BHI- Corp, Office- Binder docs updated 10-16-combined

BHISeniorLivingMissionStatement

ThemissionofBHISeniorLiving,Inc.(“BHISeniorLiving,”“BHI”or“Company”),is toenhancethequalityoflifeofolderadultswithinasecureenvironmentwhichsupports theirneeds,values,interests,andindependencewhileencouragingpersonalandspiritual growth.

BHICOREVALUES:

Respect: Valuingtheworth,dignity,anddiversityofeveryone.

Compassion: Sensitivitytotheneedsandrightsofallpersons.

Integrity: Maintainingthehigheststandardsoftrustandhonesty.

PersonalDevelopment: Acommitmenttolifelonglearningandpersonalgrowth.

CustomerSatisfaction: Providingqualityservicethatexceedsexpectations

Advocacy: Speakingandactingonbehalfofothers.

Stewardship: Usinghuman,environmental,andfinancialresourceswisely

ServantLeadership: Inthespiritofservingothersfirst,werespectandhonorourChristianHeritage

IN MISSION

A CULTURE OF CARE, GROWING WITH PURPOSE.

accomplish more – for each other and for the residents we serve.

At BHI Senior Living, being United in Mission stepping up as one team. We work across departments support shared goals, and adapt when needed. In ret we experience the strength of a connected workplace where purpose and teamwork fuel everything we do.

When you GIVE...

Flexibility to collaborate across roles and teams

Commitment to shared success

Engagement in cross-campus or organization-wide initiatives

A strong support system of mission-driven teammates

Opportunities to contribute beyond your immediate role

A culture that celebrates teamwork and unity

“We’re always looking at how we can best serve our residents. They are always the top priority. If you’re focused on them, everything else will sort itself out.“

-Jennifer Zvokel, Director of Community Partnerships | Corporate Office

United in Mission in Action

During a major snowstorm, Leah knew how essential it was to have caregivers present for residents. She personally drove to pick up team members and bring them safely to work. Her actions ensured residents continued receiving the care they needed.

-Leah Jeffries, Associate Executive Director | Westminster Village North

Simple Ways to Be United in Mission

Jump in to help another department during a busy shift.

Invite a new teammate to join an activity or team lunch.

Volunteer for an interdepartmental committee.

Praise a teammate for a job well done, and be specific about naming what you appreciated about their action and the impact that it had.

how someone

A CULTURE OF CARE, GROWING WITH PURPOSE.

We show up with empathy, presence, and respect.

Lead with Compassion means more than just showing kindness—it’s about truly understanding the residents we serve. We ask our team members to model empathy, build trusting relationships, and bring their full hearts to every interaction. In return, they experience deep fulfillment, a culture of respect, and the knowledge that their work matters.

Consistent empathy, even during challenging days

Deep listening and emotional support to residents and teammates

A commitment to setting the tone through compassionate actions

A workplace grounded in mutual trust and care

A profound sense of purpose in your work

A team culture that values each individual’s contributions

When a resident was missing his family during the pandemic, Rhonda and a co-worker baked and delivered a fresh pumpkin pie because they wanted him to know he was cared for and to have some home cooking for the holidays.

-Rhonda Burton, Housekeeping | Four Seasons

Dana has built relationships with many generations of families, with many residents remembering her from when their own parents lived at Hoosier Village. She takes pride in positively encouraging hesitant residents to participate in activities and self-care.

-Dana Brooks, CNA | Hoosier Village

Simple Ways to Lead with Compassion

Take time to ask a coworker how they’re really doing.

Help a teammate finish a tough task without being asked.

Listen fully before offering a solution.

Recognize when a resident or teammate might need extra emotional support.

A CULTURE OF CARE, GROWING WITH PURPOSE.

GROW & THRIVE

At BHI Senior Living, Growing and Thriving is more than a goal—it’s a shared journey. Team members are encouraged to seek out learning opportunities, embrace feedback, and actively shape their professional path. We believe in a culture that values curiosity and continuous improvement.

In return, we offer clear career pathways and support for educational development, including funding for training & certifications. It’s an environment where initiative is celebrated, and every individual is empowered to thrive.

When you GIVE...

Commitment to continuous learning

Openness to feedback and self-improvement

Initiative in pursuing growth opportunities

You GET…

Support for education and certification through the BHI Foundation

A culture that values innovation and progress

Clear pathways for advancement and leadership

Despite having no previous related experience, Jake learned HVAC and electrical work thanks to support from BHI’s scholarship fund and on-thejob training—and he’s now considering pursuing CPR training and a CNA certification to expand his impact.

-Jake Bradley, Maintenance | The Barrington of Carmel

GROW & THRIVE

Cindy used BHI’s Foundation to fund her RN program and tuition reimbursement for her LPN training, allowing her to climb the career ladder from QMA to Medical Records to Director of Nursing. She credits internal mentors for continuing to guide her through complex regulations and policies as she grew into leadership.

-Cindy Reecer, Director of Nursing | Wesley Manor

Simple Ways to Grow and Thrive

Reflect on recent feedback and identify one skill you want to strengthen.

Volunteer for a project or committee that stretches your strengths in new ways.

Talk with your leader about your goals—big or small.

Take the next step toward a class, certification, or training.

● TheAgingpopulation(majority65+)

Population Served

● Peoplewithcommonchronicconditions(e.g.,dementia, arthritis,diabetes)

● Peoplewithculturalandlanguagediversity

● Peoplewithvaryinglevelsofphysicalandcognitiveability

● Peoplewithdifferentsocialandemotionalneeds

Enrolling in Benefits Welcome!

BHI Senior Living is proud to offer a comprehensive, competitive benefits package designed to meet the diverse needs of our employees at every stage of life. This 2025 employee benefits guide outlines the resources available to help you evaluate your benefit options, understand the benefits enrollment process, and make the best decisions for yourself, your family, and your lifestyle.

The contents of this guide are not all inclusive, nor is the guide intended to be a legal document. For the most current information, please consult our Summary Plan Description (SPD), which is available on the UKG employee web portal. If you have questions about enrollment procedures or any general benefits questions, please contact Human Resources.

Who Is Eligible?

If you are a BHI Senior Living full‑time employee scheduled to work 30 or more hours per week, you are eligible to enroll in the benefits described in this guide. If you are a BHI Senior Living part time employee scheduled to work 20 hours or more, but less than 30 hours per week, you are eligible to enroll in a specified Medical plan, Dental, Vision, Voluntary Life, and Disability.

The following family members are eligible for Medical, Dental, and Vision coverage: legal spouse and children under the age of 26, consisting of natural children, stepchildren (who are filed as an exemption on tax return, in legal custody, and financially dependent on the employee or employee’s spouse), eligible foster child of the taxpayer, adopted children, children placed for adoption, and children under legal guardianship.

Go to your UKG web benefits portal via account.mybenefitsportal.com/bhi/.

If you have any questions please reach out to human resources.

How to Enroll

All benefit elections for Open Enrollment and new hires can be made through your employee access online through UKG. Once you have made your elections, you will not be able to change them again until the next Open Enrollment period, unless you have a qualifying life event.

When to Enroll

The Open Enrollment period for 2025 runs from November 1 through November 15. The benefits you elect during Open Enrollment will be effective from January 1, 2025, through December 31, 2025. New employees are eligible for all benefits available to you depending on your status, the first day of the month following 30 days of employment.

How to Make Changes

Unless you have a qualifying life event, you cannot make changes to the benefits you elect until the next Open Enrollment period. Qualifying life events include marriage; divorce; legal separation; birth or adoption of a child; change in child’s dependent status; death of spouse, child, or other qualified dependent; change in residence due to an employment transfer for you or your spouse; commencement or termination of employment; or change in spouse’s benefits or employment status.

Medical and Prescription Drug Coverage

BHI will offer two plan options for 2025, a Qualified High Deductible Health Plan and a Buy Up PPO plan. The Buy Up Plan, which is a PPO plan, will offer a lower deductible, with higher per paycheck premiums, while the QHDHP will offer a higher deductible, with lower per paycheck premiums and the ability to open an Health Savings Account (HSA). Please note the QHDHP plan is embedded. An embedded deductible means that no one person on the QHDHP plan will pay more than their individual deductible in order for their covered services to be paid at 100%. Both plans offer Medical coverage through Allied. Prescription Drug coverage will be offered through National CooperativeRx for the 2025 plan year. Aetna will be Allied’s network for 2025. Please reference page 7 for how to find an in network provider. Please see the summary below to determine which plan works best for you and your family.

In Network Services

There are no changes to the 2025 Buy Up Plan. The Qualified High Deductible Health Plan has a slight increase to the deductible and out of pocket maximum in order to remain compliant with IRS regulations.

Visit

$25 copay

$50 copay

copay

Room $200 copay, then 20%

Prescription Drugs

Out of Pocket Limit (Individual/Family)

Brand Nonformulary Brand Specialty Drugs

$2,100/$4,200

$10 copay

$60 copay

$95 copay 20% to $200 max N/A

then 100% covered

Be Informed About the Qualified High Deductible Plan

If you enroll in the qualified high‑deductible health plan, BHI will help seed your HSA annually!

$250 for single only coverage and $500 for dependent tiers. For part time employees, BHI offers $150 HSA seed for single only coverage and $300 for dependent tiers. New hires HSA seed will be prorated based on the start date month.

BHI Senior Living Wellness Program

PORTAL LOGIN INSTRUCTIONS

Existing Users: If you have logged into your Wellness Portal in the past, please continue to use your existing Username and Password Otherwise, please create an account by following the instructions below. Forgot Your Username Or Password?

Go to w www wellworksforyoulogin com

Click the link F Forgot Username or Forgot Password

Follow the instructions to retrieve your Username or reset your Password

If issues persist, please contact Wellworks For You at 8 800-4254657

Click the link to create an account as a N New Member

Enter your C Company ID: 1 12575

Select Y Yes to confirm the company name listed is correct

Create a Username, Password, and enter the required personal information

SPOUSES ONLY: set the A Account Type to S Spouse, and enter the Username of the employee in the P Primary Username field to link the accounts

Accept the terms of the consent form

Enter a valid mobile number and save by clicking U Update Communication Settings

How to Find an Aetna PPO Network Provider

Your plan contains enhanced benefits through network providers powered by Aetna Signature Administrators PPO Network. Benefits are generally paid at a higher level when using network hospitals and network physicians than when using non network providers. For online inquiry to locate a network provider near you, or to verify that a provider is in the Aetna PPO network, visit alliedbenefit.com, or for direct assistance in locating network providers, call Allied at 866 455 8727.

STEP 1:Go to alliedbenefit.com, click on the “Provider Networks” tab, and select “Aetna Signature Administrators.”

STEP 2:Enter your home location and shift the tool to look within a distance near to you.

STEP 3:Type or click the type of provider you would like to use.

STEP 4:Narrow your search by selecting the provider type.

STEP 5:Browse through the search results to obtain more information on the provider matches.

Flu Shot and Immunizations

Staying healthy is more important than ever. You can get a no cost flu shot at any network pharmacy.

■ Keeping an eye on your health? Flu shots can help everyone stay healthier during flu season.

■ Out and about? Get your flu shot at more than 68,000 convenient locations, including CVS Pharmacy.

■ What will you need? Just take your insurance card and valid photo ID.

■ Is it really no cost? Yes! No copay and no cost to you.

Visit caremark.com to find a vaccine pharmacy in your network.

Immunizations are available from many retail pharmacies. Check with your local pharmacy regarding available services as these may vary by location. The Advisory Committee on Immunization Practices (ACIP) and Centers for Disease Control (CDC) recommended immunization schedules for children and adults may be found at cdc.gov/vaccines

Telemedicine — Teladoc

For 2025, employees will continue to have access to Telemedicine! Telemedicine is free to use and gives you access to care online anytime with Teladoc without having to leave the comfort of your home.

■ Talk to a doctor by phone or video within minutes.

■ Save money! Virtual visits can be a better alternative than going to the emergency room or urgent care center, as services can be provided for a lower cost than an in person visit.

■ Save time by skipping long waits in a doctor’s office.

■ Available 24 hours a day, 365 days a year for cold and flu symptoms, allergies, ear infections, rash and skin problems, and more!

Activate Your Account Today!

■ Teladoc.com or call 800 Teladoc (800 835 2362).

2025 Medical Cost

Bi weekly payroll deductions (24 pays) are shown below. Please note that the “Wellness Rates” outlined below include wellness premium credits or surcharges you may have earned/received. Please reference page 6 for details on the program and credits/surcharges. If you are hired or newly benefit eligible between September 1, 2024, and December 1, 2024, you are NOT required or eligible to complete wellness activities in 2024 to earn the wellness credits for 2025, but you are encouraged to access the Wellness Portal to view activities and educational resources.

Wise Use of Medical Plan

If you are enrolled in the BHI Buy Up PPO Plan, you will have the opportunity to access the US Imaging free VIP appointment scheduling service to coordinate your advanced diagnostic imaging needs. After your doctor prescribes an advanced imaging test such as an MRI, CT, or PET scan, simply call the US Imaging service, and we will locate a fully credentialed, high quality facility to perform your test at a time and location that meets your needs. In addition, when you schedule your procedure through US Imaging, your out of pocket cost will be $0 if you are on the Buy Up Plan. The Imaging Plan is available to only those enrolled in the Buy-Up Plan.

The US Imaging Value

Members often choose a radiology facility out of a directory or from a list provided by their referring physician or plan. By calling US Imaging, you can be assured that you are receiving your test at a high quality facility. Each of the 2,400 freestanding facilities in the US Imaging network has been credentialed to ensure that its equipment meets nationally recognized quality standards.

What You Need to Know About Your Benefit

■ STEP 1: Your Medical insurance ID card includes your US Imaging benefit information on the back.

■ STEP 2: When your physician prescribes an MRI, CT, or PET scan, you or your doctor can call US Imaging’s toll free number at 877 874 6385 to schedule your appointment. Please have your prescription available.

■ STEP 3: A US Imaging scheduling specialist will work with you to receive a VIP appointment with a date, time, and location that is convenient for YOU.

By scheduling your MRI, CT, or PET scan using the US Imaging appointment scheduling service, you will receive the following benefits:

■ VIP appointment scheduling within 24 48 hours

■ Preferred after hours and weekend appointments

■ Directions to the facility

■ A facility that has been credentialed for quality

How Does Scheduling Work?

Call our toll free number 877 874 6385 or visit usimagingnetwork.com.

Please note: USI providers are also listed on the alliedbenefit.com website. To conduct a search, click on Tools and Resources, select Other Resources, select US Imaging Facility Search, enter a ZIP code, and click search.

Dental Coverage

Delta Dental | DeltaDental.com | 800-524-0149

Delta Dental will continue to be our Dental insurance partner for 2025. With this coverage, you have broad access to in‑network providers. Participation is voluntary, and employees may choose between the Low and High Plans. With a more expansive selection of in network providers, you have a better chance of avoiding additional out‑of‑pocket exposure or “balance billing.” Balance billing is the practice of out of network providers billing the patient for amounts that exceed the reimbursement amount under a patient’s Dental plan. The patient is responsible for the additional amounts charged. Therefore, it is important to stay in network to avoid excess charges.

Applies to type B and C services Individual: $50 Family: $150

To find a provider, visit DeltaDental.com and select FIND A DENTIST. Enter your criteria to search by location or for a specific dentist or practice. Make sure to select the networks Delta Dental PPO and Delta Dental Premier.

Or call customer service at 800 524 0149.

Your Dental Cost

Vision Coverage

Eyemed | eyemed.com | 866-804-0982

EyeMed will continue to be our Vision insurance partner for 2025. An outline of the vision care services is listed in the table below for in‑network as well as for out‑of‑network reimbursement.

Allowed Frequency

Standard Corrective Lenses

Contact Lenses

Exam With Dilation

1 per 12 months 1 per 12 months 1 per 24 months

1 per 12 months

$10 copay

Retinal Imaging Up to $39 copay

$130 allowance and 20% off remaining balance

Standard Lenses Single Vision

Progressive

Lens Options

Contact Lenses

Fitting and Evaluation Elective

Medically Necessary

$25 copay

$25 copay

$25 copay

$25 copay

$80 copay

Solid tints: $15 copay

Scratch coating: $15 copay

Standard polycarbonate: $40 copay

Standard anti reflective: $45 copay

Other add ons and services: 20% off retail price

$40 copay

$130 allowance and 15% off remaining balance Covered in full

to $40

to $70

to $30

to $50

to $70

to $70

to $50

Applied to the allowance for the applicable corrective lenses.

to $70

to $210

Health Savings Account (HSA)

HealthEquity | healthequity.com | 866-346-5800

A Health Savings Account (HSA) will be available for all employees enrolled in the Qualified High Deductible Health Plan (QHDHP). An HSA is a personal healthcare bank account that you can use to pay out‑of‑pocket medical expenses with pre‑tax dollars. You own and administer your Health Savings Account. You determine how much you will contribute to your account, when to use your money to pay for qualified medical expenses, and when to reimburse yourself. HSAs allow you to save and roll over money if you do not spend it in the calendar year. This is a bank account; you must have money in the account before you can spend it. The money in this account is always yours. If you change health plans or jobs, the money in the account is yours to keep.

You are eligible to open and fund an HSA if:

■ You are covered by an HSA-eligible High Deductible Health Plan, such as the BHI HDHP for 2025.

■ You are not covered by your spouse’s health plan (unless it is a qualified HDHP), Flexible Spending Account (FSA), or Health Reimbursement Account (HRA).

■ You are not enrolled in the BHI Healthcare FSA.

■ You are not eligible to be claimed as a dependent on someone else’s tax return.

■ You are not enrolled in Medicare, TRICARE, or TRICARE For Life.

■ You have not received Veterans Administration benefits in the past three months.

Qualified Expenses

You can use HSA money to pay for qualified medical expenses now or in the future. Your HSA can be used for your expenses and those of your spouse and dependents, even if they are not covered by the HDHP. Qualified medical expenses are defined by the IRS. These expenses include doctor’s office visits, deductibles, coinsurance, and prescription drugs. IRS Publication 502 provides a complete list of eligible expenses and can be found at irs.gov.

Eligible Examples

■ Medical expenses: coinsurance and deductibles

■ Dental expenses: exams, cleanings, X rays, and braces

■ Vision expenses: exams, contact lenses and supplies, eyeglasses, and laser eye surgery

Professional services: physical therapy, chiropractic, and acupuncture services

■ Prescription drugs and insulin

■ Over the counter healthcare items: bandages, pregnancy test kits, blood pressure monitors, etc.

Ineligible Examples

■ Babysitting

■ Cosmetic surgery

■ Funeral expenses

■ Hair transplant

■ Health club dues

■ Insurance premiums

■ Teeth whitening

BHI has partnered with Health Equity to administer the HSAs opened by employees participating in the HDHP. You can elect to participate in the HSA and have deductions taken on a pre tax basis and deposited into your account.

There Are Three Ways to Maximize Your Tax Savings

Contributions to an HSA are tax‑free (they can be made through payroll deduction on a pre‑tax basis when you open an account with Health Equity).

■ The money in this account (including interest and investment earnings) grows tax-free.

■ As long as the funds are used to pay for qualified medical expenses, they are spent tax-free.

HSA Funding and Limits

Employees are responsible for tracking annual limits. Funding limits include both employer and employee contributions. The BHI employer contribution will count towards the maximums listed below.

The 2025 IRS maximum contributions for these accounts are:

■ $4,300 for employee-only coverage.

■ $8,550 for all other tiers.

Catch-Up Contribution

Individuals ages 55 and older may make an additional $1,000 annual contribution to their HSAs.

Flexible Spending Accounts (FSAs)

BHI Senior Living, Inc., provides you the opportunity to pay for out of pocket Medical, Dental, and Vision care expenses with pre tax dollars through a Flexible Spending Account. You must enroll/re enroll in the plan to participate for the plan year January 1st to December 31st, 2025. You can save approximately 30% of each dollar spent on these expenses when you participate in an FSA.

Please note, if you enroll in the QHDHP plan, you will only be eligible for a Limited Purpose FSA and/ or a Dependent Care FSA.

A Medical Reimbursement Account is used to reimburse out of pocket Medical, Dental, and Vision expenses incurred by you and your dependents. Contributions to your FSA come out of your paycheck before any taxes are taken out. This means that you don’t pay federal income tax, Social Security taxes, or state and local income taxes on the portion of your paycheck you contribute to your FSA. You should contribute the amount of money you expect to pay out of pocket for eligible expenses for the plan period. If you have funds remaining in your Medical Reimbursement Account at the end of the plan year, you may carry them over into the next plan year. The maximum you may carry over is $640. Anything over the $640 will be forfeited at the close of the 2025 plan year. You have until March 31, 2025, to submit claims for 2024 expenses. A Limited Purpose Flexible Spending Arrangement (LPFSA) is a tax advantaged account that allows you to use pre‑tax dollars for eligible dental and vision expenses. Unlike standard FSAs, LPFSAs are specifically designed to complement Health Savings Accounts (HSAs), meaning you can use them for certain expenses while still contributing to your HSA. You can use them to cover dental, vision, and preventative care costs.

A Dependent Care FSA is also available to BHI employees. The Dependent Care FSA is limited to $5,000, subject to IRS change.

A Dependent Care Flexible Spending Account (FSA) is a pre tax benefit account used to pay for eligible dependent care services, such as preschool, summer day camp, before‑ or after‑ school programs, and child or adult daycare. This account helps you save money on dependent care expenses by reducing your taxable income. By using pre tax dollars, you can lower your overall tax burden while ensuring your dependents receive necessary care.

The maximum that you can contribute to the Medical Reimbursement Flexible Spending Account is $3,200 per year. The minimum you may contribute per year is $125.

The following example shows how you can save money with a Flexible Spending Account.

Bob and Jane’s combined gross income is $30,000. They have two children and file their income taxes jointly. Since Bob and Jane expect to spend $2,000 in adult orthodontia and $3,300 for day care in next plan year, they decide to direct a total of $5,300 into their FSAs.

Life Coverage

Basic Life and Accidental Death and Dismemberment Insurance

Mutual of Omaha | mutualofomaha.com | 800-775-8805

Be sure to update/review your beneficiaries listed in UKG

For your peace of mind and the financial protection of your family, BHI provides eligible employees with a Basic Life insurance benefit and an Accidental Death and Dismemberment benefit. You are automatically covered for the amount of 1 x your annual salary to a maximum of $100,000.

Part time employees are eligible for a flat amount of $15,000. This benefit is at no cost to you. Each year it is important that you review and update your beneficiary.

Supplemental Life Insurance

We recognize you and your family have specific needs, and our company paid Life insurance policy may not be enough to ensure your financial security if your income were suddenly lost. If necessary, we offer a Supplemental Life insurance option with competitive group rates so you can purchase and secure the financial protection you need.

Voluntary Life insurance is available to all employees who are scheduled to work 20 or more hours each week. When you enroll yourself and/ or your dependents in this benefit, you pay the full cost through 24 payroll deductions.

Employee Benefit: units of $10,000 up to 5x your annual salary to a maximum of $500,000.

Guaranteed issue: 5x your annual salary or $150,000, whichever is less.

Spouse Benefit: units of $5,000 up to a maximum of $100,000.

Guaranteed issue: 100% of life amount or $25,000, whichever is less.

Child Benefit: $10,000 of coverage under the age of 26.

Guaranteed issue: 100% of life amount or $10,000, whichever is less.

Evidence of Insurability

An evidence of insurability may be required for Supplemental Life insurance. Please consult the BHI Evidence of Insurability Overview Document. Monthly Cost

Supplemental Insurance Sample Calculation

Example: John Smith wants to elect 1 x his annual salary. His annual salary is $100,000, and he is 35 years old.

Here’s how to determine how much this Voluntary Life insurance would cost John per pay period:

($.080) x $100,000 = $8.00 per month

$1,000

x

Disability Coverage

Voluntary Short Term Disability Insurance

Mutual of Omaha | mutualofomaha.com | 800-775-8805

Voluntary Short Term Disability insurance is available to all employees who are scheduled to work 20 or more hours each week. If you are unable to work due to a sickness or injury, Short Term Disability insurance can help you maintain your standard of living. It can help you pay bills like your mortgage, tuition, and car payments and help cover expenses for food, clothing, and utilities. By replacing a portion of your income, Short Term Disability insurance can help provide financial security until you get back on your feet and return to work.

Employees have the opportunity to elect Voluntary Short Term Disability coverage of either 40% or 60% of their before tax weekly earnings up to $1,500 per week for a maximum of 24 weeks. The opportunity to elect either 40% or 60% increases the overall value of the benefit offered and allows employees to receive the necessary short term financial protection when needed.

Please note: That BHI has a 3/6 pre existing condition clause. This means that any medical condition for which you received treatment, consultation, care, or services (including diagnostic measures) or took prescribed drugs or medicines within the 3 months before your coverage start date will not be covered if it causes a disability within the first 6 months of your coverage. An evidence of insurability is required if you choose to elect this coverage after you are first eligible. It is also needed if you are wanting to increase your benefit amount during a subsequent enrollment period.

Short Term Disability

Voluntary Short Term Disability Sample Calculation

Example:

John Smith wants to elect STD for a 24 week duration. He is 35 years old and earns $30,000 per year. First, John must determine how much he earns per week:

$30,000/52 (weeks per year) = $577 x 60% = $346.

Here’s How to Determine How Much STD Would Cost

John Per Month:

($.75 x $346)/10 = $25.95 per month

John Per Pay:

($25.95 x 12)/24 = $12.98 per pay period

Voluntary Long Term Disability Insurance

Mutual of Omaha | mutualofomaha.com | 800-775-8805

Long Term Disability insurance is available to all employees who are scheduled to work 20 or more hours per week. This benefit provides a monthly income in the event you become totally disabled due to a covered injury or sickness. If you elect Voluntary Long Term Disability coverage, you will have the opportunity to elect a benefit that is 40% or 60% of your salary up to a maximum replacement of $6,000 per month. You must be disabled for 180 days to qualify for benefits. Employees are responsible for the full cost of this benefit. An evidence of insurability is required if you choose to elect this coverage after you are first eligible. It is also needed if you are wanting to increase your benefit amount during a subsequent enrollment period.

Voluntary Long Term Disability Benefits Begin Must be disabled for 180 days Benefit Duration 5 years Percentage of Income Replaced 40% or 60% up to $6,000

Voluntary Long Term Disability Sample Calculation

Example:

John Smith wants to elect LTD. He is 35 years old and earns $30,000 per year. First, John must determine how much he earns per month: $30,000/12 (months per year) = $2,500.

Here’s How to Determine How Much LTD Will Cost

John’s Monthly Benefit Amount: 60% x $2,500 = $1,500

John Per Month:

($.35 x $1,500)/$100 = $5.25 per month

John Per Pay:

($5.25 x 12)/24 = $2.63 per pay period

Accident Insurance

MetLife | Customer service: 800-438-6388

What Is It?

With Accident insurance, you will receive a cash benefit for each covered injury and related services for accidents that occur outside of work. These include:

■ X rays and diagnostic exams

■ Initial and follow up physician visits

■ Emergency room visits

■ Ambulance

■ Fractures and dislocations

■ Concussions

■ Recovery services

■ Hospitalization

Additionally, a $150 wellness benefit is payable for you, your spouse, and children each year for completing a qualified preventative exam.

Why May One Need It?

Out of pocket expenses add up quickly, especially since major medical insurance may only pick up part of the tab. It helps ease the unplanned financial burden of an accident and is especially useful for parents of young children and people who are active. Contact your HR Manager for more information regarding accident rates.

Critical Illness

MetLife | Customer service: 800-438-6388

What Is It?

With Critical Illness insurance, you will receive lump sum payments when a covered illness is diagnosed. If a previously covered illness returns, or you are diagnosed with an additional covered illness, benefits remain payable up to the benefit maximum for as long as you are insured (subject to plan terms and conditions). A $75 wellness benefit is payable for you, your spouse, and children each year for completing a qualified preventative exam. Pre existing conditions are waived meaning benefits are payable when a covered illness is diagnosed on or after the effective date. Contact your HR manager for more information regarding Critical Illness Rates.

You may choose a benefit amount of up to $50,000 in $10,000 increments. Your spouse and children can be covered at 50% of your benefit amount. Rates vary based on benefit amount and age. You can use the payment in any way you choose, including:

■ Deductibles and coinsurance

■ Travel

■ Treatment and rehabilitation

■ Groceries and childcare

Why May One Need It?

A major illness — such as cancer, heart attack, Alzheimer’s, stroke, and more — can leave you and your family emotionally, physically, and financially overwhelmed. Critical Illness insurance can help:

■ Relieve the financial impact so you can focus on recovery.

■ Enhance your traditional medical plan.

■ Ensure that you will be better prepared to cover out of pocket expenses in the event of a serious illness.

Hospital Indemnity

MetLife | Customer service: 800-438-6388

What Is It?

Hospital Indemnity Insurance provides a cash benefit in the event of a hospital stay of one day or longer for covered illnesses, injuries, procedures, and pregnancy. You and your covered dependents are paid a set benefit amount, depending on your plan and the length of your stay. You can use the payment in any way you choose — from medical expenses like deductibles, to everyday costs, like housekeeping and childcare. This plan has no pre‑existing conditions and will pay out when you have a covered hospital stay on or after your effective date. You have the option to choose between two Hospital Indemnity plans.

Benefits pay for hospital care, including:

■ First day stay (hospital admission) $500 for low plan; $1,000 for high plan

■ Additional days in the hospital $100 per day for low plan and $200 per day for high plan up to 15 days

■ Days spent in the Intensive Care Unit (ICU) $200 per day for low plan and $400 per day for high plan up to 15 days

Why May One Need It?

Even if you have one of the best medical plans out there, it’s unlikely that your plan will cover all the costs incurred by a hospital stay. Aside from hospital bills, there may be additional costs attached to time away from home, like meals, travel and lodging expenses for loved ones. That’s where Hospital Indemnity insurance can help. It can give you the peace of mind to focus on what’s most important — getting better. Contact your HR Manager for more information regarding Hospital Indemnity Rates.

Employee Assistance Program (EAP)

Allied Care Solutions | Customer service: 800-440-1440

At some point in our lives, each of us faces a problem or situation that is difficult to resolve. When these instances arise, Allied Care Solutions will be there to help. The Allied Care Solutions program is a company sponsored EAP that helps you deal with life’s challenges and the demands that come with balancing home and work. The EAP is a voluntary, confidential resource provided to you by BHI at no cost. The EAP is available to all BHI employees. For short-term counseling needs, members can receive 1-5 sessions, free from filing any claim. The program provides confidential services for a wide array of personal and work related concerns such as:

■ Stress and anxiety.

■ Depression.

■ Marriage and relationship problems.

■ Grief and loss.

■ Substance abuse.

■ Legal services.

■ Anger management.

For scheduling or for information on any of the above, please call Allied Care Solutions which offers assistance 24 hours a day, 365 days a year at 800 440 1440, or visit Allied Care Solutions on the web at alliedbenefit.com/caresolutions (username: bhiseniorliving)

■ Work related pressures.

■ Education guidance.

■ Child care referrals.

■ Financial planning.

■ Elder and adult care referrals.

■ Family issues.

■ Identity theft recovery.

Please contact Allied Care Solutions prior to accessing mental health or substance abuse services through your benefit plan. By your doing so, we can assist you in determining the most appropriate level of care for your particular situation.

Allied Care Solutions also offers additional work‑life services. Whether you are a new parent or caregiver, or if you’re selling your home or looking for legal advice, you’re likely to need guidance and referrals to expert resources. Allied Care Solutions’ work‑life specialists are here to help.

The program includes the following work life services.

■ Legal Assist: free telephonic or (30 minute) face‑to‑face legal consultation.

■ Financial Assist: Expert financial planning and consultation.

■ Family Assist: Consultation, research, and referral services for issues throughout the life cycle — from dependent care to auto repair to pet care to home improvement.

In addition to the above you will also have access to the below web based services:

■ Thousands of helpful articles and tip sheets for personal and work‑related topics.

■ Search engines and directories for child care, elder care, education, legal, financial, and convenience services.

■ Skill builders: 20‑minute elearning modules.

■ Self assessment tools: evaluate your health and emotional well being.

■ Multimedia streaming audio and video clips.

Allied Care Solutions upholds strict confidentiality standards. Nobody will know you have accessed the program unless you specifically grant permission or express a concern that presents us with a legal obligation to release information.

Questions and Answers

Below Are the Tasks You Will Need to Complete:

 Enroll through UKG online.

 Make sure you have all of your dependent’s information before you enroll online through UKG. Social Security Number and date of birth are required for all dependents and spouses.

 Beneficiary designations for Life and Supplemental Life (if applicable) need to be completed.

Where Do I Find Plan Information?

■ Plan documents and benefit summaries will be available online through UKG.

Whom Do I Contact With Questions?

■ Contact the Human Resources or Corporate Benefits.

Contacts

Medical Questions

Allied Benefit Systems

Customer service: 866 455 8727

Employee Assistance Program

Allied Benefit Systems

Customer service: 800 440 1440

Log in at alliedbenefit.com/caresolutions (username: bhiseniorliving)

Flexible Spending Questions

Allied Benefit Systems

Customer service: 800 288 2078

PPO Network

Aetna

Customer service: 866 455 8727

Pharmacy Questions

National CooperativeRx

Customer service: 866 818 6911

Telemedicine

Teladoc

Customer service: 800 835 2362

Dental

Delta Dental

Customer Service 866 356 0301

Vision

EyeMed

Customer service: 866 804 0982

Disability Claims

Mutual of Omaha

Customer service: 800 877 5176

Life Claims

Mutual of Omaha

Customer service: 800‑775‑8805

Accident, Critical Illness, and Hospital Indemnity

MetLife

Customer service: 800 438 6388

Health Savings Account

Health Equity

Customer service: 866‑346‑5800

The descriptions of the benefits are not guarantees of current or future employment or benefits. If there is any conflict between this guide and the official plan documents, the official documents will govern.

NOW IS A GOOD TIME

Create the future you want

Pursuing your long-term financial independence begins now

Your BHI Senior Living, Inc. Employee Retirement Plan can help you achieve the retirement you want — a future focused on what you want to do instead of what you have to do. Get started today and use the tools to help you invest for the retirement income you may need.

Know where your savings stand

Knowing your estimated monthly income in retirement can help you better prepare for your future.

Your BHI Senior Living, Inc. Employee Retirement Plan provides you with an easy-to-understand monthly estimate that:

● Gives you a savings goal.

● Helps you plan for your future.

● Shows how you compare with other savers.

Use the online tool to:

● Easily model different savings scenarios.

● Take the next step to help boost your retirement income.

● Quickly adjust contributions and rebalance your portfolio.

Get the most out of your plan

Take advantage of features available in your plan designed to help you get closer to your retirement goals.

● Easy payroll deductions so you can save with every paycheck.

● Pretax contributions that reduce your current taxable income.

● Any earnings on Roth contributions may be tax-free at the time of withdrawal.*

● Ability to save up to $22,500 in 2023, plus an extra $7,500 if you’re age 50 or older.

● Additional plan details, including when you become eligible to enroll, are available in the plan's Summary Plan Description and/or plan documents on the website.

Subject to requirements: Roth contributions must be in your account for at least five years and the money withdrawn after age 59½, death or disability.

If there are any discrepancies between this Enrollment Guide and the Plan Document, the Plan Document will govern.

Begin your journey now Log on to: empowermyretirement.com

For first-time access:

● Log on and select Register.

● Choose the I do not have a PIN tab.

● Follow the prompts to create your username and password.

Save more with matching contributions

Your plan provides for a match of 100% of deferrals up to 5% of compensation. Check out the details in the plan documents on the website.

The Empower Retirement app, available in the

An investment in your future

One key to investing is choosing investments based on your age, your unique situation and your investing style.

Do-it-myself investor

Your plan offers a range of investments that allows you to choose the mix of investments to fit your strategy.

Help-me-do-it investor

You may want to simplify your approach when choosing an investment by considering a single pre-diversified target date fund based on when you expect to retire. Generally, the asset allocation of a target date fund will gradually become more conservative as the target date nears. The date in the fund’s name represents when you plan to start withdrawing money (generally assumed to be at age 65). The principal value of the fund is not guaranteed at any time, including at the time of the target date and/or withdrawal.

Do-it-for-me investor

Your plan also offers My Total RetirementTM*, which provides a personalized retirement strategy created by our experienced professionals potentially for additional fees. If you prefer to manage your own investments, you can choose online advice at no additional cost.*

There is no guarantee provided by any party that participation in any of the Advisory Services will result in a profit or that the related account will outperform a self-managed portfolio invested without assistance.

MANAGING

Manage your account

Get information fast!

Provide your email address and sign up to receive electronic communications. Simply log on and follow these easy steps:

1. Click on your name in the upper right of the screen.

2. Go to Communication preference to make your election.

Designate your beneficiary

Ensure you pass your plan benefits on to the people you intend. Log on to the website and follow these steps:

1. Choose your plan name.

2. Click on Beneficiaries

Keep life simple

Consider rolling over your accounts from previous employer plans and:

- Get one statement.

- View one website.

- Call one number.

Call Empower at 800-338-4015 to get started.

You can get more information about your plan, fees and investment choices at any time online.

You are encouraged to discuss rolling money from one account to another with your financial advisor/planner, considering any potential fees and/or limitation of investment options.

800-338-4015 / empowermyretirement.com

Empower P. O. Box 173764

Denver, CO 80217-3764

Contact us

800-338-4015 weekdays from 8 a.m. to 10 p.m. Eastern Time

TTY: 800-345-1833

empowermyretirement.com

For first-time access:

● Log on and select Register

● Choose the I do not have a PIN tab.

● Follow the prompts to create a username and password.

Securities offered by Empower Financial Services, Inc., Member FINRA/ SIPC, marketed under the Empower brand. EFSI is affiliated with Empower Funds, Inc.; Empower Trust Company, LLC; and registered investment advisers Empower Advisory Group, LLC and Empower Capital Management, LLC, marketed under the Empower Investments™ brand. This material has been prepared for informational and educational purposes only and is not intended to provide investment, legal or tax advice.

*Online advice and My Total RetirementTM are part of the Empower Advisory Services suite of services offered by Empower Advisory Group, LLC, a registered investment adviser. Rebalancing, diversification, and asset allocation do not ensure a profit and do not protect against loss in declining markets. Asset allocation and balanced investment options and models are subject to the risks of the underlying investments, which can be a mix of stocks/ stock funds and bonds/bond funds.

Investing involves risk, including possible loss of principal.

All information contained on the website, in prospectuses, and in other investment option documents is offered in English. If needed, please have this information translated for your understanding.

IMPORTANT: The projections, or other information generated by the Empower participant experience and the Empower Lifetime Income Score regarding the likelihood of various investment outcomes, are hypothetical in nature. They do not reflect actual investment results and are not guarantees of future results. The results may vary with each use and over time.

© 2023 Empower Annuity Insurance Company of America. All rights reserved.

DC-EnrollmentKit-1504 RO2241157-0822

Welcome to the BHI Senior Living team! UKG is our HR management system allowing you to access and update your information whenever you need. You can get the UKG Pro app on your phone or access UKG on a web browser.

To ensure complete accuracy and allow you to become familiar with the system, we are asking that all new employees complete this checklist.

This Guide Teaches You:

• How to access UKG Pro in an internet browser

• How to log into UKG Pro

• Steps to follow when you forgot your password.

• How to use the mobile app

• How to update your personal information

Logging into Your Internet Browser:

• Start by logging on to UKG Pro: https://ew46.ultipro.com

• How to update your direct deposit

• How to view and change your W4

• How to view your W2 and pay statements

• How to view and request PTO

• How to view and approve your timecard

• From the Sign In page, enter your UKG Pro Username (email address) and Password (initial password is date of birth in this format: MMDDYYYY). Select Sign In to log in. (The system will prompt you to change your password after your first log-in.)

Get The UKG Pro Mobile App

The mobile app gives you easy access to important Human Resources, Pay, Personal, and Company information. The mobile app is free on all Apple and Android mobile devices and tablets.

From the UKG Pro mobile app, you can Sign in using fingerprint, face ID, or Single Sign-On (SSO)

• Manage Timesheets

• Request Time Off

• Manage Schedule

• View pay details

• Use Model My Pay

The Key Difference Between the Browser and the App:

Internet Browser

• Manage direct deposit accounts

• Manage name, address, and phone number

• View salary and job history

• View benefits and retirement plans

UKG Pro Mobile App

Change your W-4 Tax Withholding Forms View your W-4 Tax Withholding Forms

Update your marital status

Cannot view or change marital status

Download and Log into the UKG Pro Mobile App

1. From the Apple App Store or the Google Play Store, download the UKG Pro (UltiPro) mobile app. To find the app in the Apple App Store or Google Play store, you can search for “UKG Pro,” select a link, or scan a QR Code: Apple App Store Google Play Store

2. Enter your Company Access Code: BHI46268

3. Enter your UKG Pro login credentials:

a. Username = your email address

b. Initial Password = your birthdate in this format – MMDDYYYY

4. Verify your account with a code to either your email or text. Put in the code from your text message or your email.

5. Create your new password

a. Current password = your birthdate in this format –MMDDYYYY

b. Choose a new password that meets all the requirements.

c. Write down your password to refer to later.

6. Set-up 3 challenge questions of your choice

a. Do not use any capitalized letters or spaces between words.

b. Write down your answers to refer to later.

7. Sign in with your username and your newly created password.

Forgot Password: Follow These Five Steps

1. From the UKG Welcome page, select Forgot Your Password?

2. Enter your username on the left-hand side and Select > Go

3. To validate your identity, you will be asked the security questions you used when you first set up the account.

Once you have answered the questions Select > Next

4. Once the security questions have been correctly answered you will be asked to created a new password.

5. Once you have successfully changed your password you will see this screen.

This is the Home screen of the app. You can always click the Home icon at the bottom left corner of the screen to get back to this page. The squares on the screen are called tiles, and are shortcuts to common functions. You can get to everything you need through the Menu icon in the bottom right corner instead of using the tiles.

Go to Settings either by clicking on the Settings tile or by clicking Menu and scrolling to the bottom to click on Settings

From here, you can manage your notifications, Face and Fingerprint ID usage, shortcuts, and language.

Go to Shortcuts to get to this screen. You can toggle the tiles that appear on your home screen on and off. The tiles toggled on in blue will be the main ones that you want.

If you click on the Menu icon, this is what you will see. You can get to all your information by clicking into each section.

This is an example of one of the tiles that will be important to you, the Time & Attendance tile From here, you can punch in, request time off, see your schedule, and approve your timecard.

Update Your Personal Information

Updating your personal information is very important. You will be able to do all of this from the app. Whenever you make a change like your name, phone number, or address, you will see ‘pending change.’ Your HR Generalist will be notified and will approve any changes made.

NOTE: For name changes, you must submit your updated social security card to your HR Generalist When updates are made in UKG, you will receive an email indicating that the request has been successfully processed. Some changes require additional approval and will not be effective immediately.

In the app:

1. Click on your initials at the top of the screen or go to Menu > Profile

2. Select Edit to edit any personal information.

3. Select Add Contact to add an emergency contact

In a browser:

1. From the UKG Pro Home Page, select Main Menu > Myself Under Personal, click on Employee Summary

2. Click on the CHANGE NAME, ADDRESS, or TELEPHONE under the “Things I Can Do” section on the right side of the screen.

3. Click SAVE at the top of the screen after changes are made

4. Select Submit

Update Your Direct Deposit

It is the employee’s responsibility to view their direct deposit information for accuracy and update when needed. The HR Generalist cannot update any employee’s direct deposit information. However, the HR Generalist can assist employees in this process in navigating UKG.

In the app:

1. Select the Pay tile

2. Under your direct deposit information, select VIEW ALL.

3. To view and edit your current information, click on the account information. Select EDIT

4. To add a direct deposit, select the blue plus icon.

In a browser:

1. From the UKG Pro Home Page, select Main Menu > Myself. Under Pay, click on Direct Deposit.

2. Click on the hyper link for your Account Number to see the whole number

3. Verify that the correct Routing Number and Account Number are listed.

View and Update Your W4 Tax Forms

NOTE: You can only update your tax forms in a browser. In the app:

1. Select the Pay tile.

2. Under your tax information, select Withholding Forms

3. To view each section, click on the information you want to view. For example, if you want to view your federal W-4, ensure you are in the State tab and select Indiana WH-4.

4. To view and save the official form, select PDF in the top right corner. Select the Share icon in the top right corner. Save to your phone however you prefer.

In a browser:

1. Under Pay, click on Income Tax. Verify that all information is correct

2. To update information, click the Add/Change Withholding Form (W-4) link under the “Things I Can Do” section on the left side of the screen

3. Click SAVE at the top of the screen after changes are made

4. Check the box, Click Sign & Save

5. Review changes for Accuracy and select Submit

View Your W2 and Pay Statements

View and Request PTO

W2:

Your W2 will automatically mail to your home address annually. You can choose to only receive it within UKG, but the system defaults to mailing a copy to your home address.

1.Select the Pay tile

2.Under your tax information, select W-2.

3.To view in more detail, click on the W-2 for the relevant year

4.To view and save the official form, select the Share icon in the top right corner. Save to your phone however you prefer.

Pay Statements:

You can view all your pay statements within UKG under Pay You can also see your next payday. To view more detailed information, select the PDF icon.

1.Select the Pay tile.

2.Under your pay statements, select VIEW ALL

3.To view in more detail, click on the relevant pay statement.

4.To view and save, select PDF in the top right corner. Select the Share icon in the top right corner. Save to your phone however you prefer.

In the app:

1. Select the Time & Attendance tile. Select My Time Off.

2. You can also view and request time off in the Calendar tile. Select New Request > Time-off

In a browser:

1. From the UKG Pro Home Page, select Main Menu > Myself. Select Workforce Management.

2. UKG Dimensions opens in your browser on a new tab.

View My Accruals

Accruals are amounts of time that a person has earned, commonly referred to as paid time off. You can view your accrual balances on the My Time Off tile. You can also view your accruals at the bottom of each pay statement. Please refer to your handbook for the most updated PTO policy.

Request Time Off

1. From the My Time Off tile, select Dates

2. Select Dates from the calendar. Select Apply.

i. To select more than one day, select the days.

ii. To remove days from the selection, deselect the selected days.

3. If you select Advanced Options, you can choose the Duration and the Time Off Type

4. If you want to add comments to the request, select Review at the bottom of the page.

5. When you are ready, select Submit at the bottom of the page

Cancel Requests

1. Select the Calendar tile. Select the Show List icon in the top right corner.

2. Go to the Requests tab and select the Three Blue Dots to the right of the request you would like to cancel

3. Select Cancel Request

View and Approve Your Timecard

Approving your timecard weekly allows for payroll to be timely with accurate on everyone’s check.

We encourage all employees to approve their timecards on a weekly basis. When you approve your timecard, this alerts your manager faster and gives us another check for accuracy. This is important so that managers can update and approve timecards earlier, which allows your HR Generalist to receive timecards sooner on payroll week

If you forget to approve your timecard, your supervisor will still be able to approve your timecard and make corrections where needed.

In the app:

1. Select Time & Attendance tile > Select My Timecard tile > Select the arrow to get into your timecard

2. Select the appropriate timeframe with the Calendar icon in the top right corner. Choose Week to Date or Last Week to approve on a weekly basis.

3. Make sure the timecard is accurate. Select Approve.

4. To Add a Comment to an incorrect punch, follow the steps below. This will notify your supervisor to fix it.

i. Select the incorrect punch day.

ii. Select the three dots to the right

iii. Select the error/comment type. Add any additional notes relevant to your supervisor. Select Apply

In a browser:

1.From the UKG Pro Home Page, select Main Menu > Myself Select Workforce Management This will open into a new tab.

2.On the My Timecard tile, select the arrow to get into your timecard

3.Select the appropriate timeframe with the Calendar icon in the top right corner. Choose Week to Date or Last Week to approve on a weekly basis.

4.Make sure the timecard is accurate. Select Approve.

5.To Add a Comment to an incorrect punch, follow the steps below. This will notify your supervisor to fix it.

iv. Select the incorrect punch day.

v. Select the three dots to the right.

vi. Select the error/comment type. Add any additional notes relevant to your supervisor. Select Apply

The approval bar changes color, depending on who has approved it:

-All days approved by employee

-All days approved by manager

-All days signed off

BHICodeOfConductandProfessionalEthics

EmployeesofBHIareexpectedtoconductthemselveswiththehighestethicalstandards,incompliance withboththespiritandletterofthelawandwiththeorganization’smissionasafocalpoint.

Ourprinciplesandcorevaluesdeterminethecourseoftheorganization’soperationsandprofessional reputation,includingthedeliveryofqualityservicestoourcustomers,employees,andotherstakeholders withinourcommunities Westrivetoprovideaprofessionalenvironmentandensuredecisionsaremade inawaythathonorsourpast,definesourpresentandleadstocontinuedsuccessforourfuture

EmployeesshouldrefertotheCodeofBusinessConductandEthicsforadditionalprinciplesandpolicies theyareexpectedtofollow.EthicsviolationsandconcernsshouldbesubmittedtoHumanResourcesfor review.

InclusiveEnvironment:

BHIiscommittedtotakingthe followingactionsinsupportofan inclusiveworkplace:

● Helptosupportinclusionof allemployeesandmembers ofourcommunities

● Makesureallemployeescan shareconcernsasitpertains toinclusion

● Uselanguageeveryone understands,avoidingslang orjargonthatmaynot translateacrosscultures

● Addressbiaseddecisionsor actions,whetherintentional ornot

Confidentiality: ConflictOfInterest:

Employeesareobligatedto:

● Safeguardconfidential, sensitive,and proprietaryinformation

● Preventsthe unauthorizeddisclosure concerningresidents, communities,andour policies

● Givingandexchanging ofinformationmust abidebyHIPAA regulations

Employeesshouldavoidanysituation thatinvolvesaconflictbetweentheir personalinterestsandthebusiness interestsoftheorganization

● Alwaysprioritizethecompany's interestswhendealingwith customers,suppliers,contractors, orcompetitors

● Respectemployees'rightsto privateactivitiesoutsideofwork thatdon'tclashwiththe company'sinterests

● Conflictariseswhenpersonalor businessactivitiesmightaffect anemployee'sjudgmentatwork

● Employeesmustreportany conflictsofinteresttotheir managers,community,executive director,orcorporatecompliance officer

Drug-Free,Smoke-FreeandAlcohol-Free WorkplacePolicy

BHIhasalwaysmaintainedastrongcommitmenttoprovidingasafeenvironmentforitsresidentsand employees Aspartofthatcommitment,theCompanymaintainsadrug-free,smoke-freeandalcohol-free workenvironmentbyestablishingprogramsthatpromoteahighstandardofemployeehealth

SubstanceAbuseandTesting

ItisagainstCompanypolicytoconsume,possess,distributeortransportanycontrolledsubstance,illegal drug,drugparaphernaliaoralcoholicbeveragesontheCompany’spremises,reporttoworkunderthe influenceofanydrug(includingmarijuanaandalcohol),oroperateaCompanyvehiclewhileimpairedor undertheinfluenceofanyillegalsubstanceoralcohol.Prescriptionandover-the-counterdrugsarenot prohibitedwhentakeninstandarddosagesand/oraccordingtoaphysician'sprescription;however, employeesareresponsibleforconsultingtheirphysicianand/orpharmacisttomakesureaprescribedor over-the-counterdrugwillnotinterferewithsafejobperformance.Thispolicyisimplementedin compliancewiththeDrugFreeWorkActof1988

Allcommunityemployeesaresubjecttoadrugscreenatthetimeofinitialhiring.Anyemployeewhois reasonablysuspectedofviolatingthispolicywillbesubjecttotestingandcouldfacecorrectiveactionup toandincludingtermination,evenfortheemployee’sfirstoffense.Reasonablesuspicionmeansabelief basedonobserved,specific,andobjectivefactsthatindicateapersonisundertheinfluenceofdrugs and/oralcohol Examplesinclude:

● Directobservationofabnormalconduct

● Incoherentmentalstate

● Erraticbehaviorthatisotherwiseunexplained

● Workplaceincidentresultinginactualorpotentialharm,orinjurytoothers

● Third-partyinformationthatisreliableandcredible

Rehabilitationistheemployee’sresponsibility.Ifyoubelievethatyouneedprofessionalassistancein overcomingaproblemwithdrugsand/oralcohol,referralstolocalcounselingandrehabilitationprograms canbeobtainedfromtheHRdepartment EmployeesarealsoencouragedtoparticipateintheEmployee AssistanceProgram(EAP).

Compliancewiththispolicyisaconditionofemployment Employeeswhotestpositive,refusetosubmit tosubstanceabusescreening,orviolatethispolicyinanywayaresubjecttodiscipline,uptoand includingtermination Notwithstandinganyprovisionherein,thispolicywillbeenforcedatalltimesin accordancewithapplicablestateandlocallaw.

SmokingisnotallowedinCompanyBuildingsorworkareasatanytime “Smoking”includestheuseof any tobaccoproducts(includingchewingtobacco),electronicsmokingdevices,ande-cigarettes.

Smokingisonlypermittedduringbreaktimesindesignatedoutdoorareas.Employeesusingtheseareas areexpectedtodisposeofanysmokingdebrissafelyandproperly

SmokeFreeworkplacepolicyappliesto:

● Allareasofthebuildingsoccupiedbycompanyemployeesorresidents

● Allcompanysponsoredoff-siteconferencesandmeetings

● Allvehiclesownedorleasedbythecompany

● Allvisitors(customersandvendors)tothecompanypremises

● AllContractorsandconsultantsand/ortheiremployeesworkingoncompanyproperty

● Alltemporaryemployees

● Allstudentinterns

Employeeswhoviolatethissmokingpolicywillbesubjecttodisciplinaryactionuptoandincluding immediatedischarge.

Resolvingcomplaintsaboutsmoking:

● Anycomplaintsabouttheapplicationofthepolicytotheworkplaceshouldbebroughttothe attentionoftheHumanResourcePartnerorAdministratorforresolution

● Thecomplaintshouldbesubmittedinwritingandidentifyspecificobjections.Thecommunity’s HumanResourcedepartmentandAdministrationwillinvestigatethecomplaintandresolveitin accordancewiththepolicy

● Noemployeeshallsufferanyformofretaliationforraisingacomplaintoraskingaquestion aboutthispolicy

PhishingAwarenessandTrainingPolicy

Overview

ThePhishingAwarenessandTrainingPolicyexiststospecifytheBHISeniorLiving(BHI)internal informationsecurityawarenessandtrainingprogramandtoinformallemployeesoftheirinformation securityobligationsandtrainingrequirements Lackingadequatesecurityawarenesscancauseemployees tonotrecognizeorreactappropriatelytosecuritythreatsandincidentswhichcanputtheindividualand organizationatrisk.Theoverallobjectiveofthispolicyistoinformemployeesofpotentialsecurity threatsandtheirresponsibilityinsafeguardingtheorganizationagainstcybercrime

Scope

ThispolicyappliestoallBHIemployeeswhoaccessBHIcomputersystemsornetworksfromany personalorBHIissueddevice.Allemployeesareexpectedtoprotectallformsofinformationincluding computerdata,writtenmaterials,anddocumentsthatincludePersonalHealthInformation(PHI)ormight violateHealthInsurancePortabilityandAccountabilityAct(HIPAA)rights

StatementofExpectation

Ifanemployeereceivesanemailfromanunknownsender,employeesshouldnotengagewiththe messageincludingprovidingpersonalinformation,openinganattachment,clickingonlinksorentering informationintoapop-upbox.Employeesshouldalsobemindfulofaccessingandinteractingwith unknownwebsites Ifyouarenotsurewhetheranemail,message,linketc islegitimate,youshould deletetheemailorimmediatelyexitthewebsite. Anysuccessfulattemptsatphishingshouldbe immediatelyreportedtoIT

Phishing

Phishingisthefraudulentpracticeofsendingemails,orotherformsofmalicioussoftwarethatcanobtain confidentialinformationincludingpasswords,financialinformation,etc fromanunsuspectingperson

● Neversendpasswords,bankaccountnumbers,orotherprivateinformationinanemail.

● Avoidclickinglinksinemails,especiallyanythatarerequestingprivateinformation

● Bewaryofanyunexpectedemailattachmentsorlinks,evenfrompeopleyouknow.

● Lookfor‘https://’andalockiconintheaddressbarbeforeenteringanyprivateinformation

● Haveanupdatedanti-virusprogramthatcanscanemails.

Anti-PhishingBestPractices

● HoverovertheURLbeforeyouclick

● Avoidrespondingthoughtlesslytounknownsenders.

● Donotinstallunauthorizedsoftwareanddonotsharecredentialswithanyone.

● Uselong/complexpasswords

● Usesocialmediaresponsibly.

● Deploymulti-factorauthentication

BHISeniorLivingPhishingAwarenessTraining

AsoutlinedintheBHISeniorLivingHandbook,allemployeesarerequiredtoparticipateinroutine trainingtowardagainstphishing.FailuretocomplywiththetrainingrequirementsorputtingBHIatrisk throughcontinuedresponsetophishingattemptswillleadtocorrectiveactionuptoandincluding termination EmployeesmustregularlyreviewandfamiliarizethemselveswiththedetailedBHISenior LivingPhishingAwarenessTrainingforacompleteunderstandingofhowtonoticeandpreventphishing. BHIrequiresthateachemployeeuponhirecompletetheSecurityAwarenessTraining.Allemployeesare requiredtocompletetheSecurityAwarenessTrainingannually

Compliance&Non-Compliance

CompliancewiththispolicyandthePhishingAwarenessTrainingismandatoryforALLstaff TheBHI SeniorLivingITdepartmentwillmonitorcompliantandnon-compliantactionswiththispolicyand reporttotheexecutiveteamtheresultsoftrainingandthesocialengineeringexercises.

Certainactionsornon-actionsbyBHIpersonnelmayresultinanon-complianceevent(Failure)

AFailureincludesbutisnotlimitedto:

● Failuretocompleterequiredtrainingwithinthetimeallotted

● Failureofasocialengineeringexercise. Failureofasocialengineeringexercisemayinvolvebutisnotlimitedto:

● ClickingonaURLwithinaphishingtest

● Replyingwithanyinformationtoaphishingtest

● Openinganattachmentthatispartofaphishingtest

● Allowingexploitcodetorunaspartofaphishingtest

● Enteringanydatawithinalandingpageaspartofaphishingtest

● Transmittinganyinformationaspartofavishing(phonebased,voicephishing)test

● Replyingwithanyinformationtoasmishing(textmessagephishing)test

● PlugginginaUSBstickorremovabledriveaspartofasocialengineeringexercise

● FailingtofollowBHISeniorLivingpoliciesduringasocialengineeringexercise.

EachFailurewillresultinRemedialtrainingandprogressivecorrectiveactionuptoandincluding termination.Failureofanactualattemptatphishingmayresultinimmediateterminationdependenton impacttotheorganization

Failureswillrolloffafter12monthsfromviolationdate.

ScheduleofFailurePenalties

FailureCount ResultingLevelofRemediationAction

FirstFailure Mandatorycompletionofremedialtrainingmodule

SecondFailure Mandatorycompletionofsubsequenttrainingmodule; DocumentedCoaching

ThirdFailure Mandatorycompletionofsubsequenttrainingmodules. MeetingwiththeManager,HumanResources,and ExecutiveLeader;WrittenWarning

FourthFailure Mandatorycompletionofsubsequenttrainingmodule; FinalWrittenWarning

FifthFailure TerminationofEmployment

ResponsibilitiesandAccountabilities

Belowisanoverviewoftheresponsibilitiesandaccountabilitiesformanagingandcomplyingwiththe PhishingAwarenessandTrainingPolicy

AllStaffarepersonallyaccountableforcompletingthesecurityawarenesstrainingactivities,and complyingwithapplicablepolicies,laws,andregulationsalways

AllSupervisorsareresponsibleforensuringthattheirstaffandotherworkerswithintheirresponsibility participateininformationsecurityawareness,training,andeducationalactivitieswhereappropriateand required

TheInformationTechnologyDepartmentisresponsibleforprovidingupdatestothetrainingprogramas necessaryandprovidingadditionaleducationalopportunitiesforstaff

ZeroToleranceWorkforceViolencePolicy

BHISeniorLivingiscommittedtoprovidingasafe,violence-freeworkplaceforouremployees. Duetothiscommitment,wediscourageemployeesfromengaginginanyphysicalconfrontation withaviolentorpotentiallyviolentindividualorfrombehavinginathreateningorviolent manners Threats,threateninglanguage,oranyotheractsofaggression,intimidationorviolence madetowardorbyanyemployeewillnotbetolerated Athreatmayincludeanyverbalor physicalharassmentorabuse;attemptstointimidateothers;menacinggestures;stalking;orany otherhostile,aggressive,and/ordestructiveactionstakenforthepurposesofintimidation This policycoversanyviolentorpotentiallyviolentbehaviorthatoccursintheworkplaceorat Company-sponsoredfunctions.

AllBHIemployeesbeartheresponsibilityofkeepingourworkenvironmentfreefromviolenceor potentialviolence Anyemployeewhowitnessesoristherecipientofviolentbehaviorshould promptlyinformtheirsupervisor,manager,orHRdepartment.Allthreatswillbepromptly investigated Noemployeewillbesubjecttoretaliation,intimidation,ordisciplineasaresultof reportingathreatingoodfaithunderthisguideline

BHImaintainsazerotoleranceforworkplaceviolence.Anyindividualengaginginviolenceagainst theCompany,itsemployees,oritspropertywillbeprosecutedtothefullextentofthelaw.All actswillbeinvestigated,andtheappropriateactionwillbetaken Anysuchactorthreatening behaviormayresultindisciplinaryactionuptoandincludingtermination.

BHIprohibitstheuseoffirearmsduringandinthecourseofanemployee'sdutiesandonbehalf ofBHIwhileonthepremisesofBHI,includingourparkinglotsorCompanyvehicles Anemployee isonlypermittedtopossessafirearmorammunitionthatislockedinthetrunk,keptintheglove compartment,orstoredoutofplainsightintheemployee'slockedvehicle.Additionally,while onduty,employeesmaynotcarryaweaponofanytypeunlessauthorizedbyCompanyaspart oftheirdutiesofemployment.

TheCompanyreservestherighttoinspectallbelongingsofemployeesonitspremises,including packages,briefcases,pursesandhandbags,gymbags,andpersonalvehiclesonCompany property Inaddition,BHImayinspectthecontentsoflockers,storageareas,filecabinets,desks, andworkstationsatanytimeandmayremoveallCompanypropertyandotheritemsthatarein violationofCompanyrulesandpolicies.Employeesshouldhavenoexpectationofprivacywhile ontheCompanypremises

Dress and Grooming Policy: Corporate Office

This policy has been developed to ensure that all employees understand the importance of appropriate grooming and hygiene in the workplace or when otherwise representing BHI Senior Living, Inc. The standards outlined below set forth the minimum requirement to which all employees are required to adhere. BHI recognizes that the presentation of its employees in the workplace contributes to a professional and comfortable working environment and our public image. Therefore, BHI expects employees to be well-groomed and professional in their appearance when coming to work or engaging in work-related tasks with residents, clients, and teams.

Each employee is responsible to “dress for their day” in accordance with BHI’s dress code guidelines and should always maintain a positive, professional image. This includes choosing attire that fits their work environment, location and schedule and considers the meeting settings of their day.

Guidelines

These guidelines are intended to provide general guidance to help define appropriate attire for the work environment. Please always keep in mind that you are dressing for your career, and when at work, you represent BHI.

When hosting or attending meetings with residents, vendors, employees from other companies or board members, employees should wear appropriate clothing for the meeting or event, which may include “business professional” attire. Examples of business professional attire include suits and dresses. If uncertain, the employee should check with their supervisor or the meeting host.

• Clothing must be neat, clean and in good taste

• Employees should be well groomed and avoid clothing, fragrance or grooming choices that distract or interfere in any way with the ability for employees or others to accomplish work

• Casual attire to include jeans, plain t-shirts, and BHI branded items are permitted

Inappropriate attire includes but is not limited to:

• Any clothing with offensive or derogatory graffiti, pictures, signs, or statements

• Shorts, sweat/running/yoga pants, or exercise leggings

• Tank tops, halter tops, workout tops, or mid-riff revealing tops

• Sweatshirts or hoodies with logos (outside of BHI branded items)

• Baseball caps or hats

• Tight-fitting clothing that is revealing and inappropriate for the workplace

• Jeans, pants, or shirts that have holes, tears, or rips of any type

• Beach sandals, casual, or athletic-style flip-flops or slides

• Clothing that might create a safety hazard in certain work areas (i.e. hanging or loose clothes, jewelry, etc.)

Guidelines for daily hygiene and good grooming habits:

• Hair – hair should be clean and neatly trimmed or arranged. Sideburns, mustaches, and beards should be neatly trimmed.

• Make-Up – Make-Up should be professional and conservative.

• Fragrance – recognizing that residents, clients, and other employees in the workplace may have sensitivities or allergies to fragrant products, including but not limited to perfumes, colognes, fragrant body lotions or hair products, fragrant products should be used in moderation. Employees may be asked to discontinue the use of certain fragrant products if it is determined to be problematic in the workplace.

• Jewelry – employees may wear jewelry in moderation. Other visible body jewelry/body piercings may be restricted when an employee is in the workplace (for example, tongue or nose piercings).

• Tattoos – tattoos or other body art (such as surgically implanted ball bearings or spikes) shall be covered or removed when in the workplace, when possible. Exceptions may be made, based on the employee’s position, for non-offensive tattoos that cannot be easily covered by standard clothing (for example, wrist, neck, etc.)

• Name Badges – all employees are required to wear a name badge while at a BHI community. Badges are issued free of charge to new employees. Badges that require a replacement due to normal wear and tear are replaced at no charge.

Use good judgement when deciding what to wear and consider that if you are questioning whether a certain piece of clothing should be worn, it is probably best not to wear it.

If your supervisor finds that your personal appearance is inappropriate, you may be asked to leave work and return properly dressed and groomed. If you are asked to leave, you will not be paid for the time you are away from work. Violations of this policy may result in discipline, up to and including termination.

CENTRAL OFFICE

Page 1 Purpose

Objectives

Table of Contents

Distribution of the Manual

Emergency Defined

Page 2 Disaster Prevention Measures

Emergency Preparedness Team

Page 3 Snow/Ice

Page 4 Fire

Page 5 Tornado

Page 6 Medical Emergency

Disorderly Visitor/Active Shooter

Suspicious Item/Bomb Threat

Extortion Threat

Extended Power Outage

Page 7

Security Alarm Alert/Break-in/Burglary

Alternate Facilities Communications

Page 8 Disaster Recovery

Suppliers

List of Attachments

• Exhibit A – Building Evacuation Plan – Top Floor (KBA Offices)

• Exhibit B – Building Evacuation Plan – Main Floor (BHI Offices)

• Exhibit C – Building Evacuation Plan – Basement

• Exhibit D – Building Evacuation Plan – Parking Lot

• Exhibit E – Important Contact Information & Suppliers

• Exhibit F – Corporate Staff Contact Information

• Exhibit G – Water and Electrical Shut Offs for Building

• Exhibit H – Mail Safety Protocol

Purpose

This plan is designed to provide for the protection of lives, property and essential data from any threat presented by a natural or man-made emergency. The use of this plan will allow BHI Senior Living (BHI) to prepare for and recover from disasters or emergencies in an efficient and effective manner to enable the continuing operation of BHI. The first priority of BHI is the safety and security of all its employees and visitors.

Objectives

This plan has the following objectives:

• To reduce confusion by giving a clearly defined course of action in the event of a disaster, thus providing for an orderly and timely response and recovery.

• To provide for appropriate employee and stakeholder communications.

• To establish a plan to resume normal operations after a disaster.

Distribution of the Manual

Each member of the Emergency Preparedness Team will receive two copies of the plan, one of which will be retained at home. All other team members will receive one copy of the plan for informational and instructional purposes.

Emergency Defined

For the purposes of BHI, an emergency shall be defined as an event, or impending event, presenting a severe threat to the safety of the BHI team and visitors, BHI property or the ability to carry out critical operations.

Emergencies can be classified as man-made or natural, and examples of each are listed below:

• Natural emergencies: tornado, snow/ice storm, fire, etc.

• Man-made emergencies: civil disorder, terrorist activity, bomb threat, active shooter, etc.

Disaster Prevention Measures

The following measures will minimize the likelihood of a disaster and/or minimize the time needed to recover from a disaster:

• The BHI building is a nonsmoking facility and premises. No lighted smoking materials are allowed in the building or on the property.

• All team members are familiarized with the building evacuation plan (Exhibits A-D).

• All critical and confidential files are secured and backed up and archived at a separate location.

• All team members are aware of the locations of fire extinguishers in the building (Exhibits A-C) and are trained in the use of same. Fire extinguishers are inspected annually by a licensed service company.

• Virus protection programs are installed on all file servers and other critical network computers.

Emergency Preparedness Team (EPT)

The BHI Emergency Preparedness Team (EPT) is responsible for compliance with and execution of the BHI Corporate Office Emergency Preparedness Plan. EPT members are:

• Mark Prifogle, RVP, Operations Indiana

• Tony Conaway, VP, Information Technology

• Joe Wheeler, Compliance Officer and Internal Auditor

• Celeste Larson, Corporate Talent Acquisition Director

• Bil Potter, General Counsel, KBA

• Darrel Hutchinson, Facility Maintenance, KBA

• Rhonda Pestridge, Executive Assistant/Office Manager

In the event of an emergency, members of the EPT should be able to:

• Shut off water supply valves to the building.

• Shut off electrical systems in the building.

Exhibit G describes the locations of shut offs.

Emergency During Normal Business Hours

Snow/Ice Storm

 Before a storm:

Keep charged flashlights and stocked first aid kits at designated spots in the building.

 Storm procedure:

Any changes to the normal workday or hours of operation will be communicated to the team via group email and/or text.

Employees are encouraged to take their laptop and other necessary materials home ahead of known weather conditions that could limit ability to access the office.

If a weather or emergency situation dictates that the corporate office be closed, full- and part-time employees will be paid for the hours they were scheduled to work while the office is closed. Employees may be asked to report to work at another location and will be expected to report to any other feasible location. If remote work is possible and approved by the supervisor, employees will be expected to complete their work assignments from home and be available via phone or Microsoft Teams.

If an employee is unable to report to work due to weather conditions and the corporate office is open, the employee should work with their supervisor to determine if remote work is approved for the day. If remote work is not available, the employee will be expected to use PTO. If no PTO is available, the day will be unpaid.

BHI expects all employees to make every reasonable and safe effort to report to work as scheduled during adverse weather situations; however, at no time should an employee place themselves or their safety in jeopardy.

 After a storm:

Darrel Hutchinson (primary), Rhonda Pestridge and Joe Wheeler (secondary) are responsible for the following:

• Check for gas leaks. If the smell of gas is detected, instruct team members to leave the building immediately and call 911 after exiting. Do not turn on light switches or activate anything that could cause an electrical spark resulting in an explosion or fire.

• Check appliances for damage. If electrical wiring appears damaged, turn off the current at the main fuse box or circuit breaker.

• Check for structural damage. Watch for falling debris and any possibility of collapse.

• Check for damage to water pipes. If water pipes are damaged, do not use water from the taps; it may be contaminated.

 Before a fire:

• Make all team members aware of locations of first aid kits, fire exits and fire extinguishers (marked on Exhibits A-C).

• Conduct fire drills twice a year (winter/summer).

• Keep each fire extinguisher in working order through a scheduled maintenance program.

 Fire procedure:

If a fire is detected, call 911. The alarm system installed in the building detects fire via heat sensors and smoke detectors and should automatically call 911; however, an additional call is suggested. Immediately alert all team members via group text.

• Immediately and calmly proceed to the nearest exit; shut doors on your way to create fire breaks. Gather in front of the building in the farthest southwest corner of the parking lot. Exhibit D shows the meeting place in front of the BHI corporate building at the most southwest corner of the parking lot.

• Once in the parking lot, a member of the EPT (primarily Rhonda Pestridge or Joe Wheeler) will conduct a roll call to ensure all employees were able to evacuate safely. Report all missing persons to fire department personnel.

• It is mandatory that you stay in the designated area until a member of the EPT informs you the building is safe to re-enter.

• Use a fire extinguisher in case of a small, containable fire

- For a computer electrical fire, a Halotron extinguisher is located in the server room. Do not use any other extinguisher on computers. Halotron is a vaporizing, ozone-friendly liquid extinguishing agent requiring no clean up after the fire is out; therefore, is safe for computer equipment.

- For all other fires, use dry chemical fire extinguishers located throughout the building.

- To use an extinguisher, remember the word PASS:

P – Pull the Pin

A – Aim low at the base of the fire

S – Squeeze the handle to release the extinguishing agent

S – Sweep from side to side

- When using an extinguisher, call 911 first and keep an exit at your back to prevent being trapped.

Tornado Watch or Warning

 Before a tornado:

• Keep charged flashlights and stocked first aid kits at designated spots in the building.

• Conduct tornado drills every spring.

 Tornado procedure:

The EPT (primarily Mark Prifogle and Darrel Hutchinson) will monitor weather conditions continuously during normal business hours. There are several weather events that may make it necessary to shelter in place or adjust the workday. Employees who hear of an imminent threat to the area should immediately notify a member of the EPT so emergency procedures can be implemented.

If a tornado watch is issued – meaning conditions are such that tornadoes may develop – the EPT will notify all corporate employees via group text/email to apprise them of the situation. Employees should remain vigilant and be prepared to follow emergency procedures if implemented.

If a tornado warning is issued – meaning a tornado has been sighted or indicated on radar –the EPT will notify all corporate employees via group text/email. If you receive notification of a tornado warning in your area:

• It is mandatory for the team and visitors to immediately and calmly proceed to the basement level of the BHI building and seek shelter in the restrooms, stairwells and/or back office areas marked with Tornado Shelter signs. Close all doors and stay away from windows.

• If there is no time to get to the basement, seek shelter on the main floor in the mail room, restrooms or supply closet. Close all doors and stay away from windows.

• It is mandatory to stay in these designated areas until a member of the EPT informs you it is safe to exit shelter.

 After a tornado:

Darrel Hutchinson (primary), Rhonda Pestridge and Joe Wheeler (secondary) are responsible for the following:

• Check for gas leaks. If the smell of gas is detected, instruct team members to leave the building immediately and call 911 after exiting. Do not turn on light switches or activate anything that could cause an electrical spark resulting in an explosion or fire.

• Check appliances for damage. If electrical wiring appears damaged, turn off the current at the main fuse box or circuit breaker.

• Check for structural damage. Watch for falling debris and any possibility of collapse.

• Check for damage to water pipes. If water pipes are damaged, do not use water from the taps; it may be contaminated.

Medical Emergency

Call 911 and notify the receptionist so emergency personnel can be directed quickly to the location of the emergency. If possible, a member of the EPT should be notified. Keep the injured person calm and administer first aid. It is discouraged for team members to transport someone to the hospital as emergency personnel have the proper training and can get medical care for the patient in a more efficient manner.

Disorderly Visitor/Active Shooter

Depending on the urgency and severity of a situation of this nature, the receptionist will press the panic button located on the wall behind the reception desk to alert staff that help is needed and/or will dial 911 immediately to alert emergency responders of the situation. Pressing the panic button triggers lights to flash and alarms to sound on each level of the building, alerting staff that there is an emergency situation in the building. Employees should shelter in place until members of the EPT have assessed the situation and notify employees of appropriate action(s) to take. After the emergency, pressing the panic button again will turn off the lights and alarms.

Suspicious Item/Bomb Threat

If a suspicious item or bomb threat is received, immediately alert all team members via group text as well as building visitors. Examples include unexplainable wire or electronics, other visible bomb-like components, unusual sounds, vapors, mists, or odors. Generally, anything that is Hidden, Obviously suspicious and not Typical (HOT) should be deemed suspicious. All employees and visitors should calmly proceed to the nearest exit and assemble in the parking lot. Exhibit D shows the meeting place in the front parking lot. Call 911 to report the threat after leaving the building. A member of the EPT will ensure emergency responders as well as the CEO/CFO are briefed. It is mandatory that everyone stay in the designated area until the EPT informs you the building is safe to re-enter.

Extortion Threat

If there is an extortion threat or an attempt based on threats, whether they are to people or assets but with no hostages, document how the threat was received (whether via phone or email) and document as much detail as possible. Notify a member of the Executive Team who will contact the authorities.

Extended Power Outage

All employees will stay in their work areas until power is restored or a determination is made for everyone to work from home until power is restored.

Emergency Outside Normal Business Hours

Security Alarm Alert/Break- in/Burglary

When security at the BHI building has been breached outside normal business hours, Nelson Alarm notifies designated Key Benefits personnel. If any incident of this type will disrupt normal business hours, the EPT will be notified who will alert the rest of the team as needed.

Alternate Facilities

If an extended evacuation of the building is required, operations will be performed by team members from their home offices until building repairs are completed and/or an alternate operating location is established which is capable of housing and supporting the equipment and communications needs of team members.

Communications

Communications to Employees

In the event of a disaster or when the building is inaccessible due to weather conditions, the President and CEO or their designee will communicate the status of BHI facilities via group email and/or text.

Communications to Communities, Affiliates and Media

In the event of a disaster, BHI’s Vice President of Public Relations and Communications will communicate the status of BHI and its operations to BHI communities and affiliates via email and will handle any inquiries from the media.

Disaster Recovery

Equipment

Equipment which has been deemed critical for the continuation of BHI business functions consists of the following:

• Database server

• Network router and firewall

• Online backup and restoral system

• Photocopier machines

Suppliers

If the BHI offices are inoperative, vendors listed in Exhibit F may be contacted for replacement supplies as needed.

Attachments

Exhibit A – Building Evacuation Plan – Top Floor (KBA Offices)

Exhibit B – Building Evacuation Plan – Main Floor (BHI Offices)

Exhibit C – Building Evacuation Plan – Basement

Exhibit D – Building Evacuation Plan – Parking Lot

Exhibit E – Important Contact Information & Suppliers

Exhibit F – Corporate Staff Contact Information

Exhibit G – Water and Electrical Shut Offs for Building

Exhibit H – Mail Safety Protocol

Important Contact Information

Alarm System – Nelson Alarm Indianapolis, 317-255-2125

Darrel Hutchinson – Building Maintenance, 317-409-7041 (cell)

Electricity – AES Energy, 317-261-8222

Elevator – Elevator One, 317-716-3065

Exterior Door Issues – Nelson Alarm Indianapolis, 317-255-2125

HVAC – Edwards Mechanical, 317-354-2638

Police – 317-545-7575

Snow Removal – Rask & Associates, Inc., 317-891-2655

Insurance – Property – Lee Agency, 800-225-9252

Insurance – Liability – Caring Communities, Laura Lally, 847-507-6491

Water Utility – Citizens Energy Group, 317-924-3311

Suppliers

Type of Supplies Supplier Name Contact Information Office Supplies Office Depot odpbusiness.com/home.do

Postage Meter Pitney Bowes www.pitneybowes.com

Copiers/Printers Impact 888-752-0052

First

Alexa Evans

Amie Neiling

317-340-4264 x x

317-431-2700 x x

Andrea Kern 812-604-5250 317-210-9262 1129

Bianca Maddox

336-688-1537 317-667-0805 0805

Brian McDonald 317-371-3072 317-708-6940 1200

Brian Pangle 616-250-7709 x x

Celeste Larson 513-571-4245 x 1140

Chris Byrde 317-435-1107 317-873-6165 1123

Chris Hummel 317-210-9261 317-210-9261 9402

Chris Kukelka 317-402-2169 317-899-9515 9515

Chuck Gaskins

317-366-4275 317-708-6885 6885

Dan Carr 260-704-7998 317-218-7412 1109

Danette Shultz

765-532-6090 317-708-6937 1100

Dawn Martinie 317-752-6121 317-708-6938 6938

Dawn Raquet

317-370-9152 x x

Diana Sell 765-251-0455 317-973-4010 1131

Drew Batts

765-894-2655 x x

Erica Bair 260-450-4312 317-973-4004 4004

Erica Webb

636-614-9809 x x

Erin Rawlins 812-764-0051 x x

Felicia Sorgdrager 260-388-1948 260-969-8075 8075

Heather Kasselman 463-210-9838 x x

Jackie Lincks 317-600-8490 317-899-9507 1118

Jay Rumbach 812-630-6754 317-660-6890 1135

Jeannie Ambler 317-358-7242 317-708-6942 1137

Jennifer Zvokel

317-450-1077 317-708-6944 1120

Jenny Jaspers 513-349-4661 317-275-3230 3230

Jenny McGraw

765-610-4770 317-708-3765 3765

Jill Johnston 260-233-9401 260-233-9401 9401

Joe Wheeler 317-445-1387 317-708-6943 1108

John Dattilo 317-730-5759 317-708-6946 1121

Josh Burton 317-471-9748 317-708-6941 1106

Juanita Lavy 317-341-4304 317-873-8263 1125

Justin Elam 502-599-2002 x x

Katelyn Marcum

765-499-2807 317-708-3698 3698

Katie Laney 317-246-0692 317-899-9511 1127

Kevin Ward

Mark Prifogle

Megan Ulrich

765-601-1000 317-708-6945 2148

765-265-1763 x x

513-312-2546 x x

Nathan Welty 317-995-2798 317-899-9509 9509

Percell Smith

Ramona Ohms

248-914-8468 x x

317-701-3469 317-708-6936 1103

Rhonda Pestridge 810-333-2875 317-708-3101 3101

Roger Weideman 317-370-1446 317-708-6935 1102

Saasha Sundaresh 317-918-6456 317-210-9024 9024

Sarah Miller 317-372-3436 317-873-8221 1110

Scott Miller 765-543-3289 x x

Shawn O'Connor 317-965-0610 x x

Shenika McKenna 317-428-9909 317-608-6829 1122

Sherry Simmons 678-283-6995 317-873-6183 6183

Stacie McClain 765-277-6686 317-708-6886 6886

Tim McGowan 513-312-6755 x x

Tony Conaway 317-833-8983 317-708-6947 1117

updated 1/30/2025

Exhibit G

Water and Electrical Shut Offs for Building

Water shut off valves for the building are located in the Mechanical Room in the basement.

Electrical shut off is located in the Electrical Room in the basement.

Exhibit H – Mail Safety Protocol

Subject/Title: Mail Safety Protocol

Department: Environmental Services

Date Approved:

Date Revised:

Responsibility: (Example: Environmental Services team members providing services to BHI Senior Living, Inc. and BHI Retirement Communities, Inc. and their affiliates (collectively, “BHI”))

Policy: This internal protocol is for handling and processing mail safely to ensure the safety of BHI employees and property.

1. MAIL HANDLING/PROCESSING SAFETY PROTOCOL

- Each mail handling area in all BHI buildings will prominently display a poster of suspicious letter/package indicators and provide same to all staff who handle mail to ensure they’re familiar with it. The Postal Inspection Service’s Poster 84, Suspicious Mail or Packages (shown below) will be used to illustrate key characteristics of suspicious or potentially dangerous mail items.

2.

PROCEDURE WHEN A SUSPICIOUS LETTER OR PACKAGE IS IDENTIFIED

- When an employee receives an unexpected or suspicious piece of mail:

(1) Do NOT open the envelope or package, and contact your immediate supervisor.

(2) Remain in place and isolate the suspicious item until further instructed.

- The supervisor should attempt to contact the sender and should ask the following questions:

• Is the addressee familiar with the name and address of the sender?

• Is the addressee expecting a letter or package from the sender? If so, what’s the approximate size of the item?

• Ask the sender to fully explain the circumstances surrounding the sending of the item and describe the contents. At this point, management and security must decide whether or not to proceed to open the letter or package.

• If the sender is unknown, is the addressee expecting business correspondence from the city, state, or country of origin of the item?

• Is the addressee aware of any friends, relatives, or business acquaintances currently on vacation or on business trips in the area of the return address?

• Has the addressee purchased or ordered any merchandise from a business whose parent organization might be located in the area of the return address?

- If it’s determined the sender is unknown at that return address or the return address is fictitious, consider this an indication the letter or package may be dangerous and follow this response/action plan:

Response Action

Alert

Notify

Document

Alert employees that a suspicious letter or package has been found and to remain clear of the isolation area.

Inform management and security that a suspicious item has been detected.

Without touching the mail piece, record from each visible side of the item all available information (name and address of addressee and of sender, postmark, cancellation date, stamps, and any other markings or labels found on the item).

Inform

Inform police (and Postal Inspectors if sent through the U.S. Mail) of all information recorded from the suspect item.

OCTOBER

NOVEMBER

DECEMBER

BHI SENIOR LIVING

EMPLOYEE HANDBOOK

Revised January 2024

Welcome

Welcome to BHI Senior Living ("BHI")! We are delighted that you have chosen to join our organization and hope that you will enjoy a long and successful career with us. As you become familiar with our culture and mission, we hope you will take advantage of opportunities to enhance your career and further BHI’s goals.

You are joining an organization that has a reputation for doing what is best for the people we serve. We believe in responsible stewardship of resources — from making sure all of our communities are consistently maintained and updated, to employing the sound financial practices that have made BHI one of the most well-respected, financially stable senior living organizations in the Midwest.

Please take time to review the policies contained in this handbook. If you have questions, feel free to ask your supervisor or to contact the Human Resources ("HR") department.

1. INTRODUCTION

1.1 MISSION STATEMENT

The mission of BHI Senior Living, Inc. ("BHI Senior Living," "BHI" or "Company"), is to enhance the quality of life for older adults within a secure environment which supports their needs, values, interests, andindependence while encouraging personal and spiritual development.

1.2 CORE VALUES OF BHI SENIOR LIVING

Respect

Valuing the worth, dignity, and diversityofeveryone.

Compassion

Sensitivity to the needs and rights of all persons.

Integrity

Maintaining the highest standards of trust and honesty.

Personal Development

A commitment to lifelong learning and personal growth.

Customer Satisfaction

Providing quality service that exceeds expectations.

Advocacy

Speaking and acting on behalf of others.

Stewardship

Using human, environmental, and financial resources wisely.

Servant Leadership

In the spirit of serving others first, we respect and honor our Christian heritage.

1.3 POLICIES

This employee handbook includes summaries of the personnel policies and procedures that govern the employment relationship between the Company and its employees. However, strict adherence to this handbook is never to get in the way of decisions based on good business judgment. Whileconsistent interpretationof handbookprovisions is desirable,management and Human Resources will evaluate situations and document decisions on a case-by-case basis based on the individual circumstances. Deviations are sometimes necessary and in the best interest of the Company. Not all management practices are expected to be included in the handbook; however, management practices are to be generally consistent with this handbook. Further, the policies stated in this handbook are subject to change at any time at the sole discretion of the Company. Each employee may occasionally receive information concerning amendments to the policies, and that information should be kept with the employee’s handbook. This handbook and the policies within it supersede any prior handbooks or written policies of the Company that are inconsistent with its provisions. If you have any questions about any of the handbook’s provisions, please direct such questions to the Company’s management.

1.4 HISTORY OF BHI SENIOR LIVING

BHI Senior Living, Inc. has cultivated a tradition of serving the needs of others for over 100 years. From 1905 to 1951, the organization served as a non-profit orphanage and industrial school. Overtheyears,morethan1500boysandgirlswerehousedandcaredforbyIndianaBaptistHome in Boone County, Indiana.

In 1952, the board of directors voted to expand the services of the organization to the care of men and women aged 65 and older. Since 1952, there has been a concerted effort to meet the needsfor housing for older adults with quality communities and programs on an expanded basis.

As this campus evolved into the continuing care retirement community known todayas Hoosier Village and as other communities were developed by the corporation, it eventually changed its name to Baptist Homes of Indiana, Inc.

In 2011,the name Baptist HomesofIndiana waschangedtoBHI Senior Living, Inc.Thenewname was selected to maintain a link to the organization’s faith-based heritage while also trying to convey that the BHI communities are very inclusive and open to individuals of all denominations and backgrounds.

Currently, there are nine communities that comprise BHI Senior Living. Five communities are located in Indiana: The Barrington of Carmel in Carmel, Hoosier Village in Indianapolis, Four Seasons inColumbus, The Towne House inFort Wayne, and WesleyManor in Frankfort. In 2022, BHI Senior Living expanded our footprint into Michigan with Clark Retirement (Keller Lake and Franklin) inGrandRapidsandOhiowithMapleKnollVillageofCincinnatiandTheKnollsof Oxford in Oxford.

1.5 CODE OF PROFESSIONAL ETHICS

Employees of BHI are expected to conduct themselves with the highest ethical standards, in compliance with both the spirit and letter of the law and with the organization’s mission as a focal point.

Our principles and core values determine the course of the organization’s operations and professional reputation, including the delivery of quality services to our customers, employees, andotherstakeholderswithinourcommunities.We strivetoprovide aprofessionalenvironment and ensure decisions are made in a way that honors our past, defines our present and leads to continued success for our future.

Employees should refer to the Code of Business Conduct and Ethics for additional principles and policies they are expected to follow. Ethics violations and concerns should be submitted to Human Resources for review.

1.6 FOUNDATIONS

BHI and our affiliates maintain charitable Foundations that support both resident and employee programming. Through these Foundations, the organization is able to provide educational assistance to employees such as tuition reimbursement and scholarships. Terms and eligibility are specific to each community. More information about each region’s Foundation can be obtained online, through Human Resources or by contacting the Foundation Director for your community.

2. RESIDENT RIGHTS

BHI has adopted a formal Resident Rights Policy. Upon employment, each employee shall be instructed on the content of this policy and shall be required to acknowledge, in writing, receipt and understanding of same. Violation of this policy may result in disciplinary action up to and including termination.

3. RESIDENT ABUSE

It is the policy of BHI to ensure that all residents are free fromverbal, sexual, physical, or mental abuse; corporal punishment; exploitation; mistreatment; misappropriation of resident property; and involuntary seclusion. BHI maintains a comprehensive primary abuse prohibition policy that includes seven abuse prohibition components. Resident abuse shall be reported to appropriate authorities in accordance with such policies and state law.

This policy shall be presented to all new employees during new employee orientation and shall be presented to all employees annually through mandatory in-service programs. Each employee shall be required to sign a statement acknowledging receipt and understanding of the policy statement on resident abuse.

4. REPORTING OF A REASONABLE SUSPICION OF A CRIME PURSUANT TO THE ELDER JUSTICE ACT

It is the policy of the BHI long-term care facilities to comply with the Elder Justice Act (EJA) by reporting a reasonable suspicion of a crime against a resident under Section 1150B of the Social Security Act, as established by section 6703(b)(3) of the Patient Protection and Affordable Care Act of 2010. Employees should refer to the Resident abuse policy for their region which is reflective of all federal and state laws and reporting requirements.

5. EMPLOYMENT AND NON-DISCRIMINATION

5.1

EMPLOYMENT AT WILL

Employment at BHI is on an at-will basis unless otherwise stated in a written individual employment agreement signed by the President of the Company. This means that employment is of an indefinite duration, and either the employee or the Company may terminate the employment relationship at any time, for any reason, with or without cause or notice.

Nothing in this employee handbook creates or is intended to create an employment agreement, express or implied. Nothing contained in this or any other document provided to the employee is intended to be, nor should it be, construed as a promise or contract that employment or any benefit will be continued for any period of time. In addition, no Company representative is authorizedtomodifythispolicyforanyemployeeortoenter intoanyagreement, oralorwritten, that changes the at-will relationship, except by a written agreement signed by the President.

Any salary figures provided to an employee in annual or monthly terms are stated for the sake of convenience or to facilitate comparisons and are not intended to and do not create an employment contract for any specific period.

Nothing in this statement is intended to interfere with, restrain, or prevent concerted activity as protected by the National Labor Relations Act (NLRA). Such activity includes employee communications regarding wages, hours, or other terms or conditions of employment. BHI employees have the right to engage in or refrain from such activities.

5.2 COMMITMENT TO DIVERSITY

BHI is committed to creating and maintaining a workplace in which all employees have an opportunity to participate and contribute to the success of the business and are valued for their skills,experience,anduniqueperspectives.Thiscommitmentisembodiedin Companypolicyand the way we do business at BHI.

5.3 EQUAL EMPLOYMENT OPPORTUNITY

BHI provides equal employment opportunities to all employees and applicants for employment withoutregardtorace,color,creed,ancestry,nationalorigin,citizenship,sexorgender (including pregnancy, childbirth, and pregnancy-related conditions), gender identity or expression (includingtransgender status), sexual orientation, marital status, religion, age, disability, genetic information, service in the military, or any other characteristic protected by applicable federal, state, or local laws and ordinances. Equal employment opportunity applies to all terms and conditions of employment, including hiring, placement, promotion, termination, layoff, recall, transfer, leave of absence, compensation, and training.

The Company does not allow any form of retaliation against individuals who, in good faith, raise issues of equal employment opportunity. Retaliation means adverse conduct taken because an individual reported an actual or a perceived violation of this policy, opposed practices prohibited

by this policy, or participated in the reporting and investigation process described below. “Adverse conduct” includes but is not limited to:

(1) Shunning and avoiding an individual who reports harassment, discrimination, or retaliation;

(2) Express or implied threats or intimidation intended to prevent an individual from reporting harassment, discrimination, or retaliation;

(3) Denying employment benefits because an applicant or employee reported harassment, discrimination,orretaliationor participated in the reporting and investigationprocess;or

(4) Firing, demotion, denial of promotion, unjustified negative evaluations, increased surveillance, harassment, and assault.

Any employees with questions or concerns about equal employment opportunities should contact HR. Complaints of harassment, discrimination or retaliation should be filed according to the procedures described in the Anti-Harassment Policy and Complaint Procedure section.

5.4 AMERICANS WITH DISABILITIES ACT (ADA) and REASONABLE ACCOMMODATION

BHIis committedto thefair and equalemploymentofqualified individualswith disabilitiesunder the ADA. It is BHI’s policy to provide reasonable accommodation to qualified individuals with disabilities if such accommodation would allow the individual to perform the essential functions of the job, unless the accommodation would impose an undue hardship on the Company.

An employee or applicant with a disability may request an accommodation from Human Resources and should specify what accommodation is needed to perform the job and submit supporting documentation explaining the basis for the requested accommodation, to the extent permitted and in accordance with applicable law. The Company then will review and analyze the request, including engaging in an interactive process with the employee or applicant, to identify ifsuchanaccommodationcanbemadeorifanyotherpossibleaccommodationsareappropriate. If requested, the employee is responsible for providing medical documentation regarding the disability and possible accommodations. All information obtained concerning the medical condition or history of an applicant or employee will be treated as confidential information, maintained in separate medical files, and disclosed only as permitted by law.

It is the policy of BHI to prohibit harassment or discrimination based on disability or because an employee has requested a reasonable accommodation. BHI also prohibits retaliation against employees for exercising their rights, in good faith, under the ADA or other applicable civil rights laws.

AnyemployeeswithquestionsorconcernsabouttheADAorreasonableaccommodationsshould contact HR. If an employee feels they have been subjected to harassment, discrimination or retaliation related to their disability, they should bring these issues to the attention of an immediatesupervisor,HumanResources,orany other member ofmanagement with whom they feel comfortable. Complaints of harassment, discrimination or retaliation should be filed

according to the procedures described in the Anti-Harassment Policy and Complaint Procedure section.

5.5 ANTI-HARASSMENT AND COMPLAINT PROCEDURE

All BHI employees are expected to conduct themselves with dignity and respect for fellow employees, residents and all other individuals who have contact with the organization. It is BHI’s policy to prohibit intentional and unintentional harassment based on actual or perceived race, color, creed, religion, national origin, ancestry, citizenship status, age, sex or gender (including pregnancy, childbirth, and pregnancy-related conditions), gender identity or expression (including transgender status), sexual orientation, marital status, military service and veteran status,physical ormental disability, genetic information, orany othercharacteristicprotectedby applicable federal, state, or local laws. Such conduct will not be tolerated.

BHI is also committed to ensuring that our employees are not subjected to harassment by nonemployees. Accordingly, this policy applies to supervisors, employees, client/customers, residents and their families, vendors and all others with whom BHI has a relationship.

Harassment

Harassment prohibited by this policy is conduct that has the purpose or effect of creating an intimidating, hostile, or offensive work environment; has the purpose or effect of substantially and unreasonably interfering with an individual’s work performance; or otherwise adversely affects an individual’s employment opportunities because of the individual’s membership in a protected class.

Prohibited harassment includes, but is not limited to: epithets, slurs, jokes, pranks, innuendo, comments, or negative stereotyping; threatening, hostile, or intimidating acts based on a protected class;orwrittenor graphicmaterialthatdefamesorshowshostilityoraversiontoward an individual or group because of a protected class and that is circulated or placed by BHI employees on walls, bulletin boards, or elsewhere on the Company's premises or managed properties.

Sexual Harassment

While all forms of harassment are prohibited, special attention must also be paid to sexual harassment. “Sexual harassment” includes unwelcome conduct of a sexual nature whereby:

 Submission to or rejection of such conduct is made either explicitly or implicitly a term or condition of employment or as a basis for employment decisions.

 Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, a hostile, or an offensive work environment.

Whileitisnotpossibletolist allcircumstancesthatmayconstitute prohibited sexualharassment, the following are some examples of conduct that, if unwelcome, may constitute sexual

harassment depending on thetotality of the circumstances, including the severity ofthe conduct and its pervasiveness:

 Requests for sexual favors

 Unwantedphysicalcontact,includingtouching,pinching,orbrushingupagainstthebody;

 Unwanted sexual advances, whether they involve physical touching or not;

 Sexual epithets; jokes of a sexual nature; written or oral references to sexual conduct; gossip regarding one’s sex life; comments about an individual’s body; and comments about an individual’s sexual activity, deficiencies, or prowess;

 Displaying sexually suggestive objects, pictures, or cartoons;

 Unwelcome leering, whistling, sexual gestures, or suggestive or insulting comments;

 Inquiries into one’s sexual experiences;

 Discussion of one’s sexual activities; and

 Acts of physical aggression, intimidation, hostility, threats, or unequal treatment based on sex (even if not sexual in nature)

Other sexually oriented conduct, whether intended or not, that is unwelcome and has the effect of creating a work environment that is hostile, offensive, intimidating, or humiliating to workers may also constitute sexual harassment.

Allemployeesshouldtakespecialnotethatretaliation againstan individualwhohas complained, in good faith, about sexual or other harassment and retaliation against individuals for cooperating with an investigation of sexual or other harassment complaints is a violation of BHI’s policy.

Complaint Procedures

If you believe you have been subjected to or witnessed unlawful discrimination, including sexual or other forms of unlawful harassment, or other inappropriate conduct, you must immediately reportit.Youmayreportsuchconcernsdirectlytoyourimmediatesupervisor,HumanResources, or any other member of management with whom you feel comfortable bringing such a complaint. Similarly, if you observe acts of discrimination toward or harassment of another employee, you are required to report this to one of the individuals listed above.

All complaints will be investigated promptly, thoroughly and impartially, and confidentiality will be protected to the extent possible. A timely resolution of each complaint will be reached and communicated to the parties involved. If the investigation confirms conduct that violates this policy has occurred, BHI will take immediate, appropriate corrective action up to and including immediate termination of employment.

No reprisal, retaliation or other adverse action will be taken against an employee for making a goodfaithcomplaintorreportofdiscriminationorharassmentorforassistingintheinvestigation of any such complaint or report. Any suspected retaliation or intimidation should be reported immediately to one of the persons identified above.

5.6 CONFIDENTIALITY AND HIPAA PRIVACY STANDARDS

BHI Senior Living is committed to safeguarding confidential information and privacy throughout the organization. Employees are expected to conduct all activities with honesty, integrity, respect, and fairness.

Confidential information is any and all information disclosed to or known by you because of employment with BHI that is not generally known to people outside the Company including information regarding employees, residents and clients. Access to organizational business information may include but is not limited to, paper, electronic, video and/or audio formats. All non-public and proprietary information used within the course of business is the exclusive property of BHI Senior Living.

Disclosure of confidential information with anyone other than authorized personnel for business purposes isconsideredaviolation of BHI’sconfidentiality policyandtheemployee willbe subject to corrective action up to and including termination.

Allinquiries fromthemediamustbereferredtothe corporatemarketingdepartmentofBHI.This provision is not intended to, and should not be interpreted to, prohibit employees from discussing wages and other terms and conditions of employment if they so choose.

It is the policy of BHI to assure that the privacy of all personal health information (PHI) of our residents and employees shall be protected to the fullest extent possible in compliance with the Health Insurance Portability and Accountability Act (HIPAA) privacy and security rules. As a healthcare provider that transmits PHI in electronic format, all medical records shall be maintained in a highly confidential manner. Employees should refrain from the transfer of PHI via text or email. Under no circumstances shall an employee remove a medical record from the community nor release a medical record without the express written authorization of the community Executive Director, President/CEO, and/or Senior Vice-President/CFO (i.e., due to emergency or disaster situations.)

If you identify any employee using improper practices and/or a breach of PHI, it is your responsibility to notify the HIPAA Security Officer for your community.

5.7 EMPLOYMENT PROCESS AND PRE-EMPLOYMENT SCREENING

A completed employment application for each employee shall be on file with the Human Resources Department. Falsifying information on your employment application or withholding information that would have affected BHI's decision to hire you may result in termination of employment.

BHISeniorLivingwillconductacomprehensivepre-employmentscreeningonallnewhireswhich will include:

 state and federal criminal background check;

 verification of required credentials or licensure as deemed necessary for the position;

 non-exclusion from the Office of the Inspector General (OIG); and

 former employment verification.

In addition, a physical examination is required for each community-based employee before the first day of employment which includes a two-step tuberculosis (TB) screening and drug screening. Additional testing may be required as mandated by state regulations.

All newly hired employees are required to provide proof of eligibility for employment within the United States within 3 days of start date. Failure to provide sufficient documentation or to complete the I-9 form within the 3-day window will require the employee to cease work until documentation can be obtained and also may result in termination.

5.8 CRIMINAL BACKGROUND CHECKS AND CONVICTIONS

BHI Senior Living will conduct a comprehensive state and federal background check on all prospective employees as a condition of employment. Background checks will be conducted in accordance with state and federal regulations.

BHI will consider an applicant's job duties, among other factors, in determining what constitutes satisfactory completion of the background check. All information obtained as a result of a background check will be used solely for employment purposes and all background check information will be kept confidential.

If the Company uses a consumer reporting agency to obtain background check information or makeanemploymentdecisionbasedonthatinformation,theCompanywillcomplywithrelevant requirements under the Fair Credit Reporting Act (FCRA). Employees must also complete an authorization form. Falsification or omission of information may result in denial of employment or discipline, up to and including termination.

All active employees must report to HR if subsequent to employment, the employee is convicted of a criminal offense that would preclude employment or could result in loss of required professional licensure. Employees who provide transportation services must report information related to the suspension of driver license. A legal review will be conducted by the General Counsel and Vice President Human Resources to determine continued employment eligibility.

Employees who fail to report such convictions or offenses may be subject to corrective action, up to and including termination. At minimum, BHI will conduct background screening on active employees every 5 years (or continuously as required by state) and findings will be subject to legal review against state long-term care employment regulations.

5.9 REFERENCE CHECKS

In accordance with state regulations, BHI will conduct pre-employment professional reference checks on new hires. A copy will be stored in the employee’s personnel file.

Requests for current or former employees should follow the community process for reference checks. The organization will only provide employee name, dates of employment and job title; no other information will be released, unless required by law. Additional information, such as income verification, may be provided following written authorization by the employee.

5.10 CRIMES BARRING EMPLOYMENT AT HEALTH CARE FACILITIES

If, in their respective state of employment, an applicant of BHI has been convicted of any crime listed in Indiana Code § 16-28-13-3, Ohio RevisedCode § 3721.121 or Michigan Compiled Laws § 333.20173a, the applicant will be barred from employment at BHI.

Indiana Ind.Code§16-28-13-3

(1) Murder;

(2) Voluntarymanslaughter;

(3) Involuntarymanslaughter(w/in thepast5years);

(4) Felonybattery(w/inthepast5 years);

(5) Afelonyrelatingtocontrolled substances(w/inthepast5 years);

(6) Theft(w/inthepast5years);

(7) Asexcrime;

(8) Exploitationofanendangered adult;

(9) Failuretoreportbattery, neglect,orexploitationofan endangeredadult.

Ohio* OhioAdmin.Code§3701-13-05** Michigan Mich.Comp.LawsAnn.§ 333.20173a

(1) Homicide;

(2) Assault/Aggravatedmenacing; (3) Sexualassault/Sexualbattery/ Voyeurism;

(4) Kidnapping/Abduction/ Extortion/Coercion;

(5) Robbery/Burglary/Breaking andentering; (6) Theft/Forgery/Fraud; (7) Domesticviolence; (8) Gunorweaponviolations; (9) Drugoffenses; (10) Illegalconveyanceof prohibiteditemsonto governmentproperty; (11) Prostitution/Obscenity; (12) Patientorimpairedpersons abuseorneglect; (13) Adulterationoffood.

(1) Afelonyinvolving(w/inthe past15years):

(a) Death;

(b) Criminalsexualconduct; (c) Abuse/neglect; (d) Crimesagainstvulnerable adults;

(e) Cruelty/torture;

(f) Firearm/dangerousweapon;

(g) Controlledsubstance;

(2) Allotherfelonies(w/inthepast 10years);

(3) Amisdemeanorinvolving(w/in thepast10years):

(a) Criminalsexualconduct; (b) Firearm/dangerousweapon withintenttoinjure; (c) Crimesagainstvulnerable adults;

(d) Abuse/neglect;

(4) Amisdemeanorinvolving(w/in thepast5years):

(a) Cruelty(ifundertheageof 16whencommitted);

(b) Homeinvasion;

(c) Theft/fraud;

(d) Assault;

(e) Controlledsubstance;

(f) Retailfraudinthesecond degree;

(5) Amisdemeanorinvolving(w/in thepast3years):

(a) Assaultwithnofirearmor weaponandintenttoinjure;

(b) Retailfraudinthethird degree;

(c) Controlledsubstance;

(6) Amisdemeanorinvolving(w/in thepastyear):

(a) Controlledsubstance(if undertheageof18when committed);

(b) Larceny/retailfraud(if undertheageof16when committed).

AllStates

(1) Medicare-relatedcrimes

(2) Patientabuse

(3) Anyfelonyforhealthcare-relatedfraud,theft,embezzlement,orfinancialmisconduct

(4) Anyconvictionrelatingtoacontrolledsubstance

 Marijuanaisconsideredacontrolledsubstance,accordingtotheControlledSubstancesAct, 21U.S.C.§841(b)(1)(D)–anyconvictionformarijuanashouldbereviewedwithlegalcounselbefore proceeding.

5.11 EMPLOYEE RELATIONSHIPS AND NEPOTISM

Employeeswhoenterintoa romanticorsexualrelationshipwithanother employee areexpected to act and interact in a manner that does not affect either associate’s work. To help prevent conflicts of interest and any potential appearance of impropriety, supervisors may not engage in romantic or sexual relationships with any subordinate in their chain of command. In such case, the relationship shall be reported and may result in transfer of the employee or supervisor. Failure to act appropriately may result in corrective action up to and including termination.

BHI may hire relatives of current employees provided the applicant possess all necessary qualifications for the position and passes all pre-employment requirements. For purposes of this policy, “relative” includes spouse, parent, children, step-children, sibling, grandchildren, grandparent,in-law,niece/nephew,aunt/uncleoranyotherrelativelivinginthesamehousehold as an employee. It is against the policy of BHI for relatives to act as direct or indirect supervisor to afamilymember ortoworkinpositionsthathaveinfluenceorcontrolover theother.To avoid conflicts of interest, BHI prohibits the hiring, transfer or promotion of relatives of employees where doing such would create the perception or appearance of favoritism.

5.12 EMPLOYMENT OF MINORS

State and Federal laws regulate the employment of minors. No minor under the age of 16 may be employed by BHI Senior Living. Employment of those between the ages of 16 and 17 years of

age must comply with all applicable state and federal regulations surrounding the employment of minors.

5.13 REASONABLE ACCOMODATIONS FOR PREGNANT WORKERS

PUMP ACT

As part of our family-friendly policies and benefits BHI supports breastfeeding employees by accommodating an employee who needs to express breast milk during the workday.

Accommodation for Lactating Employees

For up to one year after the child’s birth, any employee who is breastfeeding will be provided reasonable break times to express breast milk. Employees should speak with human resources to reserve the designated lactation room for their community.

Breaks of more than 20 minutes in length will be unpaid and recorded on timesheets where appropriate.

PREGNANT WORKERS FAIRNESS ACT (PWFA)

As required by the federal Pregnant Workers Fairness Act (PWFA), BHI Senior Living will provide reasonable accommodations to employees and applicants with limitations related to pregnancy, childbirth, or related medical conditions, unless the accommodation will cause undue hardship to BHI’s operations. Requests for accommodation should be made through human resources.

6. EMPLOYMENT RELATIONSHIP

6.1 EMPLOYMENT CLASSIFICATION

All employees will be provided with a copy of a job description which details the performance expectations for their specificposition. Inorder to determine eligibility for benefits and overtime status and to ensure compliance with federal and state laws and regulations, BHI Senior Living classifies its employees as shown below. BHI may review or change employee classifications at any time.

 Exempt - Employees whose duties comply with one of the exemptions under the Fair Labor Standards Act (FLSA). Exempt employees are typically paid on a salary basis and are not eligible to receive overtime pay for hours worked over 40 in a workweek.

 Nonexempt - Employees who do not qualify for one of the exemptions under the FLSA. Nonexempt employees are typically paid on an hourly basis and are eligible to receive overtime pay for overtime hours worked over 40 in a workweek.

 Regular, full time - Employeeswhoarenotinatemporarystatusandworkaminimum of 30 hours weekly (60 hours per pay period) and maintain continuous employment status. Generally, these employees are eligible for the full-time benefits package and are subject to the terms, conditions, and limitations of each benefits program.

 Regular, part time - Employees who are not in a temporary status and who are regularly scheduled to work less than 30 hours weekly (less than 60 per pay period) and who maintain continuous employment status. Part-time employees are eligible for some of the benefits offered by the Company and are subject to the terms, conditions, and limitations of each benefits program.

 Temporary, full time - Employees who are hired as interim replacements to temporarily supplement the workforce or to assist in the completion of a specific project and who are temporarily scheduled to work the Company’s full-time schedule for a limited duration. Employment beyond any initially stated period does not in any way imply a change in employment status. Temporary employees are not eligible for benefits offered by the Company.

 Temporary, part time - Employees who are hired as interim replacements to temporarily supplement the workforce or to assist in the completion of a specific project and who are temporarily scheduled to work less than 30 hours weekly for a limited duration. Employment beyond any initially stated period does not in any way imply a change in employment status. Temporary employees are not eligible for benefits offered by the Company.

 Contingent (On-Call) - Contingent employees are those individuals hired with no specificnumberofapprovedhours.Contingentemployeesarenoteligibleforbenefits offered by the Company.

6.2 INTRODUCTORY PERIOD

Employees of BHI Senior Living are considered to be in an “onboarding period” of employment during their first 90 days. During this time, employees are in training and should receive routine feedbackfromleadersonperformanceandresourcesto assistinassimilatingtotheorganization.

Employees are eligible for benefits as applicable during this period, subject to the terms of plan description.Anemployeemayterminatetheiremploymentandtheemployeemaybedischarged with or without notice or cause both during and after the initial onboarding period. The onboarding period does not modify any employee’s at-will status.

A written employee evaluation will be completed for employees after 30 days and at the conclusion of the introductory period.

6.3 CONFLICTS OF INTEREST

BHI Senior Living expects all employees to conduct themselves and company business in a manner that reflects the highest standards of ethical conduct and in accordance with all federal, state, and local laws and regulations. All business judgements should be made in the Company’s best interest to meet and sustain its mission and reflect the core values and code of ethics. This includes avoiding real and potential conflicts of interests.

Generally speaking, a conflict exists when the personal or business interests and/or activities of an employee may potentially influence the employee's judgement in the performance of their duty to the Company. BHI recognizes and respects the individual employee’s right to engage in activities outside of employment that are private in nature and do not conflict with the Company’s business interests.

All employees arerequired to immediatelydisclose any potentialorperceived conflictof interest at the time it develops to Human Resources, the Executive Director, or the Compliance Officer.

It is not possible to define all the circumstances and relationships that might create a conflict of interest.Thelistbelowsuggestssome,butnot all,ofthetypesof activitiesthat indicate improper behavior, unacceptable personal integrity, or unacceptable ethics:

 Items purchased from a resident.

 The sale of products or services to residents, resident family members, or visitors.

 Accepting tips or gifts from residents.

 Accepting inheritances from a resident’s estate.

 Witnessing resident documents without the express permission of the Executive Director (wills, etc.).

 Serving as a Power of Attorney, Health Care Representative, Trustee, Guardian, or any other legal capacity for a resident.

 Employment directly with a resident without the express written permission of the Executive Director.

 Working asecondjob,ifit interfereswiththeemployee’sproductivityandworkschedule.

 Simultaneous employment by another firm that is a competitor of or supplier to BHI without advance approval of BHI (does not applyto part time or contingent nursing staff)

 Carrying on company business with a firm in which the employee, or a close relative of the employee, has a substantial ownership or interest.

 Holding a substantial interest in, or participating in the management of a firm to which BHI makes sales or from which it makes purchases.

 Borrowing money from residents or firms, other than recognized loan institutions, from which BHI buys services, materials, equipment, or supplies.

 Accepting substantial gifts or excessive entertainment from an outside organization or agency.

 Speculating or dealing in materials, equipment, supplies, services, or property purchased by the Company.

 Misusing privileged information or revealing confidential data to outsiders.

 Using one’s position in the Company or knowledge of its affairs for personal gains.

 Engaging in practices or procedures that violate antitrust laws, commercial bribery laws, copyright laws, discrimination laws, campaign contribution laws, or other laws regulating the conduct of Company business.

6.4 ACCESS TO PERSONNEL FILES

Employee files are maintained by the HR department and are considered confidential. Managers and supervisors may only have access to personnel file information on a need-to-know basis. Employees may inspect their own personnel files periodically at reasonable intervals, generally not more than twice per year. Employees may copy but may not remove documents from their file (copy fees may apply). Inspections by employees must be requested in writing to HR and will be scheduled at a mutually convenient time, or as required under state law. Personnel files are to be reviewed in the HR department. Representatives of government or law enforcement agencies, in the course of their duties, may be allowed access to file information.

6.5 SEPARATION FROM EMPLOYMENT

In all cases of voluntary resignation (one initiated by the employee), employees are asked to provide a written notice to their supervisors at least 10 working days in advance of the last day of work. The 10 days must be actual working days. Holidays and PTO will not be counted toward the 10-day notice. Employees who provide the requested amount of notice will be considered to have resigned in good standing and generally will be eligible for rehire.

In most cases, HRwill conduct an exit meeting onor beforethe last day of employment to collect all Company property and to discuss final pay. Company's sole obligation shall be to pay accrued but unpaid wages up until the separation of employment. If applicable, information regarding benefits continuation through the Consolidated Omnibus Budget Reconciliation Act (COBRA) will be sent to the employee.

Employees who separate from the organization and return after a period of six months or less will have the time counted towards original service period and will be eligible for all benefits as such.

6.6 EMPLOYEE PRIVACY AND WORKPLACE INVESTIGATIONS

Investigations

It is the goal of BHI Senior Living to respect the individual privacy of its employees and at the same time maintain a safe and secure workplace. When issues of safety and security arise, employees may be requested to cooperate with an investigation to safeguard the Company and its employees. Thus, the Company reserves the right at all times to search or inspect employees' surroundings and possessions in the workplace. Employees should have no expectation of privacy while on the Company premises, except in private areas such as restrooms and locker/dressing rooms. Company investigations may include searches of personal belongings, searches of work areas, searches of private vehicles on Company premises, medical examinations, etc. Failure to cooperate with an investigation is grounds for termination. Providingfalseinformationduringanyinvestigationmayleadtodiscipline,includingtermination.

Monitored Activity

As part of its security measures and to help ensure a safe workplace, BHI utilizes video surveillance cameras to monitor various areas of its facilities. Video cameras are not used in private areas, such as restrooms and locker/dressing rooms.

BHI regularly monitors its communications systems and networks as allowed by law. Monitored activity may include voice, e-mail, and text communications, as well as Internet search and browsing history. Employees are expected to keep personal communication to a minimum and to emergency situations. Employees who make excessive use of the communications system for personal matters are subject to discipline.

Employees are expected to make use of Company facilities only for the business purposes of the Company. Accordingly, materials that appear on Company hardware or networks are presumed to be for business purposes, and all such materials are subject to review by the Company at any timewithoutnoticetothe employees.Employeesdo not havetohaveany expectation of privacy with respect to any material on Company property.

6.7 TRANSFERS & PROMOTIONS

It is the policy of BHI to transfer and/or promote the most qualified person and not discriminate because of race, color, religion, disability, national origin, sex, age, gender identity, sexual orientation, genetic information, or any other factor prohibited by law.

BHI encourages internal mobility and is committed to hiring and promoting from within, when appropriate. Employeesshould applyfor internalopportunitieswhentheypossess thenecessary experience and qualifications for jobs within their current department or other departments within the organization. Employees interested in internal job opportunities must complete an

internal application on the HR management system for promotion or transfer. The hiring manager for the role should consult with the employee’s current supervisor to discuss the employee’s performance and share relevant feedback regarding the position the employee is being considered for, if the employee is otherwise qualified.

Employees are not permitted to apply for another position unlessthey havebeenemployed for at least six (6) consecutive months in their current position (unless an exception has been approved by the Executive Director or Vice President of Human Resources). Employees who are on an active written warning, or who received aperformance rating of “below expectations”, are not eligible to apply for other positions.

Due to changes in workloads or other relevant business reasons, it may be necessary for BHI to make temporary or permanent transfers or reassignments.

 Transfers are a change in job responsibilities and/or department but the job classification/grade remains equivalent to the position from which the employee transferred. Transfers do not generally warrant a change in compensation.

 Promotions are a significant change in duties and/or responsibilities within the same department or to another department which may include a change in compensation.

 Reassignments are a change in job duties within the same department.

7. PAYROLL AND TIMEKEEPING

7.1 PAYCHECKS

BHI pays its employees for wages bi-weekly on Friday for a total of 26 pay periods per year.

When payday falls on a holiday, the effective payroll date will be the day before the regular payday. The Company will not approve a pay advance under any circumstances.

Direct deposit is the preferred wage payment method for BHI. Employees will enroll into direct deposit while completing new hire onboarding in the HR Management System (UKG). New employees may receive their pay in the form of a check for the first pay while direct deposit is being set up.

Employee Earnings Statements will be made available after each bi-weekly pay period and are viewable by employees in UKG. Paychecks or earnings statements will not be given to persons other than the employee unless the person requesting presents a written authorization signed by the employee directing such delivery.

Any questions you might have related to your salary or pay should be discussed with your supervisor. It is the responsibility of the employee to review their paystub and report any inaccuracies, omissions, etc. If you believe there is an error in your pay, please contact Human Resources immediately. To the extent an error is confirmed, it will be corrected on the next payroll.

7.2 TIMEKEEPING AND BREAKS

Non-exempt employees must accurately record all time worked for payroll purposes and are expected to clock-in and out in accordance with their scheduled shift and breaks. Employees should not begin working prior to their scheduled time unless authorized. Employees are to be paid for any time worked. Working off the clock is strictly prohibited. Employees should adhere to the established timekeeping guidelines for their community regarding clocking in and out.

Filling out another employee's time, allowing another employee to fill out your time, or altering any time without authorization will be grounds for discipline up to and including termination. Any changes to timecards must be approved and completed by a supervisor.

Supervisors will inform full-time employees when they are permitted to take their breaks. Meal and break periods are meant to provide employees an opportunity to be away from work, and nonexempt employees may not perform any work during meals or breaks. Meal periods must be accuratelyrecordedinthe time keepingsystembyclocking inand out. Anynonexemptemployee whoperformsworkduringtheirmealperiod must clockbackinbeforeperformingwork ornotify their supervisor so that the appropriate time entry adjustment can be made.

Any errors with regard to your time should immediately be reported to management, who will attempt to promptly correct legitimate errors.

7.3 OVERTIME PAY

Occasionally overtimework becomes necessary,and employees may be asked to work overtime. Refusal to work overtime may result in disciplinary action. No overtime will be allowed without the prior approval of your supervisor. Nonetheless, employees must record or be clocked in during all hours worked, even if it results in overtime that has not been approved.

Nonexempt Employees

Nonexempt employees receive overtime pay of one and one-half times their regular hourly rate for all hours worked over 40 hours in any work week. Paid hours not actually worked (e.g., paid time off, holidays, etc.) will not be counted toward the 40 hours per work week required to receive overtime pay.

NonexemptemployeesarenotexpectedtoandshouldnotengageinBHIbusinessbeforeorafter the employee's shift through calls, texts, or e-mails, unless specifically requested by the employee’s supervisor or another member of management or otherwise required by the employee's position. If an employee does engage in business calls, texts, or e-mails outside of the employee's shift, the employee must report the time spent in such activities.

Exempt Employees

Exempt employees are not eligible for overtime pay and typically receive a predetermined salary amounteachpayperiod.Certaintypesofdeductions fromexemptemployees'payareallowable, including:

 Full-day absences for sickness or disability if made in accordance with a bona fide plan of providing compensation for loss of salary caused by the impairment (e.g., disability insurance, workers' compensation benefits, etc.).

 To offset amounts employees receive as jury dutyor witness duty fees or for military pay.

 For penalties imposed in good faith for infractions of safety rules of major significance.

 For unpaid disciplinary suspensions of one or more full days imposed in good faith for workplace conduct rule infractions.

 For partial weeks worked in the initial or final week of employment.

7.4 TRAVEL TIME

Nonexempt employees shall be paid their hourly rate for travel time from the community or, if more efficient, from the employee’s home if traveling for an approved business purpose. Such time does not include normal commute time from the regular place of work. The employee’s supervisor must approve paid traveltime in advance. Travel time for the purposes of computing overtime shall be considered as hours worked.

7.5 DEDUCTIONS AND GARNISHMENTS

BHI withholds all necessary federal and state taxes from employees' pay as mandated by law. Employees are expected to update tax forms as needed based on changes in residence,

dependents or status to ensure accuracy for each tax year. Employees must also update UKG as soon as possible regarding any change of name, address, marital status, and/or telephone number.

Additionally, voluntary deductions such as health benefits, retirement deferrals etc. can be electedbytheemployeein accordancewiththe organization’senrollment eligibility and process. The Company prohibits unlawful deductions from exempt employees' pay and will not take any deductions unless allowed by applicable law. If an employee believes any improper deductions have been made from their pay, employee should report their concern to management. The Company will investigate all concerns and take prompt corrective action if an error has been made. Retaliation against an employee who has raised such a concern in good faith is strictly prohibited.

Wage garnishment is a legal proceeding initiated by a creditor to capture a portion of the employee’s wages to make payment through the employer toward the employee’s debt. BHI is obligated to notify the employee of any garnishment order and to begin withholding the garnishment as soon as administratively possible. It is the organization’s policy not to become involved in the personal financial responsibilities ofemployees outside of this legal requirement.

8. TIME OFF AND LEAVES OF ABSENCE

8.1 PAID TIME OFF (PTO)

Paid Time Off (PTO) provides employees with compensated time off work for vacation, personal or family illness, injury, religious observation, inclement weather, extended bereavement, and other personal matters.

Eligible employees begin accruing PTO immediately upon employment and are eligible to begin scheduling PTO upon completion of 30 days of continuous employment. PTO is based on actual hours worked (hours worked includes time workedand paid time off) and accrues at the following rates:

Regular Paid Time Off

Professional/Salary Paid Time Off

Executive Paid Time Off

For example, if an employee works 80 hours during the pay period and has 2 years of service, he/she will earn 4.92 hours of PTOfor that pay period (80 x 0.0615 PTO factor = 4.92 PTO hours).

Time off should be requested in advance whenever possible, however, PTO can be used for both scheduled and unscheduled absences. PTO must be requested in accordance with community or department policy and procedures. There must be enough available PTO accrued for an employee to request PTO. Unpaid time off is subject to supervisor and HR approval. Due to

staffing and business needs, not all PTO requests may be honored, and advance requests are still subject to appropriate approval.

No unused PTO benefits shall be paid out to employees upon involuntary separation of employment. The Company will only pay out accrued, unused PTO benefits to employees upon voluntary termination and with proper notice. PTO requests will not be granted during the notification period for those employees leaving the company.

PTO CASH OUT

Regular full-timeand part-time employeeswhomeetthe servicerequirementsbelowareeligible to receive pay in lieu of PTO as follows:

 Year 1 Up to 20 hours of PTO

 Year 2 Up to 30 hours of PTO

 Year 3+ Up to 40 hours of PTO

A minimum balance of 40 hours must remain in the employee’s PTO bank to utilize the cash out option. Employees are eligible to request this benefit multiple times a year but may not exceed the maximum cash out hours for their years of service. The cash out request mustbe received on Thursday before payroll processing to receive a cash out by the next pay day.

PTO DONATION

BHI recognizes that there may be situations where an employee may experience financial hardship or may need to take additional time away from work to handle an urgent matter and as such, permits employees the opportunity to donate PTO to other employees to assist them in those situations.

Eligibility for Giving Employee:

1. The giving employee must have a minimum of 40 hours remaining in their PTO bank after making the PTO donation.

2. The giving employee may not donate more than 40 hours per year.

3. Executives are not eligible to donate PTO.

Eligibility for Receiving Employee:

1. Employee may receive PTO from more than one donator however, they may not cash out more than 40 hours of PTO and cannot exceed their current PTO bank annual maximum through the donation.

2. Receiving employee must be in a PTO eligible position and have been employed for a minimum of 90 days.

Employees should contact Human Resources for specific guidance on how to participate in the PTODonationProgram.AllPTOdonationrequestsaresubjecttoHumanResourcesapproval. BHI reserves the right to revise and/or terminate the Employee PTO Donation Program at any time.

Extended Illness Bank and Additional PTO

There may be circumstances in which an employee has a second bank of paid time off or additional paid time off temporarily available to them.

Additional PTO may be available in an employee’s PTO bank when, as a result of a new organization affiliating or being acquired by BHI, the employee has accrued but unused PTO that exceeds the maximum amount permitted under BHI’s current PTO policy. Employees with additional PTO are expected to use this time within six months from the date in which the additional PTO was deposited into the employee’s PTO bank. The additional PTO is eligible to be cashed out or donated in accordance with BHI’s current PTO policy.

The Extended Illness Bank may be available when an employee, as a result of a prior BHI policy or an affiliation or acquisition, has accrued but unused PTO separate from their regular paid time offandspecificallydesignatedfortheemployee’sillnessorinjurythatrequires anabsencelonger than two weeks. Employees shall use their regular PTO time for the initial two weeks of their absence. There is no time limit for using time within the Extended Illness Bank. Additionally, no newtimeistobe earnedintothebank. These hours arenoteligibletobe cashed out ordonated. An employee who is at least 62-1/2 years of age, with at least 15 years of service and is leaving the organization due to retirement and with proper notice will be paid out 50% of the bank’s remaining balance on their final paycheck (less applicable taxes).

BHI’s Corporate Human Resources department determines the rules andconditions under which Paid Time Off, the Extended Illness Bank and additional PTO are used.

8.2 COMPANY PAID HOLIDAYS

The following are considered holidays for all BHI Senior Living communities:

 New Year’s Day

 Martin Luther King Jr Day

 Memorial Day

 Independence Day

 Labor Day

 Thanksgiving Day

 Christmas Day

For administrative staff, holidays occurring on Saturday will be observed on the Friday prior to theholiday. Holidaysoccurring on Sunday willbeobserved on the Monday following the holiday.

Employees who needtime off to observe religious practices or holidays notalready scheduled by the Company should speak with their supervisor. Depending upon business needs, the employee may be able to work on a day that is normally observed as a holiday and then take time off for another religious day. Employees may also be able to switch a scheduled day with another

employee, take vacation time, or take off unpaid days for religious practices or holidays. The Company will seek to reasonably accommodate individuals’ religious observances.

Employees are eligible for holiday pay after 30 calendar days of employment. All employees who workonaholidayarepaidtwicetheirregularhourlyrateforallhoursworked.Regularemployees who do not work on a holiday will receive holiday pay at their regular hourly rate for up to 12 hours, based on their regularly scheduled hours for the pay period. Use of unscheduled PTO the day prior to or the day following the holiday will result in loss of holiday pay.

8.3 FAMILY MEDICAL LEAVE ACT (FMLA)

BHI Senior Living complies with the federal Family and Medical Leave Act of 1993 (FMLA), which requires employers to grant unpaid, job-protected leaves of absence to qualified workers for certainmedicalandfamily-related reasons.TheCompany alsoabidesby anystate and localleave laws. The more generous of the laws will apply to the employee if the employee is eligible under both federal and state laws.

Please note there are many requirements, qualifications, and exceptions under these laws, and each employee’s situation is different. Employees should contact the HR department for their community to discuss options for leave.

The FMLA requires private employers with 50 or more employees and all public agencies, including state, local, and federal employers, and local education agencies (schools) to provide eligible employees up to 12 weeks of unpaid, job-protected leave in any 12-month period for certain family and medical reasons. The 12-month period is a rolling period measured backward from the date an employee uses any FMLA leave, except for leaves to care for a covered service member with a serious illness or injury. For those leaves, the leave entitlement is 26 weeks in a single 12-month period measured forward from the date an employee first takes that type of leave.

Employee Eligibility

The FMLA defines eligible employees as employees who (1) have worked for the Company for at least 12 months; (2) have worked for the Company for at least 1,250 hours in the previous 12 months; (3) work at or report to a worksite that has 50 or more employees or is within 75 miles of Company worksites that, taken together, have a total of 50 or more employees; and (4) have a qualifying reason to take FMLA leave.

Basic Leave Entitlement

The FMLA requires covered employers to provide up to 12 weeks of unpaid, job-protected leave to eligible employees for the following reasons: (1) for incapacity due to pregnancy, prenatal medical care, or childbirth; (2) to care for the employee’s child after birth or placement for adoption or foster care; (3) to care for the employee’s spouse, child, or parent who has a serious health condition; or (4) for a serious health condition that makes the employee unable to work.

Military Family Leave Entitlements

Eligible employees with a spouse, child, or parent on active duty or called to active-duty status in the National Guard or Reserves in support of a contingency operation may use their 12-week leave entitlement to address certain qualifying exigencies.

Qualifying exigencies may include addressing issues that arise from (1) short notice of deployment (limited to up to 7 days of leave); (2) attending certain military events and related activity; (3) arranging child care and school activities; (4) addressing certain financial and legal arrangements; (5) attending certain counseling sessions; (6) spending time with covered military family members on short-term temporary rest and recuperation leave (limited to up to 5 days of leave); (7) attending post deployment reintegration briefings; (8) arranging care for or providing care to a parent who is incapable of self-care; and (9) any additional activities agreed upon by the employer and employee that arise out of the military member’s active duty or call to active duty.

The FMLA also includes leave entitlement that permits eligible employeesto takeup to 26 weeks of leave to care for a covered servicemember during a single 12-month period. A covered servicemember is a current member of the armed forces, including a member of the National Guard or reserves, who has a serious injury or illness incurred in the line of duty on active duty that may render the servicemember medically unfit to perform the duties of the servicemember’s office, grade, rank, or rating and for which the servicemember is undergoing medical treatment, recuperation, or therapy; is in outpatient status; or is on the temporary disability retired list.

Both spouses employed by BHI

Eligible spouses who both work for the Company may only take a combined total of 12 weeks of leave for the birth of a child, adoption, or placement of a child in foster care, or to care for a parent(butnotaparent"in-law")withaserioushealthcondition.Bothmayonlytakeacombined total of 26 weeks of leave to care for a covered injured or ill service member (if each spouse is a parent, spouse, child or next of kin of the service member).

Benefits and Protections During FMLA Leave

DuringFMLAleave,theCompanywillmaintaintheemployee’shealthcoverageunderany“group health plan” on the same terms as if the employee had continued to work. Upon return from FMLA leave, employees will be restored to their original or equivalent positions with equivalent pay, benefits, and other employment terms. However, an employee on FMLA leave does not have any greater right to reinstatement or to other benefits and conditions of employment than if the employee had been continuously employed during the FMLA leave period.

Certain highly compensated key employees also may be denied reinstatement when necessary to prevent “substantial and grievous economic injury” to the Company’s operations. A “key” employee is an eligible salaried employee who is among the highest-paid 10 percent of the Company’s employees within 75 miles of the worksite. Employees will be notified of their status as key employees, when applicable, after they request FMLA leave.

Use of FMLA leave cannot result in the loss of any employment benefit that accrued before the start of an employee’s leave.

Definition of “Serious Health Condition”

Aserioushealthcondition isan illness,aninjury,animpairment,oraphysicalormentalcondition that involves either an overnight stay in a medical care facility or certain types of continuing treatment by a healthcare provider for a condition that either prevents the employee from performing the functions of the employee’s job or prevents the qualified family member from participating in school, work, or other daily activities.

Use of Leave

An employee may use FMLA leave in a continuous block or intermittently. Leave can be taken intermittently or on a reduced work schedule when medically necessary. Employees must make reasonable efforts to schedule leave for planned medical treatment so as not to unduly disrupt the employer’s operations. Leave due to qualifying exigencies also may be taken on an intermittent or a reduced work schedule basis. In all cases, the leave may not exceed a total of 12 workweeks (or 26 workweeks to care for an injured or ill service member) in a 12-month period.

If all leave under this policy is exhausted and the employee is still unable to return to work, they must notify the Company as soon as possible. The situation will be reviewed to determine what rights and protections might exist under other Company policies.

Substitution of Paid Leave for Unpaid Leave

The Company requires employees to use any accrued PTO concurrently during any approved FMLA leave. In order to use paid leave for FMLA leave, employees must comply with the Company’s normal paid leave procedures found in its PTO policy.

The substitution of paid leave time for unpaid FMLA leave does not extend the FMLA leave period. In no case can the substitution of paid leave time for unpaid leave time result in receipt of more than 100% of the employee's salary. Unless prohibited by law, FMLA leave runs concurrently with other types of leave.

Employee Responsibilities

Employees must provide 30 days’ advance notice of the need to take FMLA leave when the need is foreseeable. When 30 days’ notice is not possible, employees must provide notice as soon as practicable and generally must comply with the Company’s normal call-in procedures. The Company may delay leave to employees who do not provide proper advance notice of the foreseeable need for leave, absent unusual circumstances preventing the notice.

Employees must provide sufficient information for the Company to determine if the leave may qualify for FMLA protection and the anticipated timing and duration of the leave. Sufficient information may include that the employee is unable to perform job functions, the family memberisunabletoperformdailyactivities,theneedforhospitalizationorcontinuingtreatment

by a healthcare provider, or circumstances supporting the need for military family leave. Employees also must inform the Company if the requested leave is for a reason for which FMLA leave was previously taken or certified.

Employees are required to provide a medical certification and periodic recertification supporting the need for leave or to certify that the employee is fit to resume work. The Company also may require a second and, if necessary, a third opinion (at the Company’s expense) and, when the leave is a result of the employee’s own serious health condition, a fitness-for-duty report to returntowork. The Company alsomaydelayordeny approvalof leaveforlackofpropermedical certification.

Iftheemployeetakesleavebecauseoftheirownserioushealthconditionortocareforacovered relative, the employee must contact the Company on following the start of leave as well as one week prior to the expected end of the leave, regarding the status of the condition and their intention to return to work.

If the employee wishes to return to work before the scheduled expiration of FMLA leave or change or extend leave dates, the employee must notify the Company of the change in circumstances as soon as possible, but no later than two working days prior to thedesired return date.

Company Responsibilities

BHI will inform employees requesting leave whether they are eligible under the FMLA. If they are, the notice will specify any additional information required, as well as the employees’ rights and responsibilities. If employees are not eligible, the Company will provide a reason for the ineligibility.

BHIwillinformemployeesifleavewillbedesignatedas FMLA-protected andthe amountof leave counted against the employees’ FMLA leave entitlement. If the Company determines that the leave is not FMLA-protected, the Company will notify the employee.

Other Provisions

Under an exception to the FLSA in the FMLA regulations, hourly amounts may be deducted for unpaid leave from the salary of executive, administrative, and professional employees; outside sales representatives; certain highly skilled computer professionals; and certain highly compensated employees who are exempt from the minimum wage and overtime requirements of the FLSA,withoutaffecting the employee'sexempt status.Thisspecial exceptiontothe “salary basis” requirements for the FLSA’s exemptions extends only to eligible employees’ use of FMLA leave.

Employees may not perform work for self-employment or for any other employer during an approved leave of absence, except when the leave is for military or public service or when the Company has approved the employment under its Outside Employment policy and the employees’ reason for FMLA leave does not preclude the outside employment.

The FMLA does not affect any federal or state law prohibiting discrimination or supersede any stateorlocallaworcollectivebargainingagreementthatprovidesgreaterfamilyormedicalleave rights.

8.4 PERSONAL LEAVE

Full-time employees who have completed 30 days of service may request a personal leave of absence for necessary non-medical related leaves or leaves where FMLA would not otherwise coverthetimeoff.Personalleavesofabsenceareconsideredunpaid. Ingeneral,apersonalleave willnot beapprovedifthe employeehas availabletimeoff underany othertime awayfromwork policy (FMLA, PTO, ADA leave or military leave). Personal leaves of absence are not guaranteed and must be approved by HR with input from leadership.

Employees are eligible to request up to 4 weeks (20 business days) of personal leave of absence per 12-month period. During the period of personal leave, the employees’ job will be held. Employees returning to work immediately after leave will be reinstated to the same or an equivalent position. If the employee is unable to return to work when the leave period is exhausted, the employee will be terminated. The employee will be eligible for rehire when they are again able to work.

8.5 MILITARY LEAVE

BHI Senior Living supports the military obligations of all employees and grants leaves for uniformed service which includes the Army, Navy, Marine Corps, Air Force, Coast Guard, Army National Guard,Air National Guard,andPublic HealthServicecommissioned corps,aswell asthe reserve components of these services. Employees taking part in a variety of military duties are eligible for a leave of absence under federal and/or state law. Such military duties include leaves of absence taken by members of the uniformed services for training, periods of active military service, and funeral honors duty, as well as time spent being examined to determine fitness to perform such service.

Any employee who needs time off for uniformed service should immediately notify the HR department and the employee’s supervisor, who will provide details regarding the leave. If an employee is unable to provide notice before leaving for uniformed service, a family member should notify the supervisor as soon as possible.

Employees who have short-term (no longer than 2 weeks) military reserve obligations, will be paid the difference between their military pay and their regular rate of pay.

Upon return from military leave, employees will retain certain rights with respect to reinstatement, seniority, layoffs, compensation, length of service promotions, and length of service pay increases, as required by applicable federal or state law. Failure to report for work within the prescribed time after completion of military service will be considered a voluntary termination.

8.6 BEREAVEMENT

Allregularemployeeswill begranted3daysofpaidbereavement leavetoprovidetimeto grieve, make necessary arrangements and, if needed, travel when the death of a close family member* (spouse, registered domestic partner, children, parents, in-laws, siblings, grandparents, grandchildren) occurs.Additionaldays offwillrequireuseofPTOor unpaidtimeoffasnecessary. Employees should notify their supervisor of the need to take bereavement leave, and documented substantiation may be required (obituary, program, letter from the funeral home). Any exceptions to this policy must be made by HR and the employee’s supervisor.

*Includes step relationships

8.7 JURY DUTY

BHI Senior Living believes that employees have a civic responsibility to serve on Jury Duty, if summoned to do so. BHI provides full-time employees with up to 30 days of compensation (less any amount paid to you by the court system) within a one-year period. You can submit a copy of yoursummonsandanytimesheetsand/orcertificatesofcompletionissuedbytheClerkofCourts to HR.

The employee is expected to report for work when doing so does not conflict with court obligations. It is the employee's responsibility to keep Company management informed in advance of any jury duty time.

8.8 TIME OFF FOR VOTING

BHI believes that it is the responsibility and duty of employees to exercise the privilege of voting in elections. All employees should be able to vote either before or after regularly assigned work hours or utilize early voting or mail-in voting options that may be available in their location. However, if this is not possible due to work schedules, BHI will grant employees a reasonable period off for voting not to exceed four hours and will pay in accordance with state law requirements in each location.

If the state does not require employees to be compensated for time off for voting, nonexempt associates may elect to utilize PTO. Employees must obtain advance approval from direct supervisor and take the time off for voting either at the beginning or end of the work shift. BHI reserves the right to request proof of voting.

9. TOTAL REWARDS

9.1 GENERAL BENEFITS INFORMATION

BHISenior Living strivesto provideaTotal Rewards programthatdemonstratesour commitment to our employees, their growth and well-being, by offering a variety of options that enhance the

lives of our employees. We are committed to providing a total rewards program (compensation and benefits) that supports the employee and the organization’s values and goals while meeting operationalandfinancialneeds. Theinformation in thishandbook provides anoverviewofmany of BHI’s benefits, programs, and incentives. Employees can find the most detailed, accurate and timely information on the carrier portals and in the plan documents and/or summary plan descriptions (SPD) for each benefit plan. If ever there is a discrepancy in the information provided, the plan document and/or SPD will supersede any/all other information. BHI encourages employee feedback and recommendations and may conduct surveys, interviews and/or focus groups to gain insights into what current and prospective employees desire from a Total Rewards program.

BHI offers a competitive and comprehensive benefit package to Full-time Employees and offers several benefit options to Part-Time Employees. Our goal is to offer a variety of options that meet the diverse needs of our employees and their families, at every stage in life. BHI may pay the full cost, or share in the cost, of this coverage. Some plans are paid exclusively by the employee but are offered at BHI’s group discounted rates. BHI makes it simple to maintain your coverage by deducting your portion of any insurance premiums directly from your paycheck, twice a month.

9.2 COMPENSATION PHILOSOPHY

At BHI Senior Living, we strive to keep our compensation program consistent with our values of financial stewardship and compassion to further our mission of enhancing the quality of life of the older adults and everyone we serve. The goal of our pay program is to attract, retain and reward the talented employees who help us accomplish our goals. We support our employees through competitive base pay and other cash incentives, such as attendance bonuses, shift and weekend differentials, gift cards, etc.

We payfor performance. As part of our culture, we rewardemployees who are makinga positive impact in their positions. Employee pay will vary in relation to experience, certification and /or educational level and performance.

We strive to provide market competitive compensation based on the responsibilities and qualifications required by each job. To support this, BHI has created pay ranges, based on an established, market-based benchmarking process. Jobs are benchmarked based on duties compared to other similar jobs within the same industry or geographic location (which reflects the market in which BHI is competing for talent). Benchmarking is reviewed regularly.

It is the policy of BHI to make compensation related decisions without regard to race, color, creed, religion, sex (including pregnancy and gender identity), national origin, marital status, genetic information, status with regard to public assistance, disability, sexual orientation, or age, and to make employment decisions in a manner which will further the principles of equal employment opportunity.

9.3 PLANNING FOR RETIREMENT

BHI’s 401(k) plan is a great way to start or continue saving for the future. Employees can begin contributing at the first of the month after 30 days of employment. BHI offers matching of up to 5% of an employees salary, and you will be 100% vested in the plan immediately. Employees can enroll in a traditional 401(k) to make pre-tax contributions to reduce taxable income for the year or a Roth 401(k) to make after-tax contributions and not to pay taxes when funds are withdrawn upon retirement.

9.4 EMPLOYEE ASSISTANCE PROGRAM

BHI provides access to an Employee Assistance Program (EAP) for all employees regardless of job classification/status at no cost to the employee. Through the EAP, employees have access to resources including professional counseling, legal and financial consultation, referrals for providers (ex. childcare) and many other services.

Participation in any EAP service is voluntary and confidential. Information on accessing the EAP can be obtained through HR.

9.5 CONTINUOUS SERVICE AWARDS

BHI celebrates employees for their milestone work anniversaries every 5 years. Each community will hold an annual recognition celebration to commemorate these anniversary achievements.

9.6 WORKERS’ COMPENSATION

Employees are provided Workers’ Compensation insurance for on-the-job injuries or job-related illnesses and compensation for lost time at no cost. Employees are required to report any workrelated injuryor illness immediatelyto Human Resources. Workers’compensation generallymay provide disability income and benefits for necessary medical care.

Workers’ compensation does not cover injuries or illnesses that occur outside the course and scope of employment or during voluntary participation in any off-duty recreational, social, or charitable activity sponsored by BHI Senior Living.

10.WORK ENVIRONMENT

10.1

ZERO TOLERANCE WORKPLACE VIOLENCE

BHI Senior Living is committed to providing a safe, violence-free workplace for our employees. Due to this commitment, we discourage employees from engaging in any physical confrontation

with a violent or potentially violent individual or from behaving in a threatening or violent manner. Threats, threatening language, or any other acts of aggression, intimidation or violence made toward or by any employee will not be tolerated. A threat may include any verbal or physical harassmentor abuse; attempts to intimidateothers; menacing gestures; stalking;or any other hostile, aggressive, and/or destructive actions taken for the purposes of intimidation. This policy covers any violent or potentially violent behavior that occurs in the workplace or at Company-sponsored functions.

All BHI employees bear the responsibility of keeping our workenvironment free from violence or potential violence. Any employee who witnesses or is the recipient of violent behavior should promptly inform their supervisor, manager, or HR department. All threats will be promptly investigated. No employee will be subject to retaliation, intimidation, or discipline as a result of reporting a threat in good faith under this guideline.

BHImaintainsazerotoleranceforworkplaceviolence.Anyindividualengaginginviolenceagainst the Company, its employees, or its property will be prosecuted to the full extent of the law. All acts will be investigated, and the appropriate action will be taken. Any such act or threatening behavior may result in disciplinary action up to and including termination.

BHI prohibits the use of firearms during and in the course of an employee's duties and on behalf of BHIwhileonthe premisesofBHI,includingourparkinglotsor Companyvehicles.An employee is only permitted topossess a firearm or ammunition that is locked inthetrunk, kept in the glove compartment, or stored out of plain sight in the employee's locked vehicle. Additionally, while on duty, employees may not carry a weapon of any type unless authorized by Company as part of their duties of employment.

The Company reserves the right to inspect all belongings of employees on its premises, including packages, briefcases, purses and handbags, gym bags, and personal vehicles on Company property. Inaddition, BHI may inspectthe contents oflockers, storageareas, filecabinets,desks, and workstations at any time and may remove all Company property and other items that are in violation of Company rules and policies. Employees should have no expectation of privacy while on the Company premises.

10.2 VACCINE POLICY

It is the duty of all BHI Senior Living employees to help safeguard thehealth of fellow employees, ourresidents,theirfamilies,andthecommunityatlarge.Forthisreason,BHIstronglyencourages all employees to receive vaccinations as recommended by the Centers for Disease Control and Prevention (CDC), including but not limited to influenza vaccinations and vaccinations for COVID19. Free influenza and COVID-19 vaccine can be obtained through a BHI clinic.

Government and public health guidelines and restrictions and business and industry best practices regarding vaccines change as new information becomes available, further research is conducted, and additional vaccines are approved and distributed. BHI reserves the right to

modify this policy at any time in its sole discretion to adapt to changing circumstances, legal requirements, and business needs, consistent with its commitment to maintaining a safe and healthy workplace. Notwithstanding anything to the contrary herein, BHI reserves the right to mandate that employees receive vaccines in accordance with applicable legal requirements and/or guidance from relevant authorities such as the CDC, the Centers for Medicare and Medicaid Services, and the departments of health of any state in which BHI or its affiliates operate.

10.3 SAFETY AND UNIVERSAL PRECAUTION

All BHI Senior Living employees will be trained on the community’s Emergency Preparedness Plan. The community’s Infection Control Manual, which includes the Exposure Control Plan and Universal Precautions is available in each department and defines categories of employees who are exposed to communicable diseases. It is the responsibility of each employee to maintain awareness and compliance of their community’s Exposure Control Plan and Universal Precautions.

All employees must have appropriate health screens completed prior to resident contact. No person with an illness or disease which may be transmitted in the performance of a person’s job responsibilities will be permitted to work until the condition is resolved. Employees with signs and symptoms of communicable disease will be referred to the Medical Director or another medical professional for evaluation.

10.4 EMPLOYEE SAFETY AND SECURITY

Safety is a top priority for BHI and its communities. Our goal is to be a safe, secure and healthy environment for employees, residents, clients and visitors. A successful safety program depends on everyone being alert and committed to safety.

Employees and supervisors will participate in periodic drills and safety training including:

 Fire Safety

 Bomb Threat

 Tornado Watch/Warning

 Terrorist Threats/Attack

 Power/Telephone Outage

 Water Advisory/ Outage

 Chemical Safety/ Hazard Communication

 Active Shooter

Employees are expected to be aware of, and obey, all safety rules at work. Employees are expected to immediately report any unsafe conditions to a supervisor or administration. If an employee violates BHI's safety and security standards, they may be subject to corrective action up to and including termination. Violations include, but are not limited to, causing a hazardous or dangerous situation, not reporting a hazardous or dangerous situation and not correcting a problem that an employee could have reasonably corrected.

Should an employee witness an incident or accident involving a resident, visitor or other employee or should they see anythingwhich is inconsistent with proper procedure, they have an obligation to report this immediately. Employees must also notify a supervisor and HR immediately regarding any incident that causes injury or illness, no matter how minor it may seem atthetime. Further,allemployeeswhodrivewhileconductingbusinessforBHIareexpected to report accidents immediately. See section 9.6 Workers Compensation for more details on handling workplace injury or illness.

10.5 CELL PHONE USE AND SAFETY

While at work, employees are expected to use discretion in using personal mobile phones and other handheld electronic devices. Excessive use of these handheld devices during the workday can interfere with employee productivity and be distracting to others. Employees should use good judgment when making or receiving personal calls or texts while at work, limiting nonbusiness communications to breaks and lunch periods unless there are urgent or extraordinary circumstances.

Employees should not use mobile devices for personal calls or texts in resident rooms or in areas where residents are present while the employee is on the clock. Employees who, through use of their personal vehicle or a Company-provided vehicle, drive for business purposes are reminded to follow all applicable state and local laws regarding mobile device use and driving. Safe driving is the first priority. Never allow a cell phone or other mobile device to distract you from concentrating on driving.

10.6 BUSINESS-RELATED EXPENSES

It is the policy of BHI to reimburse employees for reasonable and necessary expenses incurred for an approved business purpose or travel. Requests for reimbursement must be submitted using the community’s expense reporting process and generally should be submitted on a monthly basis.

Certain positions may require the routine use of the employee’s personal mobile device to conduct business on behalf of BHI. The employee’s supervisor should submit a Mobile Phone Stipend Request to gain approval.

10.7 PARKING

BHIprovidesfree parking for all employees. Employees mustparkinareasspecificallydesignated for them and must display a sticker or hangtag as required by each community. Parking in visitor, handicapped or other restricted spaces is strictly prohibited. Employees with DMV-issued handicap placards or plates should notify administration of the need to park in a handicap location. Speeding or any other disturbing/unsafe conduct or consistent violation of the parking restrictions will be subject to corrective action.

10.8 LOST, STOLEN OR DAMAGED ARTICLES

BHI is not responsible for lost or stolen items or damage to the employee’s property. It is suggested thatyoudonot bringany items of personal value into thecommunity. Ifit isnecessary to have personal belongings with you, it is your responsibility to see that they are stored in a secure place. Employees are encouraged to lock their vehicles.

10.9 USE OF COMPANY TECHNOLOGY, NETWORK, INTERNET, AND EMAIL

Employees of BHI Senior Living are provided Company equipment and access to systems as appropriate based on the job role. It is imperative to ensure that all property maintained by BHI is kept in the best possible working condition and properly utilized.

In the event that an employee’s computer equipment does not function properly, is damaged, and/or is stolen, the employee shall report the issue immediately to Corporate IT. Employees should not use personal computer equipment to access BHI networks.

BHI reserves the right to monitor, at any time, any communications that use BHI networks in any way, including data, voicemail, email, telephone logs, Internet use and network traffic. No employeemay knowinglydisableany networksoftwareorsystemidentified asamonitoringtool. Employees are expected to safeguard confidential information including through phishing attempts. All employees of BHI are required to participate in routine training to ward against phishing. Failure to comply with the training requirements or putting BHI at risk through continued response to phishing attempts will lead to corrective action up to and including termination.

Employees should regularly review and familiarize themselves with the detailed IT Asset Protection and Phishing Awareness and Training policies for complete information.

10.10 REMOTE WORK

Objective

Remote work allows employees to work at home, on the road or in a satellite location during working hours. BHI considers remote work to be a viable, flexible work option when both the employee and the job are suited to such an arrangement. Remote work may be appropriate for some employees and jobs but not for others. Remote work is not an entitlement, it is not a Companywide benefit, and it in no way changes the terms and conditions of employment with BHI.

Remote work is not designed to be a replacement for appropriate childcare. Although an individual employee’s schedule may be modified to accommodate childcare needs, the focus of the arrangement must remain on job performance and meeting business demands.

Procedure

On occasion, designated Regular Employees can work remotely for specific periods of time to accomplish specific work-related tasks. Remote work must be approved in advance by the employee’s supervisor.

An hourly employee shall present to their immediate supervisor a record of hours worked at home for payroll and time tracking purposes. It is noted that the employee and their supervisor shall be responsible for adherence to the Company’s overtime policy. Failure to comply with this requirement may result in the immediate termination of the remote work agreement.

Equipment

On a case-by-case basis, BHI will determine, with information supplied by the employee and the supervisor, the appropriate equipment needs (including hardware, software, modems, phone and data lines and other office equipment) for each remote work arrangement. Equipment supplied by the organization will be maintained by the organization. Equipment supplied by the employee, if deemed appropriate by the organization, will be maintained by the employee. BHI accepts no responsibility for damage or repairs toemployee-owned equipment.BHIreserves the right to make determinations as to appropriate equipment subject to change at any time. Equipment supplied by the organization is to be used for business purposes only. The employee must sign an inventory of all BHI property received and agree to take appropriate action to protectthe itemsfromdamageortheft.Uponterminationofemployment,allCompanyproperty will be returned to the Company, unless other arrangements have been made.

The employee shall establish an appropriate work environment within his or her home for work purposes.BHIwillnotberesponsiblefor costsassociated withthe setup of the employee’s home office, such as remodeling, furniture, or lighting, nor for repairs or modifications to the home office space.

Security

Consistent with the organization’s expectations of information security for employees working at the office, remote work employees will be expected to ensure the protection of proprietary Company and customer information accessible from their home office. Steps include the use of locked file cabinets and desks, regular password maintenance, and any other measures appropriate for the job and the environment.

Ad Hoc Arrangements

Temporary remote work arrangements may be approved for circumstances such as inclement weather, special projects, or businesstravel. These arrangements are approved on an as-needed basis only, with no expectation of ongoing continuance. All temporary remote work arrangements are made on a case-by-case basis, focusing first on the business needs of the organization.

Other temporary arrangements may be made for employees on family or medical leave to the extent practical for the employee and the organization and with the consent of the employee’s health care provider, if appropriate.

10.11 ANNUAL PERFORMANCE EVALUATION

BHI Senior Living encourages conversations between supervisors and employees that are open, honest, and meaningful. Discussions regarding job performance are ongoing and often informal. Employees should initiate conversations with their supervisors if they feel additional ongoing feedback is needed.

Additionally, formal performance reviews are conducted annually. Annual performance evaluations provide a written performance appraisal and a valuable opportunity for employees to receivefeedbackand engagein dialoguewiththeirsupervisorregardingtheirperformancefor the year and expectations for the coming year.

Employees are rated on factors such as: attendance, communication, job performance, goal attainment, and teamwork.

BHI has a five-point rating scale:

 Level 1: Consistently Below Expectations

 Level 2: Occasionally Below Expectations

 Level 3: Consistently Meets Expectations

 Level 4: Frequently Exceeds Expectations

 Level 5: Consistently Exceeds Expectations

Employees with a Below Expectations rating may not apply for open positions and may not be eligible for bonus payout or merit increases.

11.STANDARDS

All employees are expected to arrive on time, ready to work, every day they are scheduled to work. If unable to arrive at work on time, or if an employee will be absent for an entire day, the employee must contact the supervisor as soon as possible. Employees should follow departmental procedure for notification.

In all cases of absenceortardiness,employees must provide managementwith an honestreason orexplanation. Documentationofthereason mayberequired. Employeesmaybecompensated for authorized absences according to Company policies described in this employee handbook.

Excessive absenteeism or tardiness will result in discipline up to and including termination. Failure to show up or call in for a scheduled shift without prior approval also may result in discipline up to and including termination. If an employee fails to report to work or call in to inform the supervisor of the absence for 3 consecutive days or more, the employee will be considered to have voluntarily resigned from employment.

11.2 DRESS AND GROOMING

Your professional appearance inspires the confidence of our residents, visitors, and your coworkers. This policy was developed to create a comfortable yet professional work environment. Each employee is responsible to “dress for their day” in accordance with BHI’s dress code guidelines and should maintain a positive, professional image always. This includes choosing attire that fits their workenvironment, location and schedule and considers the meeting settings of their day. All employees are expected to dress in a manner consistent with good hygiene, safety, and good taste. Employees should be well groomed and avoid clothing, fragrance or grooming choices that distract or interfere in any way with the ability for employees or others to accomplish work.

Certain employees may be required to meet special dress and grooming, such as wearing uniforms or safety equipment/clothing, depending on the nature of their job. It is the responsibility of the employee to check with the department manager on the dress code of that department. Undesirable dress or poor appearance may result in written disciplinary warning, suspension, or termination.

When hosting or attending meetings with residents, vendors, employees from other companies or board members, employees should wear appropriate clothing for the meetingor event, which may include “business professional” attire. Examples of business professional attire include suits and dresses. If uncertain, the employee should check with their supervisor or the meeting host.

Inappropriate attire includes but is not limited to:

 Any clothing with offensive or derogatory graffiti, pictures, signs, or statements

 Shorts, sweat/running/yoga pants, or exercise leggings

 Tank tops, halter tops, workout tops, or mid-riff revealing tops

 Athletic baseball caps/hats

 Tight-fitting clothing that is revealing and inappropriate for the workplace

 Jeans, pants, or shirts that have holes, tears, or rips of any type

 Beach sandals, casual, or athletic-style flip-flops or slides

 Clothing that might create a safety hazard in certain work areas (i.e. hanging or loose clothes, jewelry, etc.)

11.3 DRUG-FREE, SMOKE-FREE AND ALCOHOL-FREE WORKPLACE

BHI has always maintained a strong commitment to providing a safe environment for its’ residents and employees. As part of that commitment, the Company maintains a drug-free, smoke-free and alcohol-free work environment by establishing programs that promote a high standard of employee health.

Substance Abuse and Testing

It is against Company policy to consume, possess, distribute or transport any controlled substance, illegal drug, drug paraphernalia or alcoholic beverages on the Company’s premises, report to work under the influence of any drug (including marijuana and alcohol), or operate a Company vehicle while impaired or under the influence of any illegal substance or alcohol. Prescription and over-the-counter drugs are not prohibited when taken in standard dosages and/or according to a physician's prescription; however, employees are responsible for consulting theirphysician and/orpharmacist tomake sure a prescribed or over-the-counterdrug will not interfere with safe job performance. This policy is implemented in compliance with the Drug Free Work Act of 1988.

All community employees are subject to a drug screen at the time of initial hiring. Any employee who is reasonably suspected of violating this policy will be subject to testing and could face corrective action up to and including termination, even for the employee’s first offense. Reasonablesuspicionmeansabeliefbasedonobserved,specific,andobjectivefactsthatindicate a person is under the influence of drugs and/or alcohol. Examples include:

 Direct observation of abnormal conduct

 Incoherent mental state

 Erratic behavior that is otherwise unexplained

 Workplace incident resulting in actual or potential harm, or injury to others

 Third-party information that is reliable and credible

Rehabilitation is the employee’s responsibility. If you believe that you need professional assistance in overcoming a problem with drugs and/or alcohol, referrals to local counseling and rehabilitation programs can be obtained from the HR department. Employees are also encouraged to participate in the Employee Assistance Program (EAP).

Compliance with this policy is a condition of employment. Employees who test positive, refuse to submit to substance abuse screening, or violate this policy in any way are subject to discipline, up to and including termination. Notwithstanding any provision herein, this policy will be enforced at all times in accordance with applicable state and local law.

Smoke-Free Workplace

Smoking is not allowed in Company buildings or work areas at any time. “Smoking” includes the use of any tobacco products (including chewing tobacco), electronic smoking devices, and ecigarettes.

Smoking is only permitted during break times in designated outdoor areas. Employees using these areas are expected to dispose of any smoking debris safely and properly.

11.4 SOCIAL MEDIA ACCEPTABLE USE

BHISeniorLivingviewssocialmediapositivelyandencouragesitsappropriateuse.“Socialmedia” refers to blogs, forums, and social networking sites, such as Twitter, Facebook, LinkedIn, YouTube, Instagram, TikTok and Snapchat, among others. However, BHI recognizes that employees’ online activities can result in negative consequences, including decreased productivity and distraction from job requirements. Employees must not use social media during working time or with equipment provided by BHI unless it is authorized by the employee’s supervisor.

BHI respects employee privacy, and this policy does not apply to personal use of social media which is unconnected to our business. However, BHI reserves the right to respond to any employee conduct which adversely impacts the organization, its reputation, or its business interests. When referencing BHI or identifying yourself as a BHI employee, always make it clear that your opinions are yours alone and that you are not speaking for or as the Company.

Confidential Information, Trademarks and Copyrights

Employees are expected to protect the intellectual property and privacy rights of BHI, its employees, residents, clients, customers, vendors and any other third parties that have shared confidential and proprietary information with BHI. Employees are not to disclose or divulge BHI confidential information such as trade secrets, client or resident information, or information restricted from disclosure by law on social media sites.

New ideas related to work or the Company’s business belong to the Company. Do not post them on a social media site without the Company’s permission. Do not use the Company’s or others’ trademarks on a social media site or reproduce the Company’s or others’ material without first obtaining permission.

Respect

Employees are discouraged from using social media to post or display comments about coworkers, leaders, and residents that are false, malicious, vulgar, obscene, physically threatening or intimidating, harassing, targets individuals because of their protected class or otherwise would constitute a violation of Company workplace policies and procedures. Employees should also refrain from posting, displaying, or responding to content that is an intentional public attack on the quality of BHI’s communities or services.

Employees should not use social media to criticize the Company’s competition and should not use it to compete with the Company.

Privacy

Employees utilizing BHI’s internet, email, and other facilities acknowledge that they have no reasonable expectation of privacy when using the internet. This includes social networking sites during working time, when using Company equipment or when on company internet or intranet. If BHI receives notice that an employee has posted content that violates the social media policy oranyotherpolicy,BHI reservestherighttoinvestigate.Iftheinvestigationconfirmsthatapolicy was violated. BHI may demand that the employee remove the posting and the employee may be subject to corrective action up to termination.

Legal

Employees are expected to comply with all applicable laws, including, but not limited to, Federal Trade Commission (FTC) guidelines and copyright, trademark, and harassment laws. Nothing in this policy is meant to, nor should it be interpreted to, in any way limit your rights under any applicable federal, state, or local laws, including your rights under the NLRA to engage in protected concerted activities with other employees to improve or discuss terms and conditions of employment, such as wages, working conditions, and benefits. Employees have the right to engage in or refrain from such activities.

11.5 CORRECTIVE ACTION

BHI Senior Living expects employees to comply with the Company’s standards of behavior, professional conduct and performance and to correct any noncompliance with these standards. BHI expects that the personal and professional conduct of its employees will conform to acceptable standards and those detailed in the Code of Conduct and all other policies.

BHI Senior Living endorses a policy of progressive discipline in which it attempts to provide employees with notice of deficiencies and an opportunity to improve. It does, however, retain the discretion to administer discipline in any manner it sees fit. The Company reserves the right to bypass the disciplinary procedures suggested where appropriate based on the circumstances.

The following recommended steps are in place for the discipline procedure. All steps should be documented in the employee’s personnel file.

1. Coaching Discussion - When a performance problem is first identified, the nature of the problem and the action necessary to correct it should be thoroughly discussed with the employee.

2. Initial Counseling - The supervisor will discuss the matter with the employee, anda plan of action to correct the problem will be outlined. The employee will be asked to sign a copy of the Initial Counseling to acknowledge the disciplinary action.

3.WrittenWarning-TheSupervisorwillmeetwiththeemployeeto a)reviewtheproblem, b) permit the employee to present information regarding the problem, c) advise the

employee that the problem must be corrected, d) inform the employee that failure to correct the problemwillresult in further disciplinaryaction thatmay include termination, and e) issue a written warning to the employee.Theemployeewillbeaskedtosigna copyoftheWrittenWarningtoacknowledgethedisciplinaryaction.

4. FinalWrittenWarning-Ifthepoorperformanceormisconductpersistsafterthe WrittenWarning, or the incident is deemed severe enough to warrant such action, the employee may be issued a Final Written Warning. The employee will be advised of the offense(s) and warned that any additional work ruleviolations,performanceproblems ormisconductwilllikelyresultintermination.Theemployeeisencouragedtoprovide anhonestexplanationfortheirperformanceand/ormisconduct.Theemployeewill beaskedtosignacopyoftheFinalWrittenWarningtoacknowledgethedisciplinary action.

5. SuspensionWithoutPay-Anemployeemaybesuspendedwith,orwithout,pay pendingtheoutcomeofaninvestigation.Suspensionwith,orwithoutpay,mustbe approvedbyHR.

6. Termination– After an employee is suspended without pay, an investigation of the incidents leading up to the suspension should be conducted to determine if any further action, such as termination, should be taken. Anemployeemaybeterminatedatany time,withorwithoutcause,warning,ornotice,foraviolationofpolicy,misconductor forpoorjobperformance,orforanyotherreasonnotcontrarytothelaw.

The progressive disciplinary procedures described above also may be applied to an employee who is experiencing a series of unrelated problems involving job performance or behavior. In cases involving serious misconduct, or any time the supervisor determines it is necessary, such as a major breach of policy or violation of law, the procedures contained above may be disregarded and an employee may immediately be terminated.

Nothing affects the employee's at-will status under which the employee or BHI is free to terminate therelationshipatanytimeandforanyreasonornoreason,withorwithoutcause ornotice.Further,anemployeemaybeterminatedbyBHIatanytime,withorwithoutcause, warning,ornotice,foraviolationofpolicy,misconductorforpoorjobperformance,orforany otherreasonnotcontrarytothelaw.

11.6 WORK RULES

Commission of the following offenses or any other improper employee actions may result in disciplinary action up to and including termination, depending upon the seriousness of the offense. This list of unacceptable employee conduct does not include all examples of improper conduct but is provided as guidance. Employees with questions concerning the propriety of any contemplated action should consult with their supervisor or HR before engaging in the activity.

Note that nothing in this Employee Handbook is intended to prevent or interfere with an employee's right to discuss the terms and conditions of their employment with other employees

or employee representatives or to otherwise engage in protected, concerted activity that is protected by the National Labor Relations Act.

Examples of prohibited conduct:

1. Failure to follow the policies and procedures of BHI and its affiliates. Failure to abide by the employee handbook.

2. Violation or failure to report a violation of the Resident’s Rights Policy, Resident Abuse Policy, Professional Ethics Statement, Corporate Compliance Policy, HIPAA Privacy Policy, Confidentiality Policy,Anti-Harassment Policy, Zero Tolerance Workplace ViolencePolicy, Timekeeping Policy, and other policies and procedures established by the Company.

3. Any behavior that endangers the life or safety of residents, staff, and/or visitors.

4. Failure to follow care guides. Failure to adhere to instructed procedures on lifting, transferring, or moving a resident.

5. Failure to followthestandards of practice for professional licensure or certification.

6. Failure to comply with all health and safety standards, including infection control, and/or committing unsafe conduct or acts that result in minor injury to self or others and/or minor property damage.

7. Failure to perform job requirements to the satisfaction of the community.

8. Disclosing anything of a personal or confidential nature concerning residents, the community, or its policies at any time, either inside or outside the community, to unauthorized persons unless the specific work duties require the giving or exchanging of such information.

9. Performing personal work while on duty without the expressed permission of the executive director.

10. Actingasexecutorforresidentsorclients

11. Residing withclients to whomservices arebeingprovided.

12. Failure to return to workafter a vacationor a leave of absence, including a personal leave of absence, unless otherwise required by law.

13. Malicious or intentional damage to community, resident, visitor, or another employee’s property, including tools, equipment, furniture, vehicles, etc.

14. Rudeness or discourtesy to residents, staff, or visitors.

15. Disorderly, offensive, immoral, or indecent conduct on the premises of the community.

16. Useof profane or abusive language whileon duty.

17. Circulating or spreading rumors or false information that have an adverse impact on working conditions or on the residents of the community.

18. Violation of safety procedures, rules, or guidelines and/or failure to exercise good

judgment regarding the safety and welfare of residents, staff, and/or visitors.

19. Unauthorized possession of a firearm (unless unloaded and locked in an employee's vehicle where it cannot be seen) or other weapon on community property.

20. Sleeping while on duty.

21. Smoking, eating, or drinking in unauthorized areas or at unauthorized times.

22. Stealing or unauthorized use of community, resident, staff, or visitor property or failure to promptly cooperate with the investigation of theft.

23. Falsifying any Company record including, but not limited to, employment applications, time records, expense reports, state/federal government reports (including Medicare information) or accreditation reports.

24. Providing incorrect or misleading information, or omitting relevant information, in response to inquiries from state or federal agencies or accreditation commissions.

25. Leaving the work area without permission of supervisor.

26. Insubordination of supervisory personnel which may include refusal to perform work as assigned or in a correct, efficient, conscientious manner.

27. Undermining the authority of department managers or other supervisory personnel and/or agitating known conflicts.

28. Use, possession, sale, manufacture, distribution, purchase, or attempt to purchase drugs/medications from any persons on BHI property; the appearance of being under the influence of alcohol or drugs on BHI property; or failure to participate in the drug/alcohol testing policy as required. Possession or being under the influence of alcohol, drugs or chemicalintoxicants while on dutyor oncompanyproperty.

29. Selling, purchasing, or attempting to sell or purchase any prescription drugs or medications kept by BHI for the medical treatment of its residents, including, but not limited to, controlled substances. Unauthorized handling/use or possession of medication, narcotics, or illegal drugs.

30. Failure to notify supervisor when leaving duty station for a break or lunch period and/or taking more than the specified time for break or lunch period.

31. Failure to start work on time or immediately after break or lunch periods or leaving the unit before the end of a scheduled shift (including waiting by the timeclock 5-10 minutes before end of shift).

32. Permitting another person to use keys to enter the community without proper authorization.

33. Being in unauthorized areas or in areas that are not necessary for the employee to be in to perform the functions of his/her job without permission.

34. Having visitors while on duty without authorization.

35. Unauthorized use of community or resident telephones, cellular telephones, computers,

and/or cameras/photographic devices.

36. Accepting tips, gifts, or loans from residents, visitors, vendors, and contractors; or use of residents’ personal property without the written permission of the resident and the executive director.

37. Failure to attend or participate in a required community in-service or complete online inservice training.

38. Failure to participate in emergency preparedness training, programs, or drills.

39. Unsafedrivingbytheemployeeortheemployee'sfamilymemberorgueston community property, or by the employee while on Company business.

40. Failure to comply with the Code of Conduct or Corporate Compliance Plan.

11.7 SOLICITATION

Employees should be able to work in an environment that is free from unnecessary annoyances and interference with their work. In order to protect our employees and visitors, solicitation by employees is strictly prohibited while either the employee being solicited or the employee doing the soliciting is on working time, which is defined as time during which an employee is not at a meal, on break, or on the premises immediately before or after a shift.

Employees are alsoprohibited from distributing written materials,handbills, or any other type of literature on working time and, at all times, in working areas, which include all office areas, but do not include break rooms, parking lots, or common areas shared by employees during nonworking time.

NonemployeesmaynottrespassorsolicitordistributematerialsanywhereonCompanyproperty at any time. Canvassing,sellingto,orsolicitationof fundsfrom residents,theirfamilies orvisitors is prohibited.

11.8 USE OF COMPANY BULLETIN BOARDS

All required governmental postings are posted on Company bulletin boards. These boards may also contain general announcements.

Employees may submit to HR notices of general interest, such as for-sale notices; recreationaltype announcements and/or club functions (e-mail should not be used for the aforementioned); postcards; expressions of gratitude or sympathy; and notices looking for/offering carpools, tickets, roommates, or pets. HR approves, posts, and takes down all notices. All notices posted by employees willberemoved after 2 weeks unless otherwisestipulated. The Company reserves the right to refuse permission to post or to take down any announcement.

11.9 OUTSIDE EMPLOYMENT

Employeesgenerallyarepermittedtoworkasecond jobas longasitdoesnot interferewith their job performance or create a conflictof interest with BHISenior Living.A conflict of interest arises in a situation where, including but not limited to, Employee's outside interests (for example personal or financial interest) in a matter may reasonably be perceived to: (i) affect Employee's objectivity incarryingoutresponsibilitiesanddutiestotheCompanyorinterferewith Company’s business interests; or (ii) represent an advantage or gain to Employee or other persons besides Company or its affiliates.

Employees with a second job are expected to work their assigned schedules. A second job will not be considered an excuse for poor job performance, absenteeism, tardiness, leaving early, refusaltotravel,or refusaltoworkovertimeordifferenthours. In addition,employeeswhohave accepted outside employment may not use paid sick time to work on the outside job. However, an employee on a leave of absence may continue to work in the outside job if this employment has been approved by the Company under this policy and the employee’s reason for leave does not preclude the outside employment.

If outside work activity causes or contributes to job-related problems, it must be discontinued, or the employee may be subject to disciplinary action up to and including termination.

12. INVESTIGATIONS AND INQUIRIES

In order to accomplish efficient, coordinated handling of all investigations or inquiries directed to the organization whether involving a community, our resources, employees, or other parties, the following procedure shall be observed:

1. The Executive Director should be notified immediately about visits from representatives from any city, county, state, or federal government agency. Employees should examine the representative’s credentials and explain that our present policy precludes discussion of any matters without first going through the designated community’s representative.

2. Any written communications from any city, county, state, or federal government agency are to be immediately forwarded to the Executive Director. No response should be made to such communications without prior approval of the Executive Director or the community’s designated representative.

3. All public communication in response to community and/or emergency events shall be the sole responsibility of the Executive Director and/or their designee.

4. Inquiries(excludingemployee referencechecks)whetherbytelephoneorin person,from private attorneys, insurance investigators, police officers, or other third parties, even if the inquiries do not appear to directly concern our community, shall also be referred to the Executive Director.

13.

Nothing in this handbook is intended to, meant to, nor should it be interpreted to in any way limit, prevent or interfere with an employee's rights under any applicable federal, state, or local lawstodiscussthetermsandconditionsoftheiremployment,suchaswages,workingconditions, and benefits, with other employees or employee representatives or to otherwise engage in protected, concerted activity that is protected by the National Labor Relations Act.

RESIDENTRIGHTS

BHI hasadoptedaformalResidentRightsPolicy Uponemploymenteachemployeeshallbeinstructed onthecontentofthispolicyandshallberequiredtoacknowledge,inwriting,receiptandunderstanding ofthesame Violationofthispolicymayresultindisciplinaryactionuptoandincludingtermination

● Betreatedwith consideration,respect, anddignity

● Recognizeeachresident’s individuality

● ChoiceofActivity, Schedule

● Healthcareprovider &TreatmentPlan

● Rulesand Regulations

● Typeofcare:Risks &Benefits

● Room/Roommate changes

● Withoutfearof retaliationor discrimination

● ChooseandRefuse visitors

● Personal&Medical Records

● Activities&Servicesin andoutofthecampus

● Managingtheirown FinancialAffairs

● Informationavailable forfinancialservices &thecost

● Regardingpersonal, financial,&medical affairs

● Private communication

Discharge/Transfer

● RighttoAppeal

● Righttowritten notice