 5.2 Group Health Insurance
2.7 Personnel Records and Employee References 5.3 Group Life Insurance
2.8 Privacy 5.4 401(k) Plan
2.9 Immigration Law Compliance 5.5 COBRA
2.10 Serious Illness or Injury 5.6 Worker’s Compensation
2.11 Political Neutrality 5.7 Social Security Benefits (FICA)
2.12 Resident Abuse 5.8 Unemployment Insurance
2.13 Job Postings of Vacant Positions 5.9 Additional Benefits
2.14 Criminal Background Checks
2.15 Disciplinary/Corrective Action SECTION 6
2.16 References EMPLOYEE LEAVES OF ABSENCE AND
2.17 Health Requirements TIME OFF

6.1 Generally
SECTION 3 6.2 Paid Time Off Days
HOURS OF WORK AND PAYROLL PRACTICES 6.3 Holidays
6.4 Family and Medical Leave
3.1 Pay Periods and Paydays 6.5 Workers’ Compensation Leave
3.2 Scheduling 6.6 Bereavement Leave
3.3 Overtime 6.7 Jury Duty
3.4 Rest and Meal Periods 6.8 Military Leave
3.5 Time Clock 6.9 Leave of Absence Policy
3.6 Deductions from Pay
3.7 Wage Garnishment
3.8 Direct Deposit
 EMPLOYEE HANDBOOK

CONTENTS
SECTION 7
CONCLUSION OF EMPLOYMENT

7.1 Resignation
7.2 Exit Interview
7.3 Return of Property
7.4 Final Pay Check
7.5 Abandonment of Job

SECTION 8
WORK RULES

8.1 Smoking/Tobacco Products and E-Cigarettes

8.2 Performance Management and Review
8.3 In-Service Training
8.4 No Solicitation
8.5 Tips and Gifts
8.6 Weekend Make-Up Policy
8.7 Weather Emergency
8.8 Change in Personal Data
8.9 Parking
8.10 Company and Resident Property
8.11 Telephone Calls/Cell Phones
8.12 Suggestions and Ideas
8.13 Fire Prevention
8.14 Personal Property
8.15 Travel Expense
SECTION 1
INTRODUCTION
1.1 Welcome
1.2 Employee Handbook
1.3 Open Door Policy
1.4 Changes in Policy
1.5 Employment-At-Will
1.6 Arbitration Policy
 WELCOME
1.1 WELCOME TO INSPIRIT SENIOR LIVING-LIVING YOUR BEST

Inspirit attracts and retains the best staff because we treat them as we do our residents, appreciating
their gifts, recognizing their goals, encouraging their dreams. At every stage in life, we all have needs,
but also gifts to share. So instead of focusing on problems and symptoms, Inspirit Senior Living focuses
on potential and dreams. We are committed to building communities on the bedrock of integrity,
compassion, and creativity so that all Inspirit residents and staff can live their best lives and so their
gifts can flourish. I founded Inspirit Senior Living with the ambitious and clear vision: nothing less than
to transform the experience of aging in this country.

WELCOME! DAVE MCHARG

1.2 EMPLOYEE HANDBOOK

This Employee Handbook (“Handbook”) is designed to summarize certain personnel policies and benefits of
Inspirit Senior Living (the “Company”), of 11350 Random Hills Drive, Suite 800, Fairfax, Virginia 22030, and
to acquaint employees with many of the rules concerning employment with the Company. This Handbook
applies to all employees, and compliance with the Company’s policies is a condition of employment. This
Handbook supersedes all previous employment policies, written and oral, express and implied. The Company
reserves the right to modify, rescind, delete, or add to the provisions of this Handbook from time to time in
its sole and absolute discretion. This Employee Handbook is not a binding contract between the Company
and its employees, nor is it intended to alter the at-will employment relationship between the Company and
its employees. The Company reserves the right to interpret the policies in this Handbook and to deviate
from them when, in its discretion, it determines it is appropriate.

1.3 OPEN DOOR POLICY

It is the desire of Inspirit Senior Living to provide pleasant working conditions and make the work of the
staff member a rewarding experience. If a problem should arise which merits a complaint or correction, you
are urged to report the matter to your immediate supervisor. Most problems can be corrected promptly
if they are discussed frankly with the person in charge of your service or responsible for your assignment.
If after speaking with your supervisor you are not satisfied, you may go to the Executives Director. This is
called, The Chain of Command. All supervisors are to be open to every reasonable expression of concern
by staff members, residents, and the public.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 1

 1.4 CHANGES IN POLICY

Since our business is constantly changing, the Company expressly reserves the right to revise, modify,
delete, or add to any and all policies, procedures, work rules, or benefits stated in this handbook or in any
other document, except for the policy of at-will employment as described below. No oral statements or
representations can in any way alter the provisions of this Handbook. Nothing in this employee handbook
or in any other document, including benefit plan descriptions, creates or is intended to create a promise
or representation of continued employment for any employee. Any changes to your at-will employment
status, described below, must be in writing and must be signed by the Company. If you are uncertain about
any policy or procedure, please check with your manager or Human Resources.

1.5 EMPLOYMENT-AT-WILL

Employment with the Company is on an at-will basis, unless otherwise specified in a written employment
agreement. You are free to resign at any time, for any reason, with or without notice. Similarly, the Company
is free to conclude the employment relationship at any time for any lawful reason, with or without cause,
and with or without notice.

Nothing in this Handbook will limit the right of either party to terminate an at-will employment. No section
of this Handbook is meant to be construed, nor should be construed, as establishing anything other than an
employment-at-will relationship. This Handbook does not limit management’s discretion to make personnel
decisions such as reassignment, change of wages and benefits, demotion, etc. No person other than the CEO,
President, or CFO has the authority to enter into an agreement for employment for any specified period of
time or to make an agreement for employment other than at-will terms. Only the CEO, President, or CFO
of the Company has the authority to make any such agreement, which is only binding if it is in writing and
signed by the President of the Company.

1.6 ARBITRATION POLICY

In consideration of your employment with Inspirit Senior Living, its promise to arbitrate all employment-
related disputes, and your receipt of the compensation, pay raises, and other benefits paid to you by the
company, at present and in the future, you agree that any and all controversies, claims, or disputes with
anyone (including the company and any employee, officer, director, or benefit plan of the company, in their
capacity as such or otherwise), whether brought on an individual, group, or class basis, arising out of, relating
to, or resulting from your employment with Inspirit Senior Living or the termination of your employment
with the company, including any breach of this agreement, shall be subject to binding arbitration under the
terms and conditions set forth in the at-will employment, confidential information, invention assignment,
and arbitration agreement between you and Inspirit Senior Living (or such other confidentiality agreement
between you and the company, each the “confidentiality agreement”). In the event the confidentiality
agreement between you and Inspirit Senior Living does not contain an arbitration provision, then you
nevertheless agree to arbitrate any and all claims set forth above in a neutral, mutually agreeable forum
according to the applicable minimum standards for arbitration.

2 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 1.7 SPEAKING FOR THE COMMUNITY

It is the goal of Inspirit Senior Living to maintain a positive public image. In the event, you are faced with
negative attention from the news media you are not to communicate with reporters. Please respond with
the following: “I am not authorized to comment for Inspirit Senior Living, let me have our Executive Director
contact you.” In the event the reporter is questioning the Executive Director; the Executive Director will
also report the he/she is not authorized to comment and will contact the Regional Director of Operations
immediately. The Executive Director will inform the reporter that someone from the corporate office will
make a statement.

All requests for a reference for either a current or past employee must be directed to either the Business
Office Manager or the Executive Director. No other employee or supervisor is authorized to give a reference.
References will only be given on position held and dates of employment. Violating this policy may result
in corrective action up to and including termination.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 3

SECTION 2
EMPLOYMENT
POLICIES
2.1 Employee Classifications
2.2 Equal Employment Opportunity & Americans
with Disabilities Act.
2.3 Confidentiality
2.4 Employment of Minors
2.5 Employment of Relatives
2.6 Introductory Period
2.7 Personnel Records and Employee References
2.8 Privacy
2.9 Immigration Law Compliance
2.10 Serious Illness or Injury
2.11 Political Neutrality
2.12 Resident Abuse
2.13 Job Postings of Vacant Positions
2.14 Criminal Background Checks
2.15 Disciplinary/Corrective Action
2.16 References
2.17 Health Requirements
 2.1 EMPLOYEE CLASSIFICATIONS

The following terms are used to describe employees and their employment status:

Exempt Employees - Employees whose positions meet specific tests established by the Federal Labor
Standards Act (“FLSA”) and Virginia state law. In general, exempt employees are those engaged in executive,
managerial, high-level administrative and professional jobs who are paid a fixed salary and perform certain
duties. In addition, certain commissioned sales employees and highly paid computer professionals are
exempt. Exempt employees are not subject to the minimum wage and overtime laws.

Nonexempt Employees - Employees whose positions do not meet specific tests established by the FLSA
and Virginia state law. All employees who are covered by the federal or state minimum wage and overtime
laws are considered nonexempt. Employees working in nonexempt jobs are entitled to be paid at least the
minimum wage per hour and a premium for overtime.

Full-Time Employees - Employees who are not temporary employees, independent contractors, or
independent consultants and who are regularly scheduled to work a schedule of 30 hours per work week.

Part-Time Employees - Employees who are not temporary employees, independent contractors, or
independent consultants and who are regularly scheduled to work less than 30 hours per work week.

Temporary Employees - Employees who are hired as interim replacements to temporarily supplement
the workforce or to assist in the completion of a specific project. Employment assignments in this category
are of limited duration and the temporary employee can be let go before the end of the defined period.
Short term assignments generally are periods of three (3) months or less, however, such assignments may
be extended. All Temporary employees are at-will regardless of the anticipated duration of the assignment
(see Employment-at-Will Policy). Temporary employees retain that status unless and until notified in writing
of a change.

Independent Contractor or Consultant - These individuals are not employees of the Company and are
self-employed. An independent contractor or consultant is engaged to perform a task according to his/her
own methods and is subject to control and direction only as to the results to be accomplished. Independent
contractors or consultants are not entitled to benefits.

Each employee will be advised of his or her status at the time of hire and any change in status. Regardless of
the employee’s status, the employee is employed at-will and the employment relationship can be terminated
by the Company or the employee at any time, with or without cause and with or without notice.

2.2 EQUAL EMPLOYMENT OPPORTUNITY & AMERICANS WITH DISABILITIES ACT.

It is the policy of the Company to provide equal employment opportunities to all employees and employment
applicants without regard to unlawful considerations of race, religion, creed, color, national origin, sex,
pregnancy, sexual orientation, gender identity, age, ancestry, physical or mental disability, genetic information,
marital status or any other classification protected by applicable local, state or federal laws. This policy
prohibits unlawful discrimination based on the perception that anyone has any of those characteristics,
or is associated with a person who has or is perceived as having any of those characteristics. This policy
applies to all aspects of employment, including, but not limited to, hiring, job assignment, working conditions,

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 5

 compensation, promotion, benefits, scheduling, training, discipline and termination.

The Company expects all employees to support our equal employment opportunity policy, and to take
all steps necessary to maintain a workplace free from unlawful discrimination and harassment and to
accommodate others in line with this policy to the fullest extent required by law. For example, the Company
will make reasonable accommodations for employees’ observance of religious holidays and practices unless
the accommodation would cause an undue hardship on the Company’s operations. If you desire a religious
accommodation, you are required to make the request in writing to your manager as far in advance as
possible. You are expected to strive to find co-workers who can assist in the accommodation (e.g. trade
shifts) and cooperate with the Company in seeking and evaluating alternatives.

Moreover, in compliance with the Americans with Disabilities Act (ADA), the Company provides reasonable
accommodations to qualified individuals with disabilities to the fullest extent required by law. The Company
may require medical certification of both the disability and the need for accommodation. Keep in mind that the
Company can only seek to accommodate the known physical or mental limitations of an otherwise qualified
individual. Therefore, it is your responsibility to come forward if you are in need of an accommodation. The
Company will engage in an interactive process with the employee to identify possible accommodations, if
any will help the applicant or employee perform the job.

2.3 CONFIDENTIALITY.

In the course of employment with the Company, employees may have access to “Confidential Information”
regarding the Company, which may include its business strategy, future plans, financial information,
contracts, suppliers, customers, personnel information or other information that the Company considers
proprietary and confidential. Maintaining the confidentiality of this information is vital to the Company’s
competitive position in the industry and, ultimately, to its ability to achieve financial success and stability.
Employees must protect this information by safeguarding it when in use, using it only for the business of
the Company and disclosing it only when authorized to do so and to those who have a legitimate business
need to know about it. This duty of confidentiality applies whether the employee is on or off the Company’s
premises, and during and even after the end of the employee’s employment with the Company. This duty of
confidentiality also applies to communications transmitted by the Company’s electronic communications.
See also Internet, Email and Computer Use policy, herein.

As a condition of employment with the Company, all employees must sign a Non-Disclosure Agreement.

2.4 EMPLOYMENT OF MINORS.

The FLSA’s child labor provisions, which the Company strictly adheres to, are designed to protect the
educational opportunities of youth and prohibit their employment in jobs that are detrimental to their
health and safety. Generally speaking, the FLSA sets the minimum age for employment (14 years for non-
agricultural jobs), restricts the hour’s youth under the age of 16 may work, and prohibits youth under the
age of 18 from being employed in hazardous occupations. In addition, the FLSA establishes subminimum
wage standards for certain employees who are less than 20 years of age, full-time students, student
learners, apprentices, and workers with disabilities. Employers generally must have authorization from the
U.S. Department of Labor’s Wage and Hour Division (WHD) in order to pay sub-minimum wage rates. It is
the policy of Inspirit Senior Living to prohibit employment of minors 16 and under.

6 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 2.5 EMPLOYMENT OF RELATIVES.

The Company recognizes that the employment of relatives in certain circumstances, such as when they will
work in the same department, supervise or manage the other, or have access to confidential or sensitive
information regarding the other, can cause problems related to supervision, safety, security or morale, or
create conflicts of interest that materially and substantially disrupt the Company’s operations. When the
Company determines any of these problems will be present, it will decline to hire an individual to work in
the same department as a relative. Relatives subject to this policy include: father, mother, sister, brother,
current spouse or domestic partner, child (natural, foster, or adopted), current mother-in- law, current
father-in-law, grandparent, or grandchild.

If present employees become relatives during employment, the Company should be notified so that we may
determine whether a problem involving supervision, safety, security or morale, or a conflict of interest that
would materially and substantially disrupt the Company’s operations exists. If the Company determines that
such a problem exists, the Company will take appropriate steps to resolve the problem, which may include
reassignment of one relative (if feasible) or asking for the resignation of one of the relatives.

2.6 INTRODUCTORY PERIOD.

The first 90 days of employment are considered an introductory period for all newly hired employees. During
this time, you will learn your new responsibilities, get acquainted with fellow employees, and determine
whether you are happy with the position. Also, during this time, your manager will monitor your performance.
Upon completion of the introductory period, your manager will review your performance. If the Company
finds your performance satisfactory and decides to continue your employment, you will be advised of any
improvements expected. This is also an opportunity for you to make suggestions to improve the Company’s
efficiency and operations. Completion of the introductory period does not entitle you to remain employed
by the Company for any definite period of time, but instead allows both you and the Company to evaluate
whether or not you are right for the position. Your status as an at-will employee does not change-the
employment relationship may be terminated with or without cause and with or without advance notice, at
any time by you or the Company.

2.7 PERSONNEL RECORDS AND EMPLOYEE REFERENCES.

The Company maintains a personnel file and payroll records for each employee as required by law. Personnel
files and payroll records are the property of the Company and may not be removed from Company premises
without written authorization. Because personnel files and payroll records are confidential, access to
the records is restricted. Generally, only those who have a legitimate reason to review information in an
employee’s file are allowed to do so. Disclosure of personnel information to outside sources will be limited.
However, the Company will cooperate with requests from authorized law enforcement or local, state, or
federal agencies conducting official investigations and as otherwise legally required.

Employees may contact a Human Resources representative to request a time to review their payroll records
and/or personnel file. With reasonable advance notice, an employee may review his or her own records in
the Company’s offices during regular business hours and in the presence of an individual appointed by the
Company to maintain the records. No copies of documents in your file may be made, with the exception of
documents that you have previously signed. You may add your comments to any disputed item in the file.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 7

 By policy, the Company will provide only the former or present employee’s dates of employment and
position(s) held with the Company. Compensation information may also be verified if written authorization
is provided by the employee.

2.8 PRIVACY.

The Company is respectful of employee privacy. All employee demographic and personal information will
be shared only as required in the normal course of business. Healthcare enrollment information is kept in a
separate folder from other human resources forms. Workers’ Compensation information is not considered
private healthcare information; however, this information will be released only on a need-to-know basis.

The Company does not make or receive any private healthcare information through the course of normal
work. If any employee voluntarily shares private healthcare information with a member of management,
this information will be kept confidential. If applicable, the Company will set up guidelines for employees
and management to follow to ensure that company employees conform to the requirements of the Health
Insurance Portability and Accountability Act (HIPAA).

2.9 IMMIGRATION LAW COMPLIANCE.

In compliance with the Immigration Reform and Control Act of 1986, each new employee, as a condition
of employment, must complete the Employment Eligibility Verification Form I-9 on the date of hire and
present documentation establishing identity and employment eligibility within three business days of date
of hire. Former employees who are rehired must also complete an I-9 form if they have not completed an
I-9 form with the Company within the past three years, or if their previous I-9 form is no longer retained
or valid. You may raise questions or complaints about immigration law compliance without fear of reprisal.

2.10 SERIOUS ILLNESSES OR INJURIES

There will be times when employees face extremely serious conditions. As with other disabilities, we will
offer you reasonable accommodations to let you perform the essential functions of your position as long
as it doesn’t cause undue hardship to Inspirit Senior Living. Employees should provide documentation
from their physician stating that they are able to work “full duty” based upon the ADA section of their job
description as it pertains to personal injuries or illnesses. Inspirit Senior Living also prohibits discrimination
or harassment against individuals with a serious illness or injury. Employees are prohibited from any actions
or behavior intended to draw attention to, harass or discriminate against an individual with a serious illness
or injury. You do not have to discuss your serious illness or injury with anyone unless you choose to do so. If
you decide to inform your supervisor or the Human Resources Director about your situation, any information
that you disclose will be held in the greatest confidence. All employees are prohibited from disclosing the
personal health information of another employee. Any medical information which we receive will be kept
confidential. If you are hospitalized or out of work and wish for us to make other employees aware of your
condition, you may notify us in writing and we will inform your co-workers. Otherwise, the Inspirit Senior
Living prohibition on the disclosure of personal health information shall apply. No employee may make
postings, send interoffice emails or circulate any information about the health status of another employee.
If you have any questions, please contact the Human Resources Director.

8 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 2.11 POLITICAL NEUTRALITY.

Maintenance of individual freedom and our political institutions necessitates broad scale participation by
citizens concerning the selection, nomination and election of our public office holders. The Company will
not discriminate against any employee because of identification with and support of any lawful political
activity. Company employees are entitled to their own personal political position. The Company will not
discriminate against employees based on their lawful political activity engaged in outside of work.

If you are engaging in political activity, however, you should always make it clear that your actions and
opinions are your own and not necessarily those of the Company, and that you are not representing the
Company.

2.12 RESIDENT ABUSE AND REPORTING

Inspirit Senior Living prides itself on providing the highest quality care and support to our residents.
Any employee found to have violated a resident’s rights or policies pertaining to resident abuse, neglect,
or exploitation will be subject to an immediate internal investigation that includes suspension pending
investigation, corrective action up to and including termination.

Violating Residents Rights is grounds for immediate termination and may be reported to Adult Protective
Services (APS) and/or other appropriate/regulatory entities.

Inspirit Senior Living believes in a zero tolerance policy of Resident abuse.

In addition, Inspirit Senior Living does reserve the right to discipline any staff member for failure to report
a suspected abuse, neglect, exploitation. Failure to report suspected resident abuse to a supervisor and
Executive Director can result in disciplinary action up to and including termination. Violating Residents
Rights is ground for immediate termination and may be reported to Adult Protective Services (APS) and/or
other appropriate/regulatory entities.

2.13 JOB POSTING OF VACANT POSITIONS

Inspirit Senior Living believes in promoting from within. To give all qualified and interested staff members’
full and fair consideration, all jobs are posted. Qualified staff members are invited to apply for these posted
positions in accordance with the following: Once the job is posted you need to fill out an internal job
application and submit a resume if needed. The job will be posted for three days.

During this time, only staff members eligible to apply will be considered. In the case of equally qualified
internal applicants as determined by Inspirit Senior Living, length of service will govern the awarding of
the position. If no qualified internal applicant is found, recruitment of outside candidates will commence.
Applicants not selected will be notified in writing by their supervisor of the reason for their non-selection.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 9

 2.14 CRIMINAL BACKGROUND CHECKS

Inspirit Senior Living completes a criminal background check on all employees. An employee with a criminal
record may be denied employment based on the state regulatory requirements. At any time prior to or
during your employment with Inspirit Senior Living, you are required to report to the Executive Director
any arrests or convictions. Failure to provide or providing inaccurate or incomplete information regarding
your arrest or conviction record will result in discipline, up to and including termination.

2.15 DISCIPLINARY/CORRECTIVE ACTION

In order to render the best services possible to the resident of Inspirit Senior Living and to make our working
conditions as pleasant as possible it should be recognized that it is necessary that both management and
staff members conduct themselves in an appropriate manner. It is everyone’s best interest to be aware of
the types of appropriate conduct. These corrective guidelines are for guidance only and are not designed
to alter the nature of the at-will employment in this community.

In addition, when corrective action is necessary, it should be administered justly and impartially. In order
that there be consistency, the following guidelines have been established.

A corrective action will remain on a staff member’s active record for a period of 24 months. Warnings over
one-year-old may be considered in future corrective action if further violations of the same policies have
occurred.

The following Progressive Disciplinary shall be utilized for all violations of personnel policies.
1. First Violation: Verbal Warning (written confirmation of a verbal warning)
2. Second Violation: Written Warning
3. Third Violation: Suspension without pay (up to three days)
4. Fourth Violation: Termination*
*Termination may occur for those violations listed herein or at the discretion of management.

However, management reserved the right to commence corrective action at any step up to and including
immediate termination if the violation so warrants. For this reason, the offenses are divided into two
categories. It is responsibility of both management and staff members to become familiar with these rules
and corrective procedures.

RULES

The following are examples of typical offenses and should not be considered all inclusive:

TYPE A – generally warrant a verbal or written warning depending upon the severity and/or
frequency of the infraction.

1. Dress code violations

2. Tardiness

10 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 3. Excessive absenteeism
4. Leaving assigned work areas without authorization during working hours
5. Use of telephone for personal calls when unauthorized
6. Abuse of break privileges/loafing
7. Solicitation
8. Defective work
9. Other similar misconduct
10. Repeated early/late time card punching
11. Improper conduct on duty, especially loud, boisterous activity, e.g., running in halls, throwing objects.
12. Using foul or obscene language in the presence of resident/patients or visitors or to fellow employees
13. Making false or defamatory remarks about Inspirit Senior Living or its management.
14. Unauthorized absences from work
15. Smoking in restricted areas
16. Defective work/eating at workstations/medication carts.
17. Unauthorized use of any Inspirit Senior Living equipment; allowing a non-employee access to Inspirit
Senior Living equipment without prior authorization of the appropriate Supervisor/Executive Directo
18. Other similar misconduct
19. Failure to report a Worker’s Compensation/occupational injury, ignoring common safety rules
20. Not answering resident call bells timely

TYPE B – may result in immediate terminatioN

1. Physical or verbal abuse of a resideNT

2. Resident neglect or misappropriation of resident funds
3. Insubordination such as refusing work assignments, etc.
4. Any conduct or act endangering the safety or well-being of a resident or staff member or visitor to a
facility
5. Fighting while on duty/inciting other employees to riot
6. Any detectable level of illegal drugs or alcohol while on duty
7. Stealing in any form while on Inspirit Senior Living property
8. Immoral conduct on the job
9. Possession, sale or taking of controlled substances while on duty or on Inspirit Senior Living property
10. Improper recording of time; or tampering with another person’s time card
11. Falsifying employment application or other information required by Inspirit Senior Living
12. Falsifying any Inspirit Senior Living documentation, including electronic files.
13. Sleeping on the job
14. Unauthorized disclosure of confidential information
15. Violation of safety, fire prevention, health or security rule, policy or practice
16. Threatened or actual physical violence
17. Carrying any weapon while on company business, job site, premises or property without authorization
from Inspirit Senior Living
18. Accepting or engaging in any outside employment with a competitor of (without prior approval) Inspirit
Senior Living, or conducting or attempting to conduct any outside business while on Inspirit Senior
Living premises or business
19. Unauthorized sharing of computer passwords or access
20. Other similar misconduct/sabotage

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 11

 21. Distribution of gambling materials/Gambling on property

ADMINISTRATION GUIDELINES

1. Multiple offenses will lead to more serious corrective penalties. In addition, more severe corrective action
may be imposed even though a subsequent offense is for a different violation.

2. A staff member shall be notified within thirty (30) days of the time that Inspirit Senior Living learns of
an offense, of the nature of the offense and either the penalty to be imposed or the action that will be
taken pending an investigation

3. In matters of serious disciplinary offenses or penalties, upon written request by the staff member,
Inspirit Senior Living will grant the staff member involved a conference where he or she may present any
relevant information including the oral or written statements of other staff members. If practicable, such
conference will be held before the final imposition of discipline.

2.16 REFERENCES

It is the policy of Inspirit Senior Living that all reference requests for current and past staff members be
generated only from the Human Resources Director of Executive Director. No staff member or co-worker
is permitted to provide a reference request. Inspirit Senior living will only provide date of hire, date of
termination and position held.

2.17 HEALTH REQUIREMENTS

All employees of healthcare facilities are required to have a negative results TB (Tuberculin) test prior to
beginning work. A negative chest x-ray for those with previously reported positive ppd is acceptable. State
requirements and mandates will continually update and alter this policy. Inspirit Senior Living will follow
what the applicable state requires. A TB test is required annually thereafter, screened by a licensed nurse.

A pre employment physical may be required after an offer of employment. Hepatitis B vaccine is optional
and will be offered to each employee determined to be at risk. Inspirit Senior Living will pay for such vaccine.
Any employee with symptoms or signs of a viral infection, communicable disease, or infected skin lesions
will be asked by the Department Head or Supervisor to report to the Director of Nursing Services or his/
her designee.

If the Director of Nursing Services or his/her designee believes the employee is infectious, he/she will
request that the employee leave the premises for the safety of all other employees and residents and to
return to work only on written proof of good health as certified by a doctor.

12 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

SECTION 3
HOURS OF WORK &
PAYROLL PRACTICES
3.1 Pay Periods and Paydays
3.2 Scheduling
3.3 Overtime
3.4 Rest and Meal Periods
3.5 Time Clock
3.6 Payroll Deductions
3.7 Wage Garnishment
3.8 Direct Deposit
 3.1 PAY PERIODS AND PAYDAYS.

Employees are paid on a bi-monthly basis. All employees will be paid every other Friday. All employees are
paid by check or direct deposit on the above-mentioned payday. If the regular payday falls on a weekend
or Company holiday, employees will be paid on the last business day before the holiday and/or weekend.

Pay increased may be initiated on the employee anniversary or other times such as promotion and change
based on the department manager’s recommendation, budget limitations, and final approval of the Executive
Director. Attainment of an anniversary date does not necessarily result in a pay increase. Employees are
asked to keep your rate of pay private and respect your colleague’s privacy as well. Discussing your rate of
pay could result in disciplinary action.

3.2 SCHEDULING

Inspirit Senior Living is open for business 365 days a year, 24 hours a day. It should be understood that
by accepting employment at Inspirit Senior Living, a staff member might be subjected to a rotation or
change of shift where necessary. A rotation plan will be scheduled whenever it is considered necessary in
the interest of the residents. Inspirit Senior Living does reserve the right to change the employee schedule
based upon the needs of the resident.

It is the desire of Inspirit Senior Living for employees to work within their scheduled hours.

Exempt employees may be required to work extra hours to ensure smooth operation of the business. Every
effort will be made to align the scheduled hours.

3.3 OVERTIME.

Exempt Employees-New overtime rules effective Dec 1, 2016. See Human Resource director for details.

Nonexempt employees will be paid in accordance with federal and Virginia state law.

All overtime work by non-exempt employees must be authorized in advance by their manager. Only hours
actually worked will be used to calculate overtime pay. Overtime will be paid at one and one-half the
employee’s regular rate of pay for all hours worked over 40 in a workweek.

Overtime is based on hours worked. Non-productive time such as PTO or any unpaid leave of absence will
not be included when calculating overtime. Failure to obtain approval for reoccurring overtime will result
in disciplinary action. Employees who work unauthorized overtime must report the hours and will be paid
for the unauthorized overtime.

Any employee asked to work overtime is expected to do so.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 15

 3.4 REST AND MEAL PERIODS.

All rest and meal periods will be in accordance with state law.

Nonexempt employees will be provided a 15-minute rest break for every four-hour period of work. This
time is counted and paid as time worked. Nonexempt employees scheduled to work more than a five-hour
period will be provided a 30-minute unpaid meal period.

3.5 TIME CLOCK.

Time clocks are official business records and may not be altered without the employee’s supervisor’s approval
and may not be falsified in any way. Each employee is responsible for punching their own time record. An
employee may NOT clock in or clock out for another employee. Employees are NOT allowed to clock in more
than (7) seven minutes before the start of their shift without permission. The employee will be considered
tardy if they clock in more than (7) seven minutes after the start of their shift.

3.6 PAYROLL DEDUCTIONS.

Various payroll deductions are made each payday to comply with federal and state laws pertaining to taxes
and insurance. Deductions will be made for the following: Federal and State Income Tax Withholding, Social
Security, Medicare, State Disability Insurance & Family Temporary Disability Insurance, and other items
designated by you or required by law (including a valid court order). You can adjust your federal and state
income tax withholding by completing the proper federal or state form and submitting it to Accounting or
Human Resources. At the start of each calendar year, you will be supplied with your Wage and Tax Statement
(W-2) form for the prior year. This statement summarizes your income and deductions for the year.

The law requires that Inspirit Senior Living make certain deductions from the employees’ paycheck. These
deductions are in compliance with federal, state, and local law. Eligible employees may voluntarily authorize
deductions from their pay to cover costs of participating in benefit and other programs. In addition, Inspirit
Senior Living may deduct other obligations such as a child support order, garnishments, or obligation to
the community.

3.7 WAGE GARNISHMENT.

A garnishment is a court order requiring an employer to remit part of an employee’s wages to a third party
to satisfy a just debt. Once the Company receives the legal papers ordering a garnishment, we are required
by law to continue making deductions from your check until we have withheld the full amount or until we
receive legal papers from the court to stop the garnishment. Even if you have already paid the debt, we
still need the legal papers to stop the garnishment.

16 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 3.8 DIRECT DEPOSIT.

All employees are encouraged, but not required, to use direct deposit and have their paychecks deposited
into a bank account of an accredited participating bank or credit union.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 17

SECTION 4
STANDARDS OF
CONDUCT AND
EMPLOYEE
PERFORMANCE
4.1 Anti- Harassment and Discrimination
4.2 Attendance
4.3 Discipline and Standards of Conduct
4.4 Dress Code
4.5 Safety
4.6 Loitering
4.7 Substance and Abuse
4.8 Workplace Searches
4.9 Internet, Email and Computer Use Policy
4.9 Social Media Policy
4.10 Cell Phone Policy
 4.1 ANTI-HARASSMENT AND DISCRIMINATION.

The Company is committed to providing a work environment free of sexual or any form of unlawful harassment
or discrimination. Harassment or unlawful discrimination against individuals on the basis of race, religion,
creed, color, national origin, sex, pregnancy, sexual orientation, gender identity, age, ancestry, physical or
mental disability, genetic information, marital status or any other classification protected by local, state or
federal laws is illegal and prohibited by Company policy. Such conduct by or towards any employee, contract
worker, customer, vendor or anyone else who does business with the Company will not be tolerated. Any
employee or contract worker who violates this policy will be subject to disciplinary action, up to and including
termination of his or her employment or engagement. To the extent a customer, vendor or other person
with whom the Company does business engages in unlawful harassment or discrimination, the Company
will take appropriate corrective action. We will not terminate, demote, harass, or otherwise “retaliate”
against an individual for filing a charge of harassment or discrimination, participating in a discrimination
proceeding, or otherwise opposing discrimination.

Prohibited Conduct:

Prohibited harassment or discrimination includes any verbal, physical or visual conduct based on sex, race,
age, national origin, disability or any other legally protected basis if:

A. Submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s
employment or engagement;

B. Submission to or rejection of such conduct by an individual is used as a basis for decisions concerning
that individual’s employment or engagement; or

C. It creates a hostile or offensive work environment.

Prohibited harassment includes (but is not limited to) unwelcome sexual advances, requests for sexual
favors and lewd, vulgar or obscene remarks, jokes, posters or cartoons, and any unwelcome touching,
pinching or other physical contact. Other forms of unlawful harassment or discrimination may include racial
epithets, slurs and derogatory remarks, stereotypes, jokes, posters or cartoons based on race, national
origin, age, disability, marital status or other legally protected categories. Prohibited harassment might also
be transmitted using the Company’s electronic communications system, or through other on-line conduct.

Complaint Procedure:

Employees or contract workers who feel that they have been harassed or discriminated against, or who
witness any harassment or discrimination by an employee, contract worker, customer, vendor or anyone
else who does business with the Company, should immediately report such conduct to their supervisor or
any other member of management.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 19

 Do not allow an inappropriate situation to continue by not reporting it, regardless of who is creating the
situation. No employee, contract worker, customer, vendor or other person who does business with this
organization is exempt from the prohibitions in this policy. In response to every complaint, the Company will
conduct an investigation which may involve interviewing witnesses if warranted and, if improper conduct
is found, take appropriate corrective action.

To the extent that an employee or contract worker is not satisfied with the Company’s handling of a
harassment or discrimination complaint, he or she may also contact the appropriate state or federal
enforcement agency for legal relief.

4.2 ATTENDANCE.

Punctuality and regular attendance are essential to the successful operation of the Company’s business. If
an employee is unable to report to work (or to report to work on time) for any reason, the employee must
notify his or her supervisor at least 2 hours before his or her starting time.

Texting a supervisor or leaving a message to inform them you are unable to report to work is NOT an
approved or recognized form of communication.

Please remember that failure to appear for work as scheduled places an undue burden on both our residents
and your co-workers.

If an employee desires to leave work for any reason during the workday, the employee must obtain the
approval of his or her supervisor prior to leaving. In the event that the employee fails to call his or her
supervisor or report for work for (1) one consecutive workday, the employee will be deemed to have
voluntarily resigned from his or her employment with the Company and will be removed from the payroll.
Excessive absenteeism or tardiness may subject the employee to disciplinary action, up to and including
termination. Excessive absenteeism will be defined as an average of one or more days per month, not
including pre-approved PTO or holidays. “No Fault Attendance Policy” looks at the attendance patterns,
not the reasons for absences. Therefore, all absences are counted, no matter what the reason, unless they
are consider a “Leave of Absence.” You are considered absent when you are not at work for more than 50%
of your regularly scheduled shift.

4.3 DISCIPLINE AND STANDARDS OF CONDUCT.

As an at-will employer, the Company may impose discipline whenever it determines it is necessary or
appropriate. Discipline may take various forms, including verbal counseling, written warnings, suspension,
demotion, transfer, reassignment or termination. The discipline imposed will depend on the circumstances
of each case; therefore, discipline will not necessarily be imposed in any particular sequence. Moreover, at
any time the Company determines it is appropriate, an employee may be terminated immediately.

20 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 Every organization must have certain standards of conduct to guide the behavior of employees. Although
there is no possible way to identify every rule of conduct, the following is an illustrative list (not intended
to be comprehensive or to limit the Company’s right to impose discipline for any other conduct it deems
inappropriate). Keep in mind that these standards of conduct apply to all employees whenever they are on
Company property and/or conducting Company business (on or off Company property). Engaging in any
conduct the Company deems inappropriate may result in disciplinary action, up to and including termination.

1. Dishonesty;

2. Falsification of Company records;

3. Unauthorized use or possession of property that belongs to the Company, a coworker, or of the public;

4. Possession or control of illegal drugs, weapons, explosives, or other dangerous or unauthorized materials;

5. Fighting, engaging in threats of violence or violence, use of vulgar or abusive language, horseplay,
practical jokes or other disorderly conduct that may endanger others or damage property;

6. Insubordination, failure to perform assigned duties or failure to comply with the Company’s health,
safety or other rules;

7. Unauthorized or careless use of the Company’s materials, equipment or property;

8. Unauthorized and/or excessive absenteeism or tardiness;

9. Lack of teamwork, poor communication, unsatisfactory performance, unprofessional conduct, or conduct

improper for the workplace;

10. Sexual or other illegal harassment or discrimination;

11. Unauthorized use or disclosure of the Company’s confidential information;

12. Violation of any Company policy.

4.4 DRESS CODE.

Employees should present a neat, professional appearance at all times and be well-groomed and appropriately.
Employees are expected to maintain good personal hygiene, cleanliness, and attire. Please consult your
supervisor if you have questions about appropriate attire. Your direct supervisor will advise you on appropriate
attire. If an employee’s supervisor finds an employee’s attire to be unacceptable, the employee will be asked
to return home to change into the acceptable attire.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 21

 A few examples of unacceptable attire that may violate our policy:
• Clothing that does not sufficiently conceal undergarments, excessively tight, revealing.
• No shorts, tank tops, crop tops, jeans.
• Jewelry that is large or excessive.
• Open toed shoes/flip flops. Shoes which do not provide adequate protection for your duties.
• Clothing with holes, rips, fraying, rude or obscene gestures, language, and graphics.
• No clothing that advertises a product or service other than those offered by Inspirit Senior Living.

A few examples of hygiene issues or personal appearance that may violate our policy:
• Nails or hair (style or color) that interfere with your ability to perform job duties safely and effectively.
• Exposed facial or body piercings, and tattoos that are offensive to the residents, their families, or co-
workers.
• Excessive odors that cause a distraction in the workplace.

Inspirit Senior Living will accommodate employees on the basis of disability, national origin and religion. If
you have questions, please feel free to contact your Human Resources Director. Disciplinary action including
and up to termination may result from repeated violations.

4.5 SAFETY.

The Company is committed to providing a safe workplace. Accordingly, the Company emphasizes “safety
first.” It is the employee’s responsibility to take steps to promote safety in the workplace and work in a safe
manner. By remaining safety conscious, employees can protect themselves and their coworkers. Employees
are expected to promptly report all unsafe working conditions, accidents and injuries, regardless of how minor
so that any potential hazards can be corrected. Employees are expected to have an understanding of the
chemicals used in the workplace and become familiar with the MSDS sheets and location of MSDS binder.

4.6 LOITERING.

Staff members are not to remain within the community or in any other working area for more than thirty
minutes after clocking out and are not to return to the community or into working areas of the community
more than thirty minutes before the scheduled starting time for any reason. Permission to wait in the
community for specified reasons may be granted by the Executive Director or your supervisor.

4.7 SUBSTANCE AND ABUSE.

The Company is committed to providing its employees with a safe and productive work environment. In
keeping with this commitment, it maintains a strict policy against the use of alcohol and the unlawful use
of drugs in the workplace. Consequently, no employee may consume or possess alcohol, or use, possess,
sell, purchase or transfer illegal drugs at any time while on the Company’s premises or while using the
Company vehicles or equipment, or at any location during work time.

22 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 No employee may report to work with illegal drugs (or their metabolites) or alcohol in his or her bodily
system. The only exception to this rule is that employees may engage in moderate consumption of alcohol
that may be served and/or consumed as part of an authorized Company social or business event. “Illegal
drug” means any drug that is not legally obtainable or that is legally obtainable but has not been legally
obtained. It includes prescription drugs not being used for prescribed purposes or by the person to whom
it is prescribed or in prescribed amounts. It also includes any substance a person holds out to another as
an illegal drug.

Any violation of this policy will result in disciplinary action, up to and including termination.

Illegal Drugs
“Illegal drugs” are drugs or controlled substances which are (1) not legally obtainable or (2) are legal drugs
legally obtainable but not obtained or used in a lawful manner.

Legal Drugs
“Legal drugs” are those prescribed or over the counter drugs that are legally obtained by the employee and
used for the purpose for which they were prescribed or sold. You may use legally prescribed drugs while at
work as long as they do not interfere with your ability to perform your job or affect the safety of yourself
or others.

PROHIBITED CONDUCT

A. Employees may not possess, use, purchase, sell, or transfer alcohol on Company property (including parking
lots), or in Company vehicles (either owned by or leased to this community), or while on company business.

B. Employees may not consume alcohol on or off Company property during working hours, lunch periods,
breaks or relief periods.

C. Employees may not report to work under the influence of alcohol. “Under the influence” means that
the employee is affected by alcohol or drugs or the combination of both in any detectable manner. This
may be established by professional opinion, a scientifically valid test, or, in some cases, by observation of
impairment of physical or mental ability, such as slurring of speech, difficulty in maintaining balance, etc.

D. Employees may not possess, use, purchase, sell, manufacture, distribute or transfer illegal drugs on
Company property (including parking lots) or in Company vehicles (either owned by or leased to this
community), or while on Company business.

E. Employees may not consume illegal drugs on or off Company property during working hours, lunch
periods, or break or relief periods.

F. Employees may not report to work “under the influence” of illegal drugs. “Under the influence” is defined

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 23

 as it was above for alcohol, and may also be established through professional opinion, a scientifically valid
test, or, in some cases, by observation of impairment of physical or mental ability, such as slurring of speech,
difficulty in maintaining balance, etc.

G. Employees are prohibited from bringing drug paraphernalia onto Company property (including parking
lots) at any time.

Legal drugs may also affect the safety of the employee or fellow employees or residents. Therefore, any
employee who is taking a legal drug that might impair safety, performance or any motor function must
advise his/her supervisor before reporting to work under such medication. Failure to do so may result in
disciplinary action. Improper use of legal drugs, including using legal drugs prescribed for someone else, is
prohibited and will result in disciplinary action.

Refusal to submit to, efforts to tamper with, or failure to pass a drug test will result in disciplinary action,
up to and including discharge.

CONSEQUENCES OF POLICY VIOLATION

Any employee who engages in prohibited conduct as set forth above will be terminated. An employee with
a first violation who then successfully completes a drug or alcohol rehabilitation program will be eligible
for rehire.

TESTING- In addition to pre-employment testing:

A. Testing Scenarios
Employees may be asked to submit to a drug test if cause exists to indicate that their ability to perform
work safely or effectively may be impaired. As noted in the Employee Handbook, Inspirit Senior Living
has a zero-tolerance policy relative to employees being under the influence of drugs and/or alcohol while
working. All testing will be conducted by an independent third-party.

Testing for cause is based upon reasonable suspicion of impairment. Factors that could establish reasonable
suspicion include but are not limited to the following: (1) where an employee manifests physical or behavioral
symptoms or reactions commonly attributed to the use of illegal drugs or alcohol, which could include
appearance, conduct, speech, or odor, or (2) the Company otherwise receives reliable information indicating
that an employee or group of employees may be engaging in conduct that violates this policy.

If a supervisor believes cause exists, the supervisor should report his or her findings and observations to
the Executive Director. Together, the supervisor and Executive Director should objectively discuss the
observations and jointly arrive at a decision as to whether cause exists to warrant testing. If needed, it is
also appropriate to elevate to regional management.

24 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 B. Random Testing
Employees will be required to submit to drug testing on a random basis as determined by the Executive
Director.

C. Post-Accident Testing
Employees will be tested for the presence of drugs or alcohol following an accident or other occurrence
where the manager can articulate a reasonable suspicion that drugs or alcohol led to one or more of the
following events: a fatality, an injury to an employee or other individual including residents requiring medical
attention, damage to vehicles and/or damage to other property.

D. Testing Procedure

1. If the employee refuses to consent to testing, fails to appear for the test, or fails to cooperate with
testing procedures he or she will be terminated

2. This Community employs a very accurate testing program. All urine samples will be subjected to the
following sequence:

a. All urine samples will first be subjected to an initial screening process to detect the presence of illegal
drugs.

b. Those samples having a negative screen (no illegal drugs present) will be considered to have tested
negative and no further testing will be done on that sample; and

c. Those samples having a positive screen will be tested more extensively to eliminate any false positive
tests and confirm the presence of illegal drugs.

d. Urine collection procedures shall allow individual privacy unless there is a reason to believe that a
particular individual may adulterate or substitute the specimen to be provided, based upon knowledge of
prior substance use such as a previous positive test, or based upon the circumstances.

e. All test results are property of this community.

E. Re testing
Any employee whose test is positive may, at the employee’s expense, obtain a retest of the same sample
with a thirty (30) day period at the same or another approved laboratory. This Community reserves the
night to assess an administrative fee of $15 per retest.

INVESTIGATION

A. To ensure that illegal drugs and alcohol do not enter or affect the workplace, this Community reserves the

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 25

 right to search all persons, vehicles, containers, lockers, or other items on this facility’s property to ensure
compliance of this policy. Individuals may be requested to display personal property for visual inspection
upon the Executive Director’s request. Entry onto company premises (including parking lots) constitutes
consent to search and inspection.

B. Searches will be conducted under this policy only where this community has reason to believe that the
employee has violated this substance abuse policy.

C. Failure to consent to a search or to display personal property for visual inspection will be grounds for
discharge and/or denial of access to this community’s premises.

CONFIDENTIALITY

Results of an applicant’s or an employee’s test for the use of illegal drugs or alcohol shall be transmitted
to the Executive Director. In order to effectively address the employees with drug or alcohol problems, it
will be necessary for the Executive Director to consult with other persons in the process. However, such
results will be disseminated only on a need to know basis. All information and test results become the
property of the facility.

Any employee who feels he or she has developed an addiction to, dependence upon, or problem with
alcohol or drugs, legal or illegal, is strongly encouraged to seek assistance before a violation of this policy
occurs. Any employee who requests time off to participate in a rehabilitation program will be reasonably
accommodated. However, employees may not avoid disciplinary action, up to and including termination, by
entering a rehabilitation program after a violation of this policy is suspected or discovered.

4.8 WORKPLACE SEARCHES.

All offices, desks, file drawers, cabinets, lockers, Company vehicles, and other Company equipment (including
but not limited to computers, e-mail and voice mail) and facilities or any area on Company premises are the
property of the Company (“Company Property”), and are intended for business use. Employees should have
no expectation of privacy with respect to Company property and/or items stored within Company Property
or on Company premises. Inspection may be conducted at any time, without notice, at the discretion of
the Company.

In addition, when the Company deems appropriate, employees may be required to submit to searches of their
personal vehicles, parcels, purses, handbags, backpacks, brief cases, lunch boxes or any other possessions
or articles brought on to the Company’s premises.

Persons entering the premises who refuse to cooperate in an inspection conducted pursuant to this policy

26 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 may not be permitted to enter the premises. All employees must cooperate in an inspection; failure to do
so is insubordination and will result in disciplinary action, up to and including termination.

4.9 INTERNET, EMAIL AND COMPUTER USE POLICY.

The Company uses various forms of electronic communication including, but not limited to: computers, email,
telephones, voicemail, instant message, text message, Internet, cell phones and smart phones (hereafter
referred to as “electronic communications”). The electronic communications, including all software, databases,
hardware, and digital files, remain the sole property of the Company and are to be used only for Company
business and not for personal use.

The following rules apply to all forms of electronic communications and media that are: (1) accessed on or
from Company premises; (2) accessed using the Company computer or telecommunications equipment, or
via Company-paid access methods; and/or (3) used in a manner which identifies the Company. The following
list is not exhaustive and the Company may implement additional rules from time to time.

a. Electronic communication and media may not be used in any manner that would be discriminatory,
harassing, or obscene, or for any other purpose that is illegal, against Company policy, or not in the best
interest of the Company. Employees who misuse electronic communications and engage in defamation,
copyright or trademark infringement, misappropriation of trade secrets, discrimination, harassment, or
related actions will be subject to discipline, up to and including termination. Employees may not install
personal software on Company computer systems.

b. Employee’s own electronic media may only be used during breaks. All other company policies, including
the Company’s no tolerance for discrimination, harassment, or retaliation in the workplace apply.

c. All electronic information created by any employee on Company premises or transmitted to Company
property using any means of electronic communication is the property of the Company and remains
the property of the Company. You should not assume that any electronic communications are private or
confidential and should transmit personal sensitive information in other ways. Personal passwords may be
used for purposes of security, but the use of a personal password does not affect the Company’s ownership
of the electronic information. The Company will override all personal passwords if necessary for any reason.

d. The Company reserves the right to access and review electronic files, messages, internet use, blogs,
“tweets”, instant messages, text messages, email, voice mail, and other digital archives, and to monitor the
use of electronic communications as necessary to ensure that no misuse or violation of Company policy or
any law occurs. All such information may be used and/or disclosed to others, in accordance with business
needs and the law. The Company reserves the right to keep a record of all passwords and codes used and/
or may be able to override any such password system

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 27

 e.Employees are not permitted to access the electronic communications of other employees or third parties
unless directed to do so by Company management. No employee may install or use anonymous e-mail
transmission programs or encryption of e-mail communications.
f. Employees who use devices on which information may be received and/or stored, including but not
limited to cell phones, cordless phones, portable computers, fax machines, and voice mail communications
are required to use these methods in strict compliance with the Confidentiality section of this Handbook.
These communications tools should not be used for communicating confidential or sensitive information
or any trade secrets.

g. Access to the Internet, websites, and other types of Company-paid computer access are to be used for
Company-related business only. Any information about Inspirit Senior Living, its products or services, or
other types of information that will appear in the electronic media about the Company must be approved
before the information is placed on any electronic information resource that is accessible to others.

4.10 SOCIAL MEDIA POLICY.

Inspirit Senior Living is committed to utilizing social media to enhance its profile and reputation, to listen
and respond to customer opinions and feedback, and to drive revenue, loyalty and advocacy. We encourage
employees to support our activities through their personal social networking channels while adhering to
the guidelines outlined in this section.

For the purpose of this section, social media and networking refers to the use of web-based and mobile
applications for social interaction and the exchange of user-generated content. Social media channels can
include, but are not limited to: Facebook, Twitter, LinkedIn, YouTube, blogs, review sites, forums, online
communities and any similar online platforms.

Employees are expected to conduct themselves in a professional manner and to respect the views and
opinions of others. The Company and its employees are committed to conducting ourselves in accordance
with best industry practices in social networking, to being responsible citizens and community members,
to listening and responding to feedback, and to communicating in a courteous and professional manner.

Behavior and content that may be deemed disrespectful, dishonest, offensive, harassing or damaging to
the company’s interests or reputation are not permitted. The use of social media channels on company
time for personal purposes is not allowed.

Any social media contacts, including “followers” or “friends,” that are acquired through accounts (including
but not limited to email addresses, blogs, Twitter, Facebook, YouTube, LinkedIn, or other social media
networks) created on behalf of the Company will be the property of the Company.

Employees must not disclose private or confidential information about the Company, its employees, clients,

28 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 suppliers or customers on social networks. Employees must respect trademarks, copyrights, intellectual
property and proprietary information. No third-party content should be published without prior permission
from the owner.

The Company maintains the right to monitor company-related employee activity in social networks. Violation
of policy guidelines is grounds for discipline, up to and including termination.

4.11 CELL PHONE POLICY.

The use of personal cell phones at work is discouraged because it can interfere with work and be disruptive
to others. Therefore, employees who bring personal cell phones to work are required to keep the ringer shut
off or placed on vibrate mode when they are in the office, and to keep cell phone use confined to breaks
and meal periods. Conversations should be had away from areas where other employees are working. When
cell phone use interferes with the satisfactory performance of an employee’s duties or disturbs others, the
privilege of using a personal cell phone at work may be taken away and other disciplinary action, up to and
including termination, may be imposed.

The Company may provide cell phone allowances to employees in certain positions in an effort to improve
efficiency and effectiveness. When cell phones are used for Company business, employees must comply
with all Company policies governing conduct, including our policies prohibiting discrimination, harassment,
and violence in the workplace. When using the cell phone in a public place, please remember to maintain
the confidentiality of any private or confidential business information. As a courtesy to others, please shut
cell phones off or place on vibrate mode during meetings.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 29

SECTION 5
EMPLOYEE BENEFITS
AND SERVICES
5.1 Generally
5.2 Group Health Insurance
5.3 Group Life Insurance
5.4 401(k) Plan
5.5 COBRA
5.6 Worker’s Compensation
5.7 Social Security Benefits (FICA)
5.8 Unemployment Insurance
5.9 Additional Benefits
 5.1 GENERALLY.

Aside from those benefits required by state and federal regulations, Inspirit Senior Living also offers additional
benefits for its employees. From time to time, benefits may be added or deleted from the benefits package.
The Company reserves the right to make such changes.

This Handbook does not contain the complete terms and/or conditions of any of the Company’s current
benefit plans. It is intended only to provide general explanations. For information regarding employee
benefits and services, employees should contact Human Resources.

5.2 GROUP HEALTH INSURANCE.

Inspirit Senior Living offers a group health plan for eligible employees. For more information, refer to the
Company’s benefits booklet for complete details and benefits.

5.3 GROUP LIFE INSURANCE.

Inspirit Senior Living offers a group life insurance plan for eligible employees, including accidental death
and dismemberment coverage. For more information, refer to the Company’s benefits booklet for complete
details and benefits.

5.4 401(K) PLAN.

After (1) one year of full-time employment you may enroll in the 401k program. Inspirit Senior Living’s
401(k) Plan is a convenient payroll deductible method to help supplement employees’ retirement benefits
and provide a long term vehicle to accumulate savings. For information regarding employee benefits and
services, employees should contact Human Resources.

5.5 COBRA.

Under the provisions of the Consolidated Omnibus Budget Reconciliation Act (COBRA) of 1986, if you are
covered under the Company’s group health insurance plan(s) you are entitled to continue your coverage
in the event that your employment with the Company ends. Under COBRA, the Company must offer each
qualified beneficiary (the employee and any covered dependents) who would otherwise lose coverage under
the plan as a result of a qualifying event an opportunity to continue their insurance coverage. A qualifying
event is defined as termination of employment, a reduction in the number of hours of employment, death
of covered employee, divorce or legal separation, a dependent child ceases to be dependent, eligibility of
the covered employee for Medicare, or an employer’s bankruptcy.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 31

 5.6 WORKER’S COMPENSATION.

All states have Workers’ Compensation laws whose purpose is to promote the general welfare of people by
providing compensation for accidental injuries or death suffered in the course of employment. These laws
are designed to provide protection to workers suffering occupational disabilities through accidents arising
out of, and in the course of employment. Inspirit Senior Living Carries Workers’ Compensation Insurance
for all employees and pays the entire cost of the insurance program. An employee who suffers an injury or
illness in connection with the job is usually eligible to receive payment through the insurance company for
lost wages and/or be offered a light duty position within the community. In addition to disability payments,
necessary hospital, medical and surgical expenses are covered under Workers’ Compensation, with payments
being made directly to the hospital or physician. Workers’ Compensation benefits to injured workers also
include assistance to help qualified injured employees return to suitable employment.

5.7 SOCIAL SECURITY BENEFITS (FICA).

During your employment, you and the Company both contribute funds to the Federal government to support
the Social Security Program. This program is intended to provide you with retirement benefit payments
and medical coverage once you reach retirement age.

5.8 UNEMPLOYMENT INSURANCE.

The company pays a state and federal tax to provide employees with unemployment insurance coverage
in the event they become unemployed through no fault of their own or due to circumstances described by
law. This insurance is administered by applicable state agencies, who determine eligibility for benefits, the
amount of benefits (if any), and duration of benefits.

5.9 ADDITIONAL BENEFITS.

Dental/Vision and Supplemental Insurance through Colonial Life. See benefit booklet for additional details.

32 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

SECTION 6
EMPLOYEE LEAVES
OF ABSENCE AND
TIME OFF
6.1 Generally
6.2 Paid Time Off Days
6.3 Holidays
6.4 Family and Medical Leave
6.5 Workers’ Compensation Leave
6.6 Bereavement Leave
6.7 Jury Duty
6.8 Military Leave
6.9 Leave of Absence Policy
 6.1 GENERALLY.

While regular attendance is crucial to maintain business operations, the Company recognizes that, for
a variety of reasons, employees may need time off from work. The Company has available a number of
types of leaves of absence. Some are governed by law and others are discretionary. For all planned leaves,
however, employees must submit a request at least 14 days in advance; in case of emergencies, employees
should submit the request as soon as they become aware of the need for leave. All leaves must have the
approval of Company management. If, during a leave, an employee accepts another job, engages in other
employment or consulting outside of the Company, or applies for unemployment insurance benefits, the
employee may be considered to have voluntarily resigned from employment with the Company.

All requests for a leave of absence will be considered in light of their effect on the Company and its work
requirements, as determined by Company management, which reserves the right to approve or deny such
requests in its sole discretion, unless otherwise required by law. For disability-related leave requests,
the Company will engage in an interactive process with the employee to determine if a leave is the most
appropriate accommodation. The employee must provide a certification from his or her health care provider
to the Company to support a leave for medical reasons. Failure to provide the required certification to the
Company in a timely manner will result in delay or denial of leave. If an employee requires an extension
of leave, the employee must request such extension and have it approved before the expiration of the
currently approved leave.

While the Company will make a reasonable effort to return the employee to his or her former position or a
comparable position following an approved leave of absence, there is no guarantee that the employee will
be reinstated to his or her position, or any position, except as required by law.

6.2 PAID TIME OFF DAYS.

Eligible employees are entitled to the Paid Time Off (PTO) Program. The PTO Program combines paid
vacation, sick, employee birthday, and personal days. A PTO days’ pay for regular full-time employees will be
calculated based on the employee’s base pay rate times the number of hours the employee would otherwise
have worked on that day. Regular part-time employees will be paid on a pro-rata basis. Employees may
not accrue more than 2 times (max. 160 hours) their annual accrual rate of time off. Once an employee’s
time off balance reaches this limit, an employee may accrue more time off only by taking some time off to
bring the balance back below the limit. When employees eligible for paid time off days do not take the full
amount of PTO time they could have taken in a year, that amount automatically carries over to the next year.

It is important for you to take time off to recharge and return to work refreshed.

Your time off request will not be granted if your requested time off exceeds your PTO balance. pay. Time
off without pay will NOT be granted if PTO is available. In certain situations, taking PTO without pay may
be permitted at the Executive Directors discretion.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 35

 Upon termination, providing the employee separates in good standing and gave appropriate notice, employees
will be paid up to 80 hours of all accrued but unused time off as wages. Employees that terminate without
notice or that are terminated will not be paid out their PTO balance.

All PTO requests are to be made at least two weeks prior to requested time off. No PTO request can be
made once the schedule is posted. If you desire a day off after the schedule is posted, you must find your
own replacement and have the time in your PTO bank. Extended time off (anything over 5 PTO days) must
be approved by your supervisor in advance.

All new employees must be employed for 6 months before using your PTO benefit. PTO starts to accrue
after 90 days of hire. Any schedule vacation planned prior to hire will be taken into consideration. Anyone
employed at the time of the acquisition to Inspirit Senior Living are exempt from this policy.

Exempt PTO is based upon hours worked and tenure with the company. Please see Human Resource Director
for details.

Full Time: Bi-Weekly Rates

o 1st and 2nd years: 8 PTO days per year

o 3rd and 4th years: 13 PTO days per year
o 5th year to 9th year: 18 PTO days per year
o 10th year+: 23 PTO days per year

Part Time: Bi-Weekly Rates

o 1st and 2nd years: 4 PTO days per year

o 3rd and 4th years: 6.5 PTO days per year
o 5th year to 9th year: 9 PTO days per year
o 10th year+: 11.5 PTO days per year

6.3 HOLIDAYS.

Inspirit Senior Living observes the following holidays:

• New Year’s Day

• Memorial Day
• Independence Day
• Labor Day
• Thanksgiving Day
• Christmas Day

36 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 •

Non-exempt employees are paid time and one half for all hours worked on holiday. Non-exempt
employees not working the holiday do not receive holiday pay. All non-exempt employees must work all
scheduled shifts (2) two days before and after the holiday to be eligible for holiday pay.

All PTO requests between Thanksgiving and New Year’s Day must be approved by your supervisor. Requested
PTO will be based on seniority and previous holidays worked. All employees are required to work a minimum of
(3) three of the (6) six company recognized holidays. Holiday schedule will be determined by your supervisor.

6.4 FAMILY AND MEDICAL LEAVE.

We recognize that our employees may occasionally need to take unpaid leave to care for a new child, to care
for a seriously ill family member, to handle an employee’s own medical issues, or to handle issues relating
to a family member’s military service, possibly including caring for a family member who is injured while
serving in the military.

Family and Medical Leave Act Policy

The Family and Medical Leave Act of 1993, as amended, (FMLA or Act) allows ‘‘eligible’’ employees of a
covered employer to take job-protected, unpaid leave, or to substitute appropriate paid leave if the employee
has earned or accrued it, for up to a total of 12 workweeks in any 12 months because of the birth of a child
and to care for the newborn child; because of the placement of a child with the employee for adoption or
foster care; because the employee
is needed to care for a family member (child, spouse, or parent) with a serious health condition; because
the employee’s own serious health condition makes the employee unable to perform the functions of his
or her job; or because of any qualifying exigency arising out of the fact that the employee’s spouse, son,
daughter, or parent is a covered military member on active duty (or has been notified of an impending call
or order to active duty) in support of a contingency operation. In addition, ‘‘eligible’’ employees of a covered
employer may take job- protected, unpaid leave, or substitute appropriate paid leave if the employee has
earned or accrued it, for up to a total of 26 workweeks in a ‘‘single 12-month period’’ to care for a covered

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 37

 service member with a serious injury or illness.
Covered employer
An employer covered by FMLA is any person engaged in commerce or in any industry or activity affecting
commerce, who employs 50 or more employees for each working day during each of 20 or more calendar
workweeks in the current or preceding calendar year.

Eligible Employees

An eligible employee is one who has been employed by us for at least 12 months (in the past seven years),
has been employed by us for at least 1,250 hours of service during the 12-month period immediately
preceding the commencement of the leave, and is employed at a worksite where 50 or more employees
are employed by us within 75 miles of the worksite. The 12 months that an employee must have been
employed by us need not be consecutive months.

QUALIFYING REASONS FOR LEAVE

General rule
Employers covered by FMLA are required to grant leave to eligible employees: (1) For birth of a son or
daughter, and to care for the newborn child, (2) For placement with the employee of a son or daughter
for adoption or foster care, (3) To care for the employee’s spouse, son, daughter, or parent with a serious
health condition, (4) Because of a serious health condition that makes the employee unable to perform
the functions of the employee’s job, (5) Because of any qualifying exigency arising out of the fact that
the employee’s spouse, son, daughter, or parent is a covered military member on active duty (or has been
notified of an impending call or order to active duty) in support of a contingency operation, and (6) To care
for a covered service member with a serious injury or illness if the employee is the spouse, son, daughter,
parent, or next of kin of the service member.

Serious health condition

For purposes of FMLA, ‘‘serious health condition’’ entitling an employee to FMLA leave means an illness,
injury, impairment or physical or mental condition that involves inpatient care or continuing treatment by
a health care provider.
Inpatient care
Inpatient care means an overnight stay in a hospital, hospice, or residential medical care facility, including
any period of incapacity or any subsequent treatment in connection with such inpatient care.
Continuing treatment
A serious health condition involving continuing treatment by a health care provider includes any one or
more of the following:
(a) Incapacity and treatment. A period of incapacity of more than three consecutive, full calendar days,
and any subsequent treatment or period of incapacity relating to the same condition, that also involves:
(1) Treatment two or more times, within 30 days of the first day of incapacity, unless extenuating circumstances
exist, by a health care provider, by a nurse under direct (e.g., physical therapist) under orders of, or on
referral by, a health care provider; or

38 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 (2) Treatment by a health care provider on at least one occasion, which results in a regimen of continuing
treatment under the supervision of the health care provider.
(3) The requirement in paragraphs (a)(1) and (2) of this section for treatment by a health care provider
means an in-person visit to a health care provider. The first (or only) in-person treatment visit must take
place within seven days of the first day of incapacity.
(4) Whether additional treatment visits or a regimen of continuing treatment is necessary within the 30-
day period shall be determined by the health care provider.
(b) Pregnancy or prenatal care Any period of incapacity due to pregnancy, or for prenatal care
(c) Chronic conditions Any period of incapacity or treatment for such incapacity due to a chronic serious
health condition. A chronic serious health condition is one which: (1) Requires periodic visits (defined as
at least twice a year) for treatment by a health care provider, or by a nurse under direct supervision of
a health care provider; (2) Continues over an extended period of time (including recurring episodes of a
single underlying condition); and (3) May cause episodic rather than a continuing period of incapacity (e.g.,
asthma, diabetes, epilepsy, etc.).
(d) Permanent or long-term conditions A period of incapacity which is permanent or long-term due to a
condition for which treatment may not be effective. The employee or family member must be under the
continuing supervision of, but need not be receiving active treatment by, a health care provider.

LEAVE FOR PREGNANCY OR BIRTH

General rules.
Eligible employees are entitled to FMLA leave for pregnancy or birth of a child as follows:
(1) Both the mother and father are entitled to FMLA leave for the birth of their child.
(2) Both the mother and father are entitled to FMLA leave to be with the healthy newborn child (i.e., bonding
time) during the 12-month period beginning on the date of birth. An employee’s entitlement to FMLA leave
for a birth expires at the end of the 12- month period beginning on the date of the birth.
(3) A husband and wife who are eligible for FMLA leave and are employed by us will be limited to a combined
total of 12 weeks of leave during any 12-month period if the leave is taken for birth of the employee’s son
or daughter or to care for the child after birth, for placement of a son or daughter with the employee for
adoption or foster care or to care for the child after placement.

Intermittent and reduced schedule leave.

An eligible employee may not use intermittent or reduced schedule leave after the birth to be with a healthy
newborn child.

LEAVE FOR ADOPTION OR FOSTER CARE.

General rules.
Eligible employees are entitled to FMLA leave for placement with the employee of a son or daughter for
adoption or foster care as follows:
Employees may take FMLA leave before the actual placement or adoption of a child if an absence from

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 39

 work is required for the placement for adoption or foster care to proceed. For example, the employee may
be required to attend counseling sessions, appear in court, consult with his or her attorney or the doctor(s)
representing the birth parent, submit to a physical examination, or travel to another country to complete
an adoption. The source of an adopted child (e.g., whether from a licensed placement agency or otherwise)
is not a factor in determining eligibility for leave for this purpose.

Unable to perform the functions of the position

(a) Definition. An employee is ‘‘unable to perform the functions of the position’’ where the health care
provider finds that the employee is unable to work at all or is unable to perform any one of the essential
functions of the employee’s position within the meaning of the Americans with Disabilities Act (ADA), as
amended. An employee who must be absent from work to receive medical treatment for a serious health
condition is considered to be unable to perform the essential functions of the position during the absence
for treatment.
(b) Statement of functions. We require certification from a health care provider to specify what functions
of the employee’s position the employee is unable to perform so that we can then determine whether the
employee is unable to perform one or more essential functions of the employee’s position.

Leave because of a qualifying exigency

Eligible employees may take FMLA leave while the employee’s spouse, son, daughter, or parent (the ‘‘covered
military member’’) is on active duty or call to active duty status for one or more of the following qualifying
exigencies: (1) Short-notice deployment (2) Military events and related activities (3) Childcare and school
activities (4) Financial and legal arrangements (5) Counseling: To attend counseling provided by someone
other than a health care provider (6) Rest and recuperation (7) Post-deployment activities (8) Additional
activities. To address other events which arise out of the covered military member’s active duty or call
to active duty status provided that the employer and employee agree that such leave shall qualify as an
exigency, and agree to both the timing and duration of such leave.
An employee whose family member is on active duty or call to active duty status in support of a contingency
operation as a member of the Regular Armed Forces is not eligible to take leave because of a qualifying
exigency.

Leave to care for a covered service member with a serious injury or illness
Eligible employees are entitled to FMLA leave to care for a current member of the Armed Forces, including
a member of the National Guard or Reserves, or a member of the Armed Forces, the National Guard or
Reserves who is on the temporary disability retired list, who has a serious injury or illness incurred in the
line of duty on undergoing medical treatment, recuperation, or therapy; or otherwise in outpatient status;
or otherwise on the temporary disability retired list.
(1) A ‘‘serious injury or illness’’ means an injury or illness incurred by a covered service member in the line
of duty on active duty that may render the service member medically unfit to perform the duties of his or
her office, grade, rank or rating.
(2) ‘‘Outpatient status,’’ with respect to a covered service member, means the status of a member of the
Armed Forces assigned to either a military medical treatment facility as an outpatient; or a unit established
for the purpose of providing command and control of members of the Armed Forces receiving medical care

40 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 as outpatients. In order to care for a covered service member, an eligible employee must be the spouse,
son, daughter, or parent, or next of kin of a covered service member.
(3) An eligible employee is entitled to a combined total of 26 workweeks of leave for any FMLA-qualifying
reason during the ‘‘single 12-month period’’ described in paragraph (c) of this section, provided that the
employee is entitled to no more than 12 weeks of leave for one or more of the following: because of the
birth of a son or daughter of the employee and in order to care for such son or daughter; because of the
placement of a son or daughter with the employee for adoption or foster care; in order to care for the
spouse, son, daughter, or parent with a serious health condition; because of the employee’s own serious
health condition; or because of a qualifying exigency.

A husband and wife who are eligible for FMLA leave and are both employed by us will be limited to a combined
total of 26 workweeks of leave during the ‘‘single 12-month period’’ if the leave is taken for birth of the
employee’s son or daughter or to care for the child after birth, for placement of a son or daughter with the
employee for adoption or foster care, or to care for the child after placement, to care for the employee’s
parent with a serious health condition where a portion of the combined 26 weeks of leave is to care for a
covered service member with a serious injury or illness.

Amount of leave
Except in the case of leave to care for a covered service member with a serious injury or illness, an eligible
employee’s FMLA leave entitlement is limited to a total of 12 workweeks of leave during any 12-month
period. The 12-month period is calculated as follows: a ‘‘rolling’’ 12-month period measured backward from
the date an employee uses any FMLA leave.

Intermittent leave or reduced leave schedule

FMLA leave may be taken ‘‘intermittently or on a reduced leave schedule’’ under certain circumstances.
Intermittent leave is FMLA leave taken in separate blocks of time due to a single qualifying reason. A
reduced leave schedule is a leave schedule that reduces an employee’s usual number of working hours per
workweek, or hours per workday. A reduced leave schedule is a change in the employee’s schedule for a
period of time, normally from full-time too part-time.

Substitution of paid leave

Our employees are required to substitute accrued paid leave for FMLA leave. FMLA leave runs concurrently
with other types of leave.

If you anticipate that you might need time off to deal with family and medical issues, please speak with
your supervisor. We will seriously consider every request on a case-by-case basis.

MAINTENANCE OF EMPLOYEE BENEFITS

Employee payment of group health benefit premiums

Group health plan benefits will be maintained on the same basis as coverage would have been provided
if the employee had been continuously employed during the FMLA leave period. Therefore, any share of

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 41

 group health plan premiums which had been paid by the employee prior to FMLA leave must continue to
be paid by the employee during the FMLA leave period.
If the FMLA leave is substituted paid leave, your share of premiums will be paid by the method normally
used during any paid leave, such as payroll deduction.

If FMLA leave is unpaid, payment is due on the same schedule as payments are made under COBRA which
is the first day of the month.

Before we drop coverage for an employee whose premium payment is late, we will provide written notice
to you that the payment has not been received. Such notice will be mailed to the employee at least 15 days
before coverage is to cease, advising that coverage will be dropped on a specified date at least 15 days
after the date of the letter unless the payment has been received by that date.

Key employee, general rule

A ‘‘key employee’’ is a salaried FMLA-eligible employee who is among the highest paid 10 percent of all
the employees employed by the employer within 75 miles of the employee’s worksite.

Substantial and grievous economic injury

In order to deny restoration to a key employee, we must determine that the restoration of the employee
to employment will cause ‘‘substantial and grievous economic injury’’ to our operations, not whether the
absence of the employee will cause such substantial and grievous injury.

Rights of a key employee

If we believe that reinstatement may be denied to a key employee, we will give written notice to the employee
at the time the employee gives notice of the need for FMLA leave (or when FMLA leave commences, if
earlier) that he or she qualifies as a key employee. At the same time, the employer must also fully inform
the employee of the potential consequences with respect to reinstatement and maintenance of health
benefits if the employer should determine that substantial and grievous economic injury to the employer’s
operations will result if the employee is reinstated from FMLA leave.

Complying with employer policy

While an employee is on FMLA leave, they are required to contact their appropriate supervisor on a weekly
basis to provide a status report. Employees on leave are not allowed to work while out on leave.

Employee notice requirements for unforeseeable FMLA leave

Calling in ‘‘sick’’ without providing more information will not be considered sufficient notice to trigger an
employer’s obligations under the Act.

Certification, general rule

We will require that an employee’s leave to care for the employee’s covered family member with a serious
health condition, or due to the employee’s own serious health condition that makes the employee unable to

42 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 perform one or more of the essential functions of the employee’s position, be supported by a certification
issued by the health care provider of the employee or the employee’s family member. We also require that
an employee’s leave because of a qualifying exigency or to care for a covered service member with a serious
injury or illness be supported by a certification.

Timing
The employee must provide the requested certification to us within 15 calendar days after our request,
unless it is not practicable under the particular circumstances to do so despite the employee’s diligent,
good faith efforts. The employee must provide a complete and sufficient certification to the employer. A
certification is considered incomplete if we receive a certification, but one or more of the applicable entries
have not been completed.

Unforeseeable leave
When the need for FMLA leave is unforeseeable and an employee fails to give notice, the extent to which an
employer may delay FMLA coverage for leave will be determined based upon the facts of the particular case.

Scheduling planned medical treatment

When planning medical treatment, the employee must consult with us and make a reasonable effort to
schedule the treatment so as not to unduly disrupt our operations, subject to the approval of the health
care provider. Employees are ordinarily expected to consult with us prior to the scheduling of treatment in
order to work out a treatment schedule which best suits our needs and the needs of the employee subject
to the approval of the health care provider.

Intermittent leave or leave on a reduced leave schedule must be medically necessary due to a serious health
condition or a serious injury or illness. An employee shall advise the employer, upon request, of the reasons
why the intermittent/reduced leave schedule is necessary and of the schedule for treatment, if applicable.
The employee and employer shall attempt to work out a schedule for such leave that meets the employee’s
needs without unduly disrupting our operations, subject to the approval of the health care provider.

Interaction with Federal and State anti-discrimination laws

We will not discriminate against employees as a result of the approved use of family care or medical leave
or a proper request for such leave. Requests for family care and medical leave will be considered without
regard to race, color, citizenship status, national origin, ancestry, gender, sexual orientation, age, religion,
creed, physical or mental disability, marital status or veteran status.

Personal Leave
If you are ineligible for any other Company leave of absence, Inspirit Senior Living, under certain circumstances,
may grant you a personal leave of absence without pay. A team member must be of full time status and
have worked for the company for no less than 6 months. A written request for a personal leave should
be presented to the Executive Director at least two (2) weeks before the anticipated start of the leave.
If the leave is requested for medical reasons and you are not eligible for leave under the federal Family

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 43

 and Medical Leave Act (FMLA) or any state leave law, medical certification also must be submitted. Your
request will be considered on the basis of staffing requirements and the reasons for the requested leave,
as well as your performance and attendance records. A leave of absence will be granted for a period of up
to 30 days. During your leave, you will not earn vacation, personal or sick time. Health insurance coverage
during your leave will continue, if you submit your share of the monthly premiums to Inspirit Senior Living
in a timely manner, subject to the terms of the plan documents.

When your return to work is anticipated, please notify the Executive Director of your expected return date.
This notification should be made at least one week before the end of your leave.

Upon completion of your personnel leave of absence, Inspirit Senior Living will attempt to return you to your
original job, or a similar position, subject to prevailing business considerations. Reinstatement, however,
is not guaranteed. Failure to advise management of your availability to return to work, failure to return to
work when notified, or continued absence from work beyond the approved time from the Executive Director
will be considered a voluntary resignation of your employment.

6.5 WORKERS’ COMPENSATION LEAVE.

Any employee who is unable to work due to a work related injury or illness and who is eligible for Workers’
Compensation benefits will be provided an unpaid leave for the period required. The first 12 weeks will be
treated concurrently as a family and medical leave under the federal Family Medical Leave Act (“FMLA”)
for employees eligible for FMLA leave.

6.6 BEREAVEMENT LEAVE.

In the event of a death in the immediate family, employees may have up to three working days, with pay, at
their regular straight time rate or base salary, to handle family affairs and attend the funeral. “Immediate
family” is defined as: father, mother, brother, sister, spouse, domestic partner, child, mother-in-law, father-
in- law, grandparents and grandchildren.

6.7 JURY DUTY.

U.S. citizens have a civic obligation to provide jury duty service when called. Employees are entitled up to
fourteen working days, with pay, at their regular straight time or base salary for jury duty.

By state law, employees may not be subject to any adverse personnel action and may not be forced to use
sick leave or vacation. AN employee who has appeared for four or more hours cannot be required to start
a shift after 5 p.m. that day or before 3 a.m. the next morning.

The employee must bring in the jury duty notice as soon as it is received so that appropriate arrangements

44 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 can be made to cover his or her duties. Employees are required to call in or report for work on those days
or parts of days when their presence in court is not required.
6.8 MILITARY LEAVE

Employees called to active military duty, military reserves or National Guard service may be eligible to
receive time off under the Uniformed Service Employment and Reemployment Rights Act of 1994. To
receive time off, employees must provide notice and a copy of their orders to an immediate supervisor.
Military leave is granted on an unpaid basis. You may use your accrued PTO benefit. Upon return with an
honorable discharge, an employee may be entitled to reinstatement and any applicable job benefits they
would have received if present, to the extent provided by law.

Notice should be given as far in advance as reasonable that you intend to leave your position to perform
service. Upon completion of your military service you must notify us of your intent to return to work.

You have the right to continue your health insurance coverage offered by Inspirit Senior Living for up to
24 months while on military leave. Continuation under the USERRA shall run concurrently with Federal
COBRA and state if applicable, to the extent allowed by law. If you choose not to continue with your health
insurance coverage while on military leave you have the right to be re-instated when you are reemployed,
generally without a waiting period or exclusions except for service-connected injuries.

6.9 LEAVE OF ABSENCE POLICY

Regular full-time employees may request an unpaid leave of absence after the exhaustion of paid leave.
A request for a leave of absence must be submitted in writing in advance to the employee’s immediate
supervisor.

Leave of absences that are granted are unpaid, and will not be considered until an employee has exhausted
all appropriate accrued PTO bivalence’s. Continuation of employee benefits during a leave of absence will
addressed on an individual basis, as required by law.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 45

SECTION 7
CONCLUSION OF
EMPLOYMENT
7.1 Resignation
7.2 Exit Interview
7.3 Return of Property
7.4 Final Pay Check
7.5 Abandonment of Job
 7.1 RESIGNATION
Administrative staff, supervisors, and department managers are requested to give at least a four week
notice of their intention to terminate employment. All other staff members are requested to give at least
a two week notice when resigning. Any notice of resignation should be in writing specifying an effective
date of termination. During this notice period NO PTO will be granted or paid. Scheduled days not worked
during the resignation period will be deducted from the PTO bank. Where proper notice to resign is not
given or worked out in full, no terminal PTO will be paid.

7.2 EXIT INTERVIEW

Feedback from you is a valuable source of input for identifying issues and opportunities for improvement
in human resource and operational practice. An exit interview will be requested prior to your departure.

7.3 RETURN OF COMMUNITY PROPERTY

You will be expected to return all community property issued by the last day of your employment. To ensure
a smooth transaction, the Executive Director or your supervisor will meet with you at the time of termination
notice is given to arrange collection of property (i.e. name badge, keys, phone, credit card, walkie talkie).

7.4 FINAL PAY CHECK

Final paychecks will be issued according to the next normal payroll cycle. Last paychecks may be picked up
at the community or if requested, mailed.

7.5 ABANDONMENT OF JOB

If a staff member fails to notify the community of an absence this will be considered a “no call, no show”
episode. One occurrence of a “no call, no show” will be considered a voluntary quit by job abandonment.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 47

SECTION 8
WORK RULES
8.1 Smoking Policy
8.2 Performance Management and Review
8.3 In-Service Training
8.4 No Solicitation
8.5 Tips and Gifts
8.6 Weekend Make-Up Policy
8.7 Weather Emergency
8.8 Change in Personal Data
8.9 Parking
8.10 Company and Resident Property
8.11 Telephone Calls/Cell Phones
8.12 Suggestions and Ideas
8.13 Fire Prevention
8.14 Personal Property
8.15 Travel Expense
 8.1 SMOKING/TOBACCO PRODUCTS AND E-CIGARETTES

Smoking, tobacco products, and e-cigarette use is only permitted in designated smoking area. Smoking,
tobacco products, and e-cigarette use should not take place during working hours. Tobacco products and
e-cigarettes may be used during break and meal time only. Excessive smoke “breaks” will result in smoking
privileges being taken away. Any violation of this policy will result in disciplinary action up to and including
termination.

8.2 PERFORMANCE MANAGEMENT AND REVIEW

Inspirit Senior Living may periodically evaluate an employee’s performance. The goal of a performance review
is to identify areas where an employee excels and area that need improvement. Inspirit Senior Living uses
performance reviews as a tool to determine pay increases, promotion, and/or terminations.

All performance reviews are based on merit, achievement and other factors may include but limited to:

• Quality of work
• Attitude
• Knowledge of work
• Job skills
• Attendance and punctuality
• Teamwork and cooperation
• Compliance with company policy
• Past Performance reviews
• Improvement
• Acceptance of responsibility and constructive feedback

Employees should note that a performance review does not guarantee a pay increase or promotion. Written
performance evaluations may be made at any time to advise employees of unacceptable performance.

8.3 IN-SERVICE TRAINING

All employees are required to attend all In-Service trainings pertaining to their specific job. General Staff
(Town Hall) Meetings also require attendance of ALL employees. Failure to attend in-service meetings or
staff meeting may, at the discretion of management, result in disciplinary action; have a negative effect on
your annual Performance Review and/or termination.

Hours earned for in-service training are counted toward the required ongoing educational requirements.
All training hours are paid.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 49

 8.4 SOLICITATION

The following rules apply to solicitation and distribution of literature on Inspirit Senior Living property:

• No staff member may solicit for any reason on working time or in resident areas.
• No staff member may distribute literature or other materials on working time or in working areas.
• Work time does not include break time, meal times or other specified break periods.

This rule is established for the purpose of preventing interference with resident care and other work duties
and applies to staff members doing soliciting or distribution as well as staff members being solicited or
receiving distribution.

8.5 TIPS AND GIFTS

Staff members shall not request and/or accept any remuneration, tip, gratuity, or loan, either in money or
material from residents, family or applicants. Violation will result in corrective action including the possibility
of termination.

8.6 WEEKEND MAKE-UP POLICY

Weekend attendance is critical to ensure that there is quality and consistency 7 seven days a week. It is
the policy of Inspirit Senior Living that is any staff member who does not work their scheduled weekend
will be require to make-up that weekend day(s) on another weekend day(s) determined by your supervisor.

It will be the responsibility of the staff member to find a replacement for a weekend shift for a requested day
off. The change must be in writing to the supervisor and both staff members’ signatures acknowledging the
change. On full weekend (Saturday and Sunday) may be requested off using PTO time only per calendar year.

8.7 WEATHER EMERGENCY

Due to the nature of the service and care which we provide to residents of Inspirit Senior Living in times
of inclement weather or other emergency situations, we ask that all staff members make every reasonable
effort possible to maintain their work schedules if not then disciplinary action will be taken. Only pre-
scheduled PTO time will be honored.

Inspirit Senior Living will provide meals, compensation, and sleeping arrangements.

50 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 8.8 CHANGE IN PERSONAL DATA

We need to maintain up-to-date information about you so that we are able to aid you and/or family in
matters of personal emergency and have accurate information for state and federal payroll taxes (i.e. W-2’s
and quarterly filing). Change in name, address, phone number, and material status, numbers of dependents
or change in next of kin and/or beneficiaries should be promptly provided to the Executive Director of
Human Resource/Payroll Director.

8.9 PARKING

Employees may park only in areas designated as “Employee Parking”. Inspirit Senior Living is not responsible
for any damage to or theft of or from any vehicle parked on the community’s property

8.10 COMPANY AND RESIDENT PROPERTY

Residents have the right to expect that their property will be safe while they are living with us. Therefore,
staff members will be held responsible for negligent and willful destruction of property belonging to both
residents and the community. The presence of unauthorized or suspicious persons in or near the community
premise should be immediately reported to the Executive Director.

All staff members are responsible for ensuring that each resident’s personal effects are safe and in their
proper places. Loss by residents should be reported to your supervisor immediately.

The community provides access to a variety of equipment and services. Community property and services
are for work-related use only. No community property is to be removed from the premises without prior
approval. All employees are encouraged to exercise care when using or operating property equipment.
Please report any damaged or improperly functioning equipment to your supervisor immediately.

The community reserves the right to inspect all community property, view all forms of communication
including internet access without notice to employees and in the absence of the employee.

Downloading any programs, data, or other material, is prohibited unless first obtaining authorization by
Inspirit Senior Living.

8.11 TELEPHONE CALLS/CELL PHONES

Staff members are required to answer the telephone promptly and courteously, giving the community name,
your department and name. personal telephone calls may be made and received only in case of emergency.
During breaks personal phone calls made be made. Cell phone use is NOT permitted during working hours.

INSPIRIT SENIOR LIVING | EMPLOYEE HANDBOOK | OCTOBER 2016 51

 8.12 SUGGESTIONS AND IDEAS

We are always interested in your constructive ideas and suggestions for improving our community. Your
suggestions should be submitted in writing to the Executive Director.

After your suggestion is evaluated, you will be notified whether or not it is feasible to put into practice.

Management believes that suggestions indicate initiative on part if a staff member. With your approval, we
will place the written suggestion in your personnel file and take it into consideration at the time of your
performance review.

8.13 FIRE PREVENTION

Each employee must be familiar with the location of the fire extinguisher and fire alarms/pulls, as well as
established policies and procedures for fire safety. The fire safety procedures, as well as evacuation routes,
are posted in each department. Each staff member is expected to participate in fire drills while on duty.

8.14 PERSONAL PROPERTY

Inspirit Senior Living encourages all employees not to bring person property to work. Inspirit Senior Living
will not be responsible lost, stolen, or damaged personal property. We will not be responsible for valuable
personal items, phones, jewelry, iPads/tablets that are lost, stolen or damaged. There are however probated
items they may not be brought into the community.

This list is not limited to the following, Inspirit Senior Living reserves the right to prohibit other items that
may be considered unacceptable:

• Weapon of any kind, including fire arms.

• Intoxicating beverages, illegal drugs, narcotics.
• Offensive or demeaning items.
• Sexually suggestive items.

8.15 TRAVEL EXPENSE

All expenses incurred in the course of business travel should be submitted to your supervisor. Your expense
report should be timely and have all receipts attached. All travel must be pre-approved by your supervisor.
Reasonable business travel may include, but not limited to, mileage, vehicle rental, hotels, meals.

52 EMPLOYEE HANDBOOK | OCTOBER 2016 | INSPIRIT SENIOR LIVING

 AT-WILL EMPLOYMENT AGREEMENT &
ACKNOWLEDGEMENT OF RECEIPT OF
EMPLOYEE HANDBOOK

Employee: _________________

I acknowledge that I have been provided with a copy of the Inspirit Senior Living (the “Company”) Employee
Handbook, which contains important information on the Company’s policies, procedures and benefits,
including the policies on Anti-Harassment/Discrimination, Substance Use and Abuse and Confidentiality. I
understand that I am responsible for familiarizing myself with the policies in this handbook and agree to
comply with all rules applicable to me.

I understand and agree that the policies described in the handbook are intended as a guide only and do not
constitute a contract of employment. I specifically understand and agree that the employment relationship
between the Company and me is at-will and can be terminated by the Company or me at any time, with or
without cause or notice. Furthermore, the Company has the right to modify or alter my position, or impose
any form of discipline it deems appropriate at any time. Nothing in this handbook is intended to modify the
Company’s policy of at-will employment. The at-will employment relationship may not be modified except
by a specific written agreement signed by me and an authorized representative of the Company. This is
the entire agreement between the Company and me regarding this subject. All prior or contemporaneous
inconsistent agreements are superseded.

I understand that the Company reserves the right to make changes to its policies, procedures or benefits at
any time at its discretion. However, the at-will employment agreement can be modified only in the manner
specified above. I further understand that the Company reserves the right to interpret its policies or to
vary its procedures as it deems necessary or appropriate.

I have received the Company Employee Handbook. I have read (or will read) and agree to abide by the
policies and procedures contained in the Handbook.

By: ______________________________________ Date: __________________

Director of Human Resource/Executive Director

By: ______________________________________ Date: __________________

Employee
 AT-WILL EMPLOYMENT AGREEMENT &
ACKNOWLEDGEMENT OF RECEIPT OF
EMPLOYEE HANDBOOK

Employee: _________________

I acknowledge that I have been provided with a copy of the Inspirit Senior Living (the “Company”) Employee
Handbook, which contains important information on the Company’s policies, procedures and benefits,
including the policies on Anti-Harassment/Discrimination, Substance Use and Abuse and Confidentiality. I
understand that I am responsible for familiarizing myself with the policies in this handbook and agree to
comply with all rules applicable to me.

I understand and agree that the policies described in the handbook are intended as a guide only and do not
constitute a contract of employment. I specifically understand and agree that the employment relationship
between the Company and me is at-will and can be terminated by the Company or me at any time, with or
without cause or notice. Furthermore, the Company has the right to modify or alter my position, or impose
any form of discipline it deems appropriate at any time. Nothing in this handbook is intended to modify the
Company’s policy of at-will employment. The at-will employment relationship may not be modified except
by a specific written agreement signed by me and an authorized representative of the Company. This is
the entire agreement between the Company and me regarding this subject. All prior or contemporaneous
inconsistent agreements are superseded.

I understand that the Company reserves the right to make changes to its policies, procedures or benefits at
any time at its discretion. However, the at-will employment agreement can be modified only in the manner
specified above. I further understand that the Company reserves the right to interpret its policies or to
vary its procedures as it deems necessary or appropriate.

I have received the Company Employee Handbook. I have read (or will read) and agree to abide by the
policies and procedures contained in the Handbook.

By: _____________________________________ Date: __________________

Director of Human Resource/Executive Director

By: ___________________________________ Date: __________________

Employee
CORPORATE OFFICES:
8000 WESTPARK DRIVE
SUITE 495
MCLEAN, VA 22102
703-815-5800

INSPIRITSENIORLIVING.COM