NORTH AMERICAN SERVICES GROUP DRUG & ALCOHOL TESTING POLICY

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1 NORTH AMERICAN SERVICES GROUP DRUG & ALCOHOL TESTING POLICY This is the policy of North American Services Group and its affiliates, North American Industrial Services, North American Flight Services, North American Services Group, LLC, MUSSOP, Inc. and NAES Northeast, LLC (collectively referred to below as the Company ) on drug and alcohol testing. All questions about this policy should be directed to your supervisor or the Human Resources Department. I. General Statement A healthy and productive work force, safe working conditions free from the effects of drugs and alcohol, and the maintenance of the quality of the Company and its services are of the utmost importance to the Company, its employees, its contractors and the general public. Drug and alcohol abuse create a variety of workplace problems, including increased injuries on the job, increased absenteeism, increased financial burden on health and benefit programs, increased workplace theft, decreased employee morale, decreased productivity, and a decline in the quality of products and services. The Company intends to provide a safe alcohol and drug-free workplace. Nothing in this Policy is intended or implies that employment with the Company is other than employment at will. This means that the employee can quit at any time for any or no reason just as the Company can terminate the employment relationship at any time for any or no reason. II. Definitions For the purposes of this Policy: A. Alcohol means ethyl alcohol or ethanol. B. Drugs or controlled substance means any substance recognized as a drug in the United States Pharmacopeia, the National Formulary, the Homeopathic Pharmacopeia, or other drug compendia, or supplement to any of those compendia. C. Employee means any person in the service of the Company for compensation of any kind. D. Prospective employee means any person who has made application to the Company, whether written or oral, to become an employee. E. Contractor means any individual, whether through a business entity or on his or her own, performs contract services for the Company. F. Prospective contractor means any individual, whether through a business entity or on his or her own, who has approached the Company about performing contract services for it. G. Sample means urine, blood, breath, saliva, or hair.

2 III. Policy Against Use of Drugs or Alcohol A. The Company prohibits the buying, selling, manufacture, transportation, possession, distribution, consumption or use of alcohol or controlled substances not required by a physician s prescription on Company premises or at any time during working hours. B. The Company further prohibits the consumption or use of alcohol or controlled substances not required by a physician s prescription off Company premises or during non-working hours where such use might, in the Company s judgment, impair the employee s work performance, affect the safety and welfare of other employees on the job or the Company s customers, or otherwise interfere with the Company s interests. C. The use of controlled substances in accordance with a physician s prescription will not be the basis for action by the Company under Section VII, below, unless such use might, in the Company s judgment, impair the employee s work performance or otherwise interfere with the Company s interests. IV. Individuals Subject to Testing A. Prospective Employees. The Company may require a prospective employee to submit to testing for controlled substances as a condition of employment or contract. B. Employees. As permitted by law, the Company may require, and an employee must submit to, testing for controlled substances and alcohol, including random testing, whenever the Company has reason to believe that the employee has violated the policies set forth in Section III or for the following purposes: 1. Investigation of possible individual employee impairment; 2. Investigation of accidents in the workplace or incidents of workplace theft; 3. Maintenance of safety for employees, customers or the general public; 4. Maintenance of productivity, quality of products or services, or security of property or information; 5. Compliance with regulations mandated by federal, state or local government. C. Management. Managers and supervisors will be tested under the same circumstances as other employees. V. Collection and Testing A. All sample collection and testing for controlled substances or alcohol shall be performed in accordance with standard laboratory operating procedures as mandated by applicable law.

3 B. Controlled substance testing will be by the Enzyme Multiplied Immunoassay Test ( EMIT ) or a gas chromatographic procedure or any other scientifically accepted testing method the Company may determine. If the initial test is positive, a confirmatory test will be done by gas chromatography mass spectrometry ( GC/MS ) or gas chromatography testing or any other scientifically accepted testing method the Company may determine. C. The Company will test for alcohol by urinalysis or any other scientifically accepted method the Company may determine. D. To ensure reliability, the Company will require presentation of reliable identification to the person collecting the samples. E. If any employee refuses to submit to the drug or alcohol screening test or tests or tampers with a sample, including but not limited to producing a cold sample or a diluted sample, such refusal or tampering may result in disciplinary action up to and including termination. F. If any prospective employee refuses to give written consent to a drug screening test or tampers with a sample, including but not limited to producing a cold sample or a diluted sample, such refusal or tampering may result in the Company s failure to take any further action toward employment. VI. Costs of Testing and Work Time A. Any controlled substance or alcohol testing shall occur during or immediately after the regular work period and shall be deemed work time for purposes of compensation and benefits for current employees and contractors. B. The Company shall pay all costs of testing, including the cost of transportation, if the testing of a current employee or contractor is conducted at a place other than the workplace. C. The Company does not compensate applicants for pre-employment drug testing unless required otherwise by state or federal law. VII. Company Action Upon receipt of a positive controlled substance or alcohol test result, an employee s refusal to provide a sample, an employee s tampering with a sample or an employee s producing a cold or diluted sample, the Company may, in its discretion: A. Require that the person enroll at his/her own expense in a Company-approved rehabilitation, treatment, or counseling program that may include additional controlled substance or alcohol testing as a condition of continued employment; B. Suspend the person with or without pay for a period of time; C. Terminate the employment relationship; D. Refuse to hire a prospective employee;

4 E. Take other disciplinary measures in conformance with the Company s usual policies and procedures. VIII. Confidentiality All information, interviews, reports, statements, memoranda, or test results received by the Company through controlled substance and alcohol testing are confidential communications and will be processed through the Company on a need to know basis and will only be used in a proceeding related to an action taken by the Company under Section VII or in defense of any action brought against the Company. IX. Notice The Company s written policy for drug and alcohol testing will be distributed to employees and be available for review by prospective employees at various Company locations.

5 INFORMED CONSENT I understand that according to the policy of North American Services Group and its affiliates, North American Industrial Services, North American Flight Services and NAES Northeast, LLC (collectively referred to below as the Company ), which I have read and understand, I am required to submit a sample of my urine and/or blood for chemical analysis. I understand that the sample collection and analysis will be conducted by trained personnel at independent facilities qualified to perform these services and that a documented chain of specimen custody exists to assure the identity and integrity of my specimens throughout the collection and testing process. The purpose of this analysis is to determine the absence or presence of drugs or alcohol. I consent freely and voluntarily to the Company s request for urine and/or blood specimens and to the release of test results to an authorized representative of the Company. I understand that if the test results indicate the presence of drugs and/or alcohol, I may be subject to disciplinary action up to and including termination by the Company. Employee s Signature Witness Print Name Position Date Date

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