Employee Handbook 2025_July2025

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Welcome to Newport Healthcare!

This is our Employee Handbook, a resource that will prove useful whether you are a new employee or a seasoned member of the Newport team. Within these pages you will find information about our history, mission, vision, and values as well as important policies, disclosures, and processes.

If you are just joining our team, we are delighted that you have chosen this meaningful work and our great company, and we look forward to your ideas and contributions. If you are an existing employee, we appreciate all that you do to positively impact the lives of our clients/patients and families. Each employee plays a unique part in the client/patient experience, and we value the time and energy it takes to provide direct care and support services.

Newport Healthcare is comprised of Newport Academy, Newport Institute, Center for Families and PrairieCare. Together, we strive to be better, do better and succeed further than other treatment programs. We emphasize evidence-based, patient-centered care and promote family involvement in the treatment process to repair ruptured relationships and provide a lasting foundation of support. Newport Healthcare is a leading provider of behavioral health treatment because we combine clinical expertise with compassionate care to empower lives and restore families.

Just as we nurture our client and family experience, we seek to provide a work environment of integrity, respect, and support. Our work helping individuals who struggle with behavioral health issues is vital and intense, but our camaraderie and collaboration are key to our success. We hope you will find your experience here fulfilling, rewarding, and inspiring. And in the spirit of continuous learning and improvement, we welcome your feedback at any time.

Thank you for being a part of the Newport Healthcare team!

INTRODUCTORY STATEMENT TO HANDBOOK

As an employee of Newport, you will want to know what you can expect from Newport and what Newport expects from you. This handbook outlines the benefits, practices, and policies of our organization, which are important to you. The policies described in this handbook are meant to replace all previous personnel policies, practices, and guidelines.

You should keep this handbook handy as a guide and ready reference. You can also reference the company Policies and Procedures which can be found on the company intranet for additional information. If you have questions as you read this handbook, please do not hesitate to discuss them with your supervisor or Human Resources. Your supervisor and Human Resources are very important sources of information and will be more than happy to assist you.

Newport reserves full discretion to revise, modify, rescind, delete, or add to the provisions of this handbook, or the policies and procedures on which they may be based (other than the at-will policy), at any time without advance notice.

Nothing in this handbook will be interpreted, applied, or enforced to interfere with, restrain, or coerce employees in the exercise of their rights under Section 7 of the National Labor Relations Act.

EMPLOYMENT AT WILL

Employment at Newport is “at will.” This means that your terms and conditions of employment may be changed with or without notice, and with or without cause, including but not limited to termination, demotion, promotion, transfer, compensation, benefits, duties, work hours, and location of work. Specifically, either you or Newport may terminate your employment at any time, with or without notice, and with or without cause. Nothing in this handbook or in any other document or statement shall limit Newport’s right to change the terms and conditions of employment at any time, with or without notice or cause. No supervisor or other employee of Newport has the authority to enter into any agreement for employment for any specified period of time or to make any agreement for employment other than “at will” employment. Any requests to alter the at-will relationship must be brought to the attention of Human Resources in writing. Only the Chief Executive Officer of Newport Healthcare has the authority to make an agreement altering an employee’s at-will status. Such an agreement must be in writing and signed by the Chief Executive Officer of Newport and expressly state that it is intended to alter the atwill employment relationship.

EQUAL OPPORTUNITY EMPLOYMENT

Newport is an equal opportunity employer. Newport provides equal employment opportunity for all employees and prohibits discrimination based on race, color, sex (including pregnancy, childbirth, breastfeeding and medical conditions related to pregnancy), gender, religious creed (including religious dress and grooming practices), marital status, domestic partner status, age, national origin or ancestry, physical or mental disability, medical condition, genetic information and characteristics, sexual orientation, gender identity or expression, military or veteran status, or any other basis protected under federal, state, or local laws. This policy pertains to all of Newport’s employment practices, including hiring, recruitment, promotion, training, and compensation. Newport also prohibits discrimination based on the perception that anyone has any of the characteristics listed above or is associated with a person who has or is perceived as having any of the characteristics. Violation of this policy will result in discipline, up to and including termination.

E-VERIFY

Newport Healthcare participates in E-Verify and will provide the federal government with your Form I9 information to confirm that you are authorized to work in the U.S.

If E-Verify cannot confirm that you are authorized to work, Newport Healthcare is required to give you written instructions and an opportunity to contact Department of Homeland Security (DHS) or Social Security Administration (SSA) so you can begin to resolve the issue before Newport Healthcare can take any action against you, including terminating your employment. Employers can only use E-Verify once you have accepted a job offer and completed the Form.

POLICY AGAINST UNLAWFUL HARASSMENT

Newport prohibits harassment on the basis of race, color, sex (including pregnancy, childbirth, breastfeeding and medical conditions related to pregnancy), gender, religious creed (including religious dress and grooming practices), marital status, domestic partner status, age, national origin or ancestry, physical or mental disability, medical condition, genetic information and characteristics, sexual orientation, gender identity or expression, military or veteran status, or any other basis protected under federal, state, or local laws. This policy applies to all persons involved in the operation of Newport and prohibits harassment by any employee of Newport, including coworkers, supervisors, managers, as well as third parties such as vendors, clients, independent contractors, suppliers, and any other persons. Violation of this policy will result in disciplinary action, up to and including termination.

Prohibited Harassment

Prohibited harassment in employment may take many different forms. Some examples are:

• Verbal conduct such as epithets, derogatory comments, slurs, unwanted comments, or jokes;

• Visual conduct such as derogatory or inappropriate posters, cartoons, drawings, websites or gestures;

• Physical conduct such as blocking normal movement, restraining, touching, or otherwise physically interfering with the work of another individual; and,

• Threatening or demanding that an individual submit to certain conduct or perform certain actions in order to keep or get a job, to avoid some other loss, or as a condition of job benefits, security, or promotion.

Sexual Harassment

Sexual harassment warrants special emphasis and will not be tolerated by Newport. Sexual harassment may take various forms. It may include behavior listed above with a sexual connotation, but also includes unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when:

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

• Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; or

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

POLICY AGAINST ABUSIVE CONDUCT

Newport defines bullying as “repeated inappropriate behavior, either direct or indirect, whether verbal, physical or otherwise, conducted by one or more persons against another or others, at the place of work and/or in the course of employment.” Newport will not tolerate bullying behavior. Employees found in violation of this policy will be subject to disciplinary action up to and including termination.

Bullying may be intentional or unintentional. However, it must be noted that where an allegation of bullying is made, the intention of the alleged bully may be irrelevant and will normally not be given consideration when determining an appropriate response, including discipline. As with harassment, it is the effect of the behavior upon the individual that is important. Newport considers the following types of behavior to be some non-exhaustive examples of bullying:

• Verbal bullying: Slandering, ridiculing, or maligning a person or his/her family; persistent name calling that is hurtful, insulting or humiliating; using a person as the butt of jokes; abusive and offensive remarks; excessive “prank” jokes or teasing of an employee.

• Physical bullying: Pushing, shoving, kicking, poking, tripping, assault or threat of physical assault; damage to a person’s work area or property.

• Gesture bullying: Nonverbal threatening gestures or glances that convey threatening messages.

• Performance bullying: Unwarranted or invalid criticism; blame without factual justification; sabotage of a co-worker’s work product or undermining of an employee’s work performance.

• Exclusion: Socially or physically excluding or disregarding a person in work-related activities; being treated differently than the rest of your work group.

• General: Any other conduct directed at an individual or individuals that a reasonable person would find hostile, offensive, threatening, intimidating, and/or humiliating and unrelated to Newport’s legitimate business interests.

Newport considers workplace bullying unacceptable and will not tolerate it under any circumstances. Managers and supervisors assume the responsibility to ensure employees are not bullied. Any employee who bullies a co-worker, contractor, client, or anyone else in the workplace or work environment will be subject to disciplinary action, up to and including termination of employment.

Newport encourages all employees to report workplace bullying to a member of management with whom you are comfortable speaking, or directly to Human Resources. All complaints of workplace bullying will be treated seriously and investigated promptly. It is a violation of company policy to retaliate or otherwise victimize anyone who makes a complaint or a witness who serves in the investigation of the

workplace bullying allegation.

Furthermore, Newport prohibits abusive conduct in the workplace. “Abusive conduct” includes workplace conduct that a reasonable person would find hostile, offensive, and unrelated to Newport’s legitimate business interests. It may also include repeated infliction of verbal abuse, such as the use of derogatory remarks, insults, and epithets, verbal or physical conduct that a reasonable person would find threatening, intimidating, or humiliating, or the gratuitous sabotage or undermining of a person’s work performance.

Notwithstanding the foregoing, this policy does not restrict or limit employees’ ability to discuss or critique their terms and conditions of employment or otherwise engage in activity protected by the National Labor Relations Act.

REASONABLE ACCOMMODATIONS/INTERACTIVE PROCESS

Newport makes reasonable accommodations, where appropriate, to enable otherwise qualified individuals with disabilities to perform the essential functions of their jobs, as long as the accommodation does not result in an undue hardship to Newport or a direct threat to health and safety.

Any employee who requires an accommodation in order to perform the essential functions of their job should contact their supervisor or designated HR representative so that Newport can engage the employee and their healthcare provider in an interactive process to determine which accommodations (if any) are reasonable and feasible. The individual with the disability should specify what job restrictions they have and what accommodation they seek in order to perform the essential functions of the job. Newport may request that the employees’ treating medical provider verify any and all work restrictions and what accommodation(s) may be needed in order to perform the essential job functions.

Newport will not inquire into any employee’s medical diagnosis and asks that the employee instruct their physician to communicate only information necessary to determine that they can perform the essential job duties and what accommodation(s) may be requested. If the accommodation is reasonable and will not impose an undue hardship or result in a direct threat, Newport will provide the accommodation.

RELIGIOUS ACCOMMODATIONS

Newport will provide reasonable accommodation for employees whose work requirements interfere with a religious belief or observance, including religious dress and grooming practices, unless doing so poses undue hardship on Newport. Employees requiring religious accommodation should notify Human Resources and submit a written request. Upon receipt of the request, Newport will engage the employee in an interactive process to determine what, if any, reasonable accommodation exists

LACTATION ACCOMMODATION

Any employee breastfeeding a child will be provided break time each time they need to express milk. Newport will provide a reasonable amount of break time to accommodate an employee’s need to express breast milk. The break time should be taken concurrently with other break periods already provided when possible. If this time does not run concurrently with normally scheduled rest periods, non-exempt employees will be provided whatever time is needed to express breast milk, but such time will be unpaid. Newport will also provide the employee with the use of a private room, other than a bathroom, or other location which is shielded from view and free from intrusion, in close proximity to the employee’s work area, for the employee to express milk in private. Employees are not required nor expected to use a restroom to express breast milk.

All employees who are lactating have a right to request lactation accommodation for as long as they are lactating. Employees should notify their immediate supervisor or Human Resources if they are requesting time to express breast milk under this policy. The request can be verbal or in writing. Newport will promptly respond to all requests for lactation accommodation. If an employee believes that their rights to appropriate lactation accommodation have been violated in any way, they are encouraged to bring the complaint to Human Resources.

Newport does, however, reserve the right to deny an employee’s request for a lactation break if the additional break time will seriously disrupt operations.

PROBLEM RESOLUTION

OPEN DOOR POLICY

Newport has an open-door policy. Employees are encouraged to promptly discuss any job-related concerns or questions with their immediate supervisor, if appropriate. Such a discussion should take place in a timely manner (ideally within three to five days of the incident while everyone’s memory is still fresh). If the parties cannot satisfactorily resolve the issue at this level, or if an employee feels they cannot approach their supervisor, then the problem should be taken to Human Resources or the program leader. Newport will attempt to maintain confidentiality to the extent possible. However, employees are not prohibited from discussing their job-related concerns or questions with others. No employee will be discriminated against for discussing or reporting, in good faith, any concerns or questions relating to any of the terms or conditions of employment.

Complaint Procedure

Employees who believe they have been subjected to conduct in violation of the policies listed in this section and/or have witnessed or are aware of violations of Newport’s EEO and anti-harassment policy, are requested and encouraged to promptly report such violations to their supervisor, management, and/or the Human Resources department. Employees are not required to complain directly to their immediate supervisor and may speak with any supervisor or the Human Resources department about their concerns. Any supervisor who receives a complaint of conduct that violates Newport’s policies detailed above must report it immediately to the Human Resources department in order to aid in internal resolution of the claim.

Newport will promptly review, thoroughly and fairly investigate complaints, and take such action as is warranted under the circumstances. While Newport cannot guarantee absolute confidentiality, Newport will keep the employee’s identity and report as confidential as reasonably possible in order for Newport to investigate the complaint. Newport may, on a case-by-case basis, restrict employees’ ability to discuss ongoing investigations.

If it is determined that evidence of a violation exists, Newport will take prompt remedial action as warranted by the circumstances. This action may include disciplinary action, up to and including immediate termination.

Newport strictly prohibits retaliation against any employee who brings a complaint of harassment or discrimination to the attention of management or who participates in any workplace investigation.

EMPLOYMENT

EMPLOYMENT ELIGIBILITY VERIFICATION COMPLIANCE

In compliance with the Immigration Reform and Control Act of 1986 (“IRCA”) and any other applicable federal, state, or local laws, Newport is committed to employing only those who are authorized to work in the U.S. and will not discriminate on the basis of national origin or citizenship in hiring, recruiting, or terminating employees.

Each new employee, as a condition of employment, must complete the Employment Eligibility Verification Form I-9 and present acceptable documentation authorized by USCIS proving identity and employment authorization no later than the 72 hours after starting employment.

EMPLOYEE CLASSIFICATIONS

Exempt Employees

Exempt employees are employees whose positions qualify as “exempt” under specific tests established by the Fair Labor Standards Act. Exempt employees are not eligible for overtime pay, regardless of the amount of time worked.

Non-Exempt Employees

Non-exempt employees are employees whose positions do not satisfy Fair Labor Standard Act exemption tests. Non- exempt employees are subject to or eligible for, among other things, overtime, record keeping requirements, meal periods, and rest breaks. Any employee with questions regarding his or her classification should contact their Human Resources Representative.

Full-Time Employees

Full-time employees (exempt and non-exempt) are those who are regularly scheduled to and who work a minimum of 30 hours per week (typical full-time schedule is 40 hours or more).

Part-Time Employees

Part-time employees are those who are regularly scheduled to work and who work less than 30 hours per week. Part-time employees who work an average of less than 30 hours per week are not eligible for employee benefits except where mandated by applicable law (i.e. workers’ compensation insurance, state disability, unemployment compensation, and social security benefits).

Per Diem Employees

Unlike part-time employees, per diem is defined as an employee that can work on an “as needed” or “on call” basis. Individuals must meet government regulations in order to qualify as a per diem employee. As a result, all proposed candidates will follow the established hiring process.

• Per Diem employees are required to be available to work a minimum of four (4) shifts a month. Newport is not obligated to provide available shifts to per diem employees as they are intended to be “as needed.”

• Weekends and/or holidays may be required based upon the staffing needs of the program.

• Employees will provide their availability for the four (4) shifts to their supervisor by the 15th of the

month for the following month.

• Failure to be available for the minimum shifts or not work any shifts within a 2-month time-period may result in termination.

• All per diem employees will be responsible for recording their work hours in Workforce Management.

• Per Diem employees are not eligible for company benefits, including but not limited to medical and dental benefits, and time off benefits excluding sick time where applicable as required by state law

• Per Diem employees must maintain all required competencies and must keep all trainings/assignments and employee TB Skin test up to date.

• Per Diem employees are subject to all policies and procedures of Newport including but not limited to attendance, tardiness, call offs, etc.

Temporary Employees

Temporary employees are those employed for short-term assignments up to six months. Temporary employees are not eligible for employee benefits except where mandated by applicable law. An employee will not change from temporary to any other employee status or classification simply because of the length of time spent as a temporary employee. The status of a temporary employee may change only if the employee is notified of the change in status, in writing.

Seasonal Employees

There is a seasonal demand for our services, and we are generally slower in the summer months, then very busy come fall. This summer shift creates an opportunity to offer a way for some employees to take a sabbatical during this timeframe (between 1-3 months during the summer months of July - September) while maintaining benefits, and still have their job in the fall.

COMPENSATION, MEAL PERIODS, AND REST PERIODS (WORKING CONDITIONS)

Pay Period and Paydays

Employees are paid on a bi-weekly basis. If a regular payday falls on a holiday, employees will be paid on the preceding workday.

For purposes of calculating overtime, Newport defines a workweek as beginning at 12:00 a.m. on Sunday and ending at 11:59 p.m. on Saturday and defines a workday as beginning at 12:00 a.m. and ending at 11:59 p.m.

If there is an error on a check, please report it immediately to Human Resources. Newport does not give advances against paychecks.

Payroll Deductions (State and Federal Employment Taxes)

The law requires that Newport make certain deductions from your compensation. Among these are applicable federal, state, and local income taxes. Newport also must deduct Social Security taxes on your earnings up to the IRS specified limit. Other deductions may be required by law. For questions about deductions, please see the Payroll Department or Human Resources.

Wage Disclosure Protection

Newport will not prohibit you from disclosing your own wages, discussing the wages of others, or

inquiring about another’s wages. Employees will also not be required to sign a waiver or other document that proposes to deny you the right to disclose the amount of your wages.

Newport will not discharge, formally discipline, or otherwise discriminate or retaliate against an employee for disclosing the amount of your wages.

However, employees who have access to or knowledge of the private compensation information of other employees as a part of their role and essential job functions may not disclose that information to individuals who do not otherwise have access to it, unless the disclosure is in response to a formal complaint or charge, part of an investigation, proceeding, hearing, or action, including an investigation conducted by Newport, or consistent with the legal duty of Newport to furnish information.

If an employee believes that they have been discriminated against or retaliated against in violation of this policy, they should immediately report their concerns to their manager or Human Resources.

Nothing in this policy will be enforced to interfere with, restrain or coerce, or retaliate against employees regarding their rights under the National Labor Relations Act.

Safe Harbor Policy: Pay For Exempt Employees

Newport is committed to abiding by all applicable state and federal wage and hour statutes and regulations. As part of this commitment, Newport pays its exempt employees on a salary basis and prohibits unlawful deductions from exempt employees’ salary payments. Generally, an exempt employee must be paid their weekly salary, without deduction, for any workweek during which the employee performs work. Certain salary deductions are legally permitted, including, but not limited to deductions for: full-day absence if the employee has exhausted their allowance under Newport’s paid time off policies; a full week disciplinary suspension; unpaid leave taken under federal or state leave statutes; or offsetting an employee’s receipt of jury fees, witness fees, or military pay. If you are an exempt employee and believe that Newport has made an improper deduction from your pay, please contact Human Resources immediately. Newport will promptly investigate the matter. If Newport determines that an improper deduction has occurred, the error will be corrected, and Newport will take appropriate measures to ensure that the improper deduction is not made in the future.

Work Schedule

Newport’s work schedules will vary in accordance with the primary business operations being 24/7 in the residential programs. Schedules will vary by outpatient program dependent upon client and programming needs. General office hours are 8:00 a.m. to 5:00 p.m. Individual work schedules will generally vary based on business need and will be assigned by your supervisor.

Timekeeping Procedures

An accurate record of hours worked in each workday and each workweek is kept on a time record to satisfy state and federal regulations. Non-exempt employees must accurately record their own time at the start and at the end of each work period and workday, including the time the employee takes for unpaid meal periods, by clocking in and clocking out via the time-keeping system embedded in UltiPro, Workforce Management.

Improper or fraudulent completion of a time record is grounds for dismissal. This includes, but is not limited to, the falsification of information on time records, inaccurate recording of time worked, unauthorized removal or destruction of time records, or recording the time of another employee.

If you discover an error on your time records, please contact your supervisor immediately to make the necessary correction.

All time worked must be accurately recorded. Failure to accurately record and approve time could result in disciplinary action, up to termination.

Working off-the-clock, either before or after clocking in or out or during a meal period, or failing to accurately record any time worked, is strictly prohibited.

Overtime Policy

All non-exempt employees who work more than 40 hours in one workweek will receive overtime pay at the rate of 1 and ½ times the employee’s regular rate of pay, or as otherwise required by applicable law. See your state-specific addenda for state-specific overtime pay.

Only hours actually worked are counted towards calculating an employee’s overtime pay. Compensated days away from work are not worked hours and therefore are not counted in making overtime calculations.

All overtime hours must be pre-approved by Newport management. If an employee works overtime without obtaining pre-approval, the employee will still be paid for the time worked, but may be subject to disciplinary action, up to and including termination of employment.

Meal and Rest Periods

See state-specific addenda for state-specific meal and rest period policies.

REMOTE AND HYBRID WORK POLICY

At Newport Healthcare, we value flexibility and understand the importance of supporting our employees’ diverse needs. Our remote and hybrid work arrangements offer eligible employees the opportunity to work offsite for all or part of their workweek. While remote work may not be suitable for every role or employee, it is a fantastic option for those whose job responsibilities align with this arrangement. This policy ensures that remote work remains a seamless extension of employment with Newport Healthcare.

We are committed to continuously evaluating remote and hybrid work arrangements to ensure they meet the needs of both the employee and the organization. Should changes be necessary, we will make every effort to provide 30 days’ notice to help employees plan for commuting, childcare, or other adjustments. In rare cases, immediate changes may be required.

Eligibility and Performance

Performance evaluations will be conducted regularly, focusing on work output and the completion of objectives. Employees will engage in consistent communication with their managers through phone, email, and virtual meetings via Teams or similar platforms. Together, employees and managers will continuously assess the arrangement, ensuring it remains effective and beneficial.

Guidelines for Success

• Clear Expectations: Supervisors will outline specific performance goals for remote and hybrid employees to achieve.

• Active Participation: Employees are expected to attend all virtual meetings where their attendance is required, provide updates, and communicate proactively.

• Flexibility for Illness: If an employee is unable to work due to personal or family illness, they should notify their supervisor to access time-away policies.

• Professionalism: Employees should maintain professional business etiquette during virtual meetings, including wearing appropriate attire, using cameras, and ensuring a distraction-free environment with a professional background.

• Equipment Support: Newport Healthcare will work with employees to determine equipment needs. Company-provided equipment will be maintained by Newport Healthcare, while employee-owned equipment will be the employee’s responsibility. All company equipment must be used for business purposes and returned upon employment termination.

Creating a Productive Work Environment

Employees are encouraged to establish a dedicated workspace at home that supports productivity and professionalism. While Newport Healthcare does not cover costs for home office setup, we are here to provide guidance and resources to help employees create an effective work environment. Employees are also expected to uphold the same high standards of information security as they would in the office, including using locked file cabinets, maintaining strong passwords, and implementing other security measures.

Work-Life Balance

Remote or hybrid work arrangements are designed to enhance flexibility, but they are not intended to replace childcare. Employees are encouraged to discuss expectations with family members to ensure a smooth transition into remote work. While schedules may be adjusted to accommodate personal needs, the focus remains on delivering excellent job performance and maintaining a professional presence during business meetings.

Timekeeping and Compliance

Non-exempt employees must accurately record their work hours using Newport Healthcare’s timekeeping system and adhere to meal and rest break requirements. Any overtime must be pre-approved by the supervisor. Timely and accurate timekeeping is essential to maintaining the remote work arrangement.

At Newport Healthcare, we are excited to offer remote work as a flexible option that empowers employees to thrive in their roles while balancing personal and professional responsibilities. Together, we can ensure this arrangement remains a positive and productive experience for everyone involved!

CREDENTIAL/LICENSURE VERIFICATION AND RENEWAL

The company verifies credentials and licensures for all personnel prior to employment and at renewal thereafter. Verification of employees’ credentials is necessary to ensure that the company hires and staff well-qualified and trained individuals to work with our population served.

Licensure renewal is the responsibility of the individual license holder. Renewal of licensure is mandatory to maintain one’s current position with Newport. It is the employees’ responsibility to renew their license prior to the expiration date. Current clinical positions may be suspended if renewal licensure verification cannot be obtained on the day after the expiration date.

JOB POSTING AND INTERNAL TRANSFERS

When appropriate, approved positions will be posted internally. Employees can go to the company intranet to find current open positions or to the Newport website Career Page.

• Employees who are interested in applying for another position should have been in their current role for a minimum of six (6) months and have satisfactory reviews with no disciplinary actions during that time. Human Resources reserves the right to allow employees with less than six months of experience to apply for another position if business needs dictate the exception and/or within a new market with minimally tenured employees.

• As a candidate, the employee must meet the education and experience requirements listed within the job description in addition to possessing the certifications/licensure necessary for the role.

• Prior to applying for another position, the employee should first meet with his/her supervisor to obtain their approval with consideration being given to departmental business needs, readiness for a new position, and any disciplinary actions.

• Apply for the position online.

• The applicant’s hiring manager is required to discuss this with the existing manager to confirm that the employee is in good standing and to determine a mutually beneficial plan for timing, should the transfer occur.

• If selected for a position that requires a transfer to another location, due to licensing requirements, the employee will need to complete the steps in the new hire process in accordance with the requirements of the new location.

PERFORMANCE EVALUATIONS

90 Day Introductory Period

Employees are evaluated after 90 days of employment and when transferring to a new position. A competency assessment will also be completed at the same time for nursing, direct care and clinical team members. In new programs that have not yet opened, the 90-day measurement period for nursing, direct care staff and clinical team members will begin once the facility is open and accepting clients.

Annual Performance Reviews and Competency Assessments

Newport Healthcare supervisors evaluate all their staff annually during a common review period each January/ February. The performance evaluation also includes a competency assessment for each member of the nursing, direct care, and clinical team. Each manager is responsible for the timely, fair, and accurate assessment of the performance and contribution of their employees.

Annual Merit Review Process

Newport is pleased to provide merit increases that are based on the employees’ performance. These are not to be considered an adjustment related to the cost of living. Merit increases are not guaranteed and are based on company and local operating unit performance.

Each manager is responsible for the timely and equitable assessment of the employee’s performance and contributions. Employees will be rated on different competencies depending upon their position.

Merit increases align with the common review period and are generally processed upon the successful completion of the company’s annual audit process which typically occurs in April.

Resignation

If an employee resigns from the company, a letter of resignation should be submitted to the immediate supervisor and Human Resources. Clinical team members and management are required to provide four (4) weeks’ notice and all other employees are required to provide a minimum of two (2) weeks’ notice in order to be considered eligible for rehire.

Any paid time away from work (exclusive of reasons covered by varying state sick leave policies) requested after an employee submits their notice will be approved by the immediate supervisor dependent upon business needs during the notice period. Prior to the employee’s last day at work, an exit interview will typically be scheduled with Human Resources.

Termination

Due to the at-will employment relationship, the employee or the company can terminate the employment relationship at any time with or without cause and with or without advanced notice, regardless of an employee’s work performance or the employee’s compliance with the rules set forth in this manual.

Where appropriate, the company will work through the progressive discipline process prior to termination, however, there are circumstances where immediate termination is warranted without any prior progressive discipline. Examples of those include but are not limited to: cases of misconduct such as violence to another person, harassment or discrimination, theft, willful destruction of the organization’s property, ethics violations, or verbal or physical aggression/abuse toward a client or family member, co-worker or supervisor. This is not an exhaustive list of the types of misconduct that may result in immediate termination without prior progressive discipline but is intended merely to provide employees with examples.

Final Paycheck

Employees who are separating from the company will receive their final paycheck in accordance with applicable state laws. Up to two (2) weeks of PTO or vacation time (where applicable) that has been accrued but not yet taken will also be paid out at the time of separation or as required per state laws

Any expense reimbursements will be paid on the company’s normal schedule.

In order to be eligible to receive any bonus, the employee must be actively employed at the time the bonus is earned, which is when all performance metrics and other performance factors are reviewed and analyzed, and the Board makes a final determination as to bonus amount. Employees must be in good standing as it relates to their performance, which will be determined by their immediate supervisor. Any employee with a written or documented verbal warning, performance improvement plan (PIP), or below average evaluation within six (6) months of bonus payout will be disqualified from bonus eligibility. If a new employee joins the company during the year, the time in position will be taken into consideration and the amount pro-rated accordingly.

The determination as to whether an employee qualifies for a bonus and the amount of any bonus awarded is within the sole discretion of Newport Healthcare’s Board of Directors. The Company reserves the right to modify or terminate the incentive program at any time.

Return of Company Property

At the time of separation, employees are expected to return all company property including any keys, computer and chargers/peripherals, phone and chargers, employee handbook, uniforms, tools, identification badge, credit cards, or any other documents that are company property that are in the possession of the employee. It is the employees’ responsibility to ensure the return of company property only to their manager or Human Resources. It is not appropriate to return company property to any other individual. The employee remains responsible for the property until it is secured by their manager or Human Resources.

Rehire

The company encourages the rehiring of former employees who left in good standing and who maintained a satisfactory work record. Former employees who meet this criterion should be classified as eligible for rehire and may be considered for reemployment provided they meet all the eligibility and application requirements.

Former employees who return within six (6) months of their termination date will be eligible for reinstatement of their seniority date and accruals. After a six (6) month break in service, previous tenure will not be considered in calculating seniority, leave accruals or any other benefits.

An employee who was terminated for cause or who resigned in lieu of termination will not be eligible for rehire. If an employee is determined to be ineligible for rehire, they are not eligible for rehire within any location in the Newport system.

If a former employee applies for an open position, Human Resources should review the former employee’s personnel file and, where applicable, contact the facility where the individual worked to determine eligibility for re-employment. If the individual is eligible for rehire, the hiring supervisor is then notified and should consider this information when determining the best applicant for the position.

• Rehired Within 91 Days of Termination

If the employee is rehired within 91 days of termination, the following procedures will be followed:

Offer Letter

An offer letter should be prepared outlining the specifics of the new role and the rehire provisions.

Background Screening

Dependent upon state and/or program requirements, the facility may use the existing background screening that is on file provided it is no more than one (1) year old. The Human Resources Representative should review the existing screening to ensure that it meets all the qualifications of the background screening policy. In addition, the screening must meet all requirements by the licensing agent for the facility.

Pre-Employment Drug Test

A new drug test will need to be completed before reinstatement for any break in employment.

• Rehired After 91 Days of

Termination

If the employee is rehired after 91 days of termination, they will be treated as if he/she is an external candidate and all the onboarding requirements for a new hire should be followed.

Paid Time Away Banks:

Eligibility for accruing paid time off is based on the employee’s classification at time of rehire. Employees who return to an eligible employment classification will have an adjusted seniority date to reflect the period of time that they were separated from the company. PTO/Vacation time accruals will begin immediately for an employee in an eligible employment classification. Sick time, if applicable, will accrue immediately for an employee in an eligible employment classification.

Benefits:

Eligibility for participating in the company health and welfare benefit programs is based on the employee’s classification at time of rehire. If an employee is rehired in a benefit eligible status, benefits will be available on the 1st of the month following 30 days of service.

Under the Affordable Care Act, an employee who was eligible to participate in the medical plan prior to termination and is rehired within 13 weeks may participate in medical coverage the first of the month following 30 days of the rehire date.

For participation in the 401(k) plan, the rules of the plan document will prevail.

WORKPLACE POLICIES

STANDARDS OF CONDUCT

Newport expects its employees to observe a standard of conduct which will help maintain a safe, positive, and productive workplace. Such a standard of conduct will benefit and protect both Newport and all employees. Behavior that violates this standard of conduct will subject employees to discipline, up to and including immediate termination.

The following list represents a non-exhaustive list of the types of behavior that will be considered improper and unacceptable in the workplace:

• Stealing private or Newport property.

• Destruction or defacement of private or Newport property.

• Non-compliance with Newport’s Drug and Alcohol Workplace policy.

• Falsification, misrepresentation, or material omission of information (e.g., time records, application, financial records, etc.).

• Fighting on Newport property or threatening violence to any Newport employee or client.

• Indecent or disorderly conduct or conduct that interferes with others in the performance of their jobs.

• Using obscene, abusive, or threatening language on Newport property or during working hours.

• Disregarding the instructions of your manager or another proper authority.

• Failure to observe work schedules, including rest breaks and meal periods as defined by state law.

• Failure to observe safety rules. You must not take any action that results in, or could result in, personal injury, injury to others, or property damage. You must follow safe driving practices and posted speed limits when driving within Newport premises.

• Inefficiency, lack of productive effort, or other unsatisfactory work performance.

• Unauthorized use of Newport time, materials, or equipment.

• Unsuitable or improper attire for the workplace. Please refer to the Dress Code policy for more specific information.

• Sleeping during work hours.

• Unexcused absences, including failure to notify your manager that you will not be reporting to work, or tardiness. See Attendance policy for specific information.

• Smoking or vaping on Newport property or while in the presence of clients.

• Removal of any property without proper authorization. If you find any personal items on Newport property that do not belong to you, return them to your supervisor or to Human Resources.

These guidelines are meant to help you better understand the standards and expectations for all employees to promote and ensure a safe, productive working environment. This list is not exhaustive and is not intended to address every conceivable situation. If you have any questions about appropriate behavior, safety processes and protocols, work rules or other work-related practices, refer to the Policy and Procedures or ask your supervisor or Human Resources.

Employees who do not abide by these guidelines are subject to disciplinary action, up to and including suspension or termination. The appropriate disciplinary action used to maintain the standards of conduct will be determined with consideration to the facts and circumstances of each individual case. No employee will be disciplined for engaging in behavior or activity that is protected by the National Labor Relations Act.

DISCIPLINE

Newport expects employees to perform to the best of their abilities at all times. Unfortunately, there may be occasions when an individual performs at an unsatisfactory level, violates a policy, or commits an act that is unacceptable. Depending on the circumstances, Newport may choose to exercise its discretion to utilize forms of discipline that are less severe than termination, such as verbal counseling, written warnings, unpaid suspension, or demotion.

Although one or more of these steps may be taken in connection with a particular employee, no formal order or system is necessary, and Newport is not required to treat each incident of discipline as a step in a progressive series of disciplinary measures. Newport may use whatever forms of discipline it deems appropriate under the circumstances, including immediate termination.

NON-FRATERNIZATION POLICY

In order to prevent misunderstandings, favoritism complaints, actual or potential conflicts of interest, harassment complaints, and employee morale issues, Newport prohibits managers or other company officials who are in sensitive or influential positions, from engaging in romantic relationships with a subordinate. If a romantic relationship develops between a manager or other company official and a subordinate, both employees must immediately disclose the existence of their relationship to Human Resources so that appropriate measures may be taken.

If management deems, in its sole discretion, that the relationship may pose an actual or potential conflict of interest, Newport may ask the employees to decide who will transfer (if another position for which the employee is qualified is available) or resign. Failure to approach Newport about a possible violation of this policy may result in disciplinary action, up to and including termination.

Newport Healthcare strongly believes that a work environment where employees maintain clear boundaries between employee personal and business interactions is most effective for conducting business and enhancing productivity. Although this policy does not prevent the development of friendships or romantic relationships between co-workers, it does establish boundaries as to how relationships are conducted during working hours and within the working environment.

• During working time and in work areas, employees are expected to conduct themselves in an appropriate workplace manner that does not interfere with others or with overall productivity.

• During non-working time, such as lunches, breaks and before and after work periods, employees engaging in personal exchanges in non-work areas should observe an appropriate workplace behavior to avoid offending other workers or putting others in an uncomfortable position.

• Employees are strictly prohibited from engaging in physical contact that would in any way be deemed inappropriate by a reasonable person while anywhere on company premises, whether during working hours or not.

• Employees who allow personal relationships with co-workers to adversely affect the work environment to the extent it becomes an issue or becomes disruptive, will be subject to the appropriate disciplinary measures.

Employees should also refer to Newport’s strict policy against unlawful harassment, including sexual harassment, as detailed in this handbook.

Additionally, although Newport permits members of the same family to work at Newport, Newport will not permit any individual to be in any supervisory or subordinate chain of command with any other family member.

ATTENDANCE

At Newport, we recognize that every employee is a vital part of our team, contributing to a safe and healing environment for our clients. Regular attendance is essential for our operations, and we appreciate your commitment to being present when scheduled.

Attendance Expectations

Notification:

• Planned Time Off

o Please refer to the Time Away From Work policies to request time off.

• Unplanned Absence or Tardiness

o If you anticipate being absent or late, please inform your manager as soon as possible, ideally at least two hours before your shift starts. Within PrairieCare only, there is an absence hotline in place that employees should utilize for informing the team that you will be absent or late. That number is 952-903-1367. This allows us to adjust schedules and ensure client needs are met.

• Shift Coverage: Employees may find a replacement to cover their shift with management approval. If the replacement is approved and covers the entire shift, the absence will not count as an occurrence. Employees must use their accrued PTO or Sick Leave where applicable to cover missed shifts when available. Employees will not be required to find a replacement, and will not receive any occurrence points, for legally protected absences

Support for Absences

We understand that unforeseen circumstances can arise. If you are absent for three or more consecutive business days, medical documentation may be requested in accordance with applicable laws. We are committed to supporting you during these times.

Attendance Recognition

At Newport, we understand the importance of reliable attendance, especially for roles with assigned shifts where punctuality and presence are critical to providing exceptional client care. To encourage and reward great attendance, we have established the following policy:

Eligibility Criteria

• This program is open to full-time, non-exempt employees who work on-site and have designated start times.

• Employees must complete a full calendar quarter (3 months) without any unscheduled absences or tardiness. Please note that protected leave is excluded from this policy.

Incentive: Eligible employees who meet the attendance criteria will receive a bonus of $100.

Attendance Management

While we strive to be understanding, we also need to maintain accountability and ensure appropriate staffing levels to care for our clients. Excessive absenteeism or tardiness may result in disciplinary action up to and including termination of employment. Unless applicable law provides otherwise, employees who incur a total of seven occurrences within a rolling 12-month period will be subject to termination

of employment. An occurrence is defined as an unscheduled absence (even if timely notification is provided), tardiness exceeding 30 minutes, or an unexcused early departure. Employees who arrive late but within the first 30 minutes of their scheduled shift or provide timely notification of an unscheduled absence (at least two hours’ notice prior to of the start of the shift) will receive a half occurrence for that tardiness or unscheduled absence.

Absent extraordinary circumstances or a legally protected reason, if an employee fails to report for work without providing notification to the Company (no call/no show), the employee will receive a final written warning. If a no call/no show continues for a period of two consecutive days or shifts, the Company will consider the employee to have abandoned and voluntarily terminated their employment with the Company.

Protected Absences

Certain absences are protected under applicable laws, including the ADA/ADAAA, FMLA, maternity leave, and others. These absences will not count against your attendance record.

Conclusion

We value your contributions and understand that life can be unpredictable. Our goal is to balance personal needs with our commitment to providing consistent care for our clients. Please communicate openly with your manager regarding any attendance concerns.

DRESS AND APPEARANCE REQUIREMENTS

Newport expects employees to dress appropriately in professional business casual attire or in the designated uniforms with the appropriate logo.

Newport expects employees to dress appropriately while onsite at work and when in virtual meetings (as employees should have their cameras on) and when representing Newport at off-site events. This policy is intended to provide a basic standard for attire throughout the organization. However, Newport reserves the right for each location to expand upon this policy as needed.

Employees are expected to demonstrate good judgment and professional taste. Employees who wear attire that is deemed inappropriate may be sent home to change into appropriate clothing. Hourly paid employees will not be compensated for any work time missed because of failure to comply with designated workplace attire and grooming standards. Enforcement of this policy is the responsibility of management and supervisory staff.

Examples of inappropriate business attire include:

• Cutoff or torn (ripped) pants

• Midriff length tops, spaghetti strap shirts or dresses, off the shoulder or halter tops, low cut or overly revealing tops, shorts – shorts may be allowed from July 1 through Labor Day depending upon weather conditions and specific positions. Please speak with your HR Representative prior to wearing shorts.

• Clothing with inappropriate logos

• Athletic attire unless authorized for a specific designated event

Newport has designated uniforms for certain positions in operations and all employees should always have their identification badges on and visible at all times. All employees working on site in our

residential and outpatient locations are expected to always wear closed toe shoes for safety purposes. Employees in positions requiring uniforms should refer to their local program for specific guidance.

Newport will reasonably accommodate an employee’s religious beliefs in terms of workplace attire unless the accommodation creates an undue hardship. Accommodation of religious beliefs in terms of attire may be difficult due to safety issues for employees. Those requesting workplace attire accommodation based on religious beliefs should be referred to their designated Human Resources Representative.

Recognizing that employees, clients, and families may have sensitivity or allergic reactions to fragrant products, please either refrain from wearing fragrances, colognes, lotions, powders, or other similar products or keep them to a minimum while at work.

This policy is not intended to prevent or discourage employees from engaging in legally protected activities, including activities protected by the National Labor Relations Act.

MEDIA INQUIRIES

Employees of Newport are not to engage with the media on behalf of the Company at any time concerning the company without prior approval. This includes never discussing patients/clients, allegations, or crisis events with the media on behalf of the Company. All media inquiries and communication should be forwarded to the Associate Vice-President, Public Relations and Communications immediately (communications@newporthealthcare.com).

It is not uncommon for the media to try to reach out to individual employees to get interesting quotes or sound bites that they can exploit. Should an employee receive an email, call, or visit from the media, Newport’s protocol is as follows:

• If email: immediately forward email to the AVP of PR and Communications.

• If phone call: Do not answer any speculative questions about specific clients, employees, or events/ incidents. Tell the media contact that you will forward their information to the correct person for a response. Get their information including name, media outlet, phone, and email and immediately email it to the AVP of PR and Communications.

• If unexpectedly visited: Be polite, but firm in informing the media contact that they are on private property and therefore must leave. Get their information (name, media outlet, phone, and email) and let them know that you will get it to the appropriate person who will follow up. Immediately email the information to the AVP of PR and Communications.

Media representatives are allowed inside Company buildings only upon the approval of the CEO and Newport’s AVP of Public Relations and Communications. Media representatives must:

• Sign a confidentiality statement;

• Be accompanied at all times by a Company staff member;

• Wear a visitor badge.

Employees who have been designated as spokespeople will undergo media training with Newport’s AVP of PR and Communication, including specific instruction for handling controversial or sensitive topics, and will adhere to the company’s Crisis Communications Plan for crisis situations.

Filming and/or photography are not permitted externally or internally without permission from the CEO.

Notwithstanding the foregoing, employees are not prohibited from speaking with the media when doing so in their personal capacity. When speaking with the media in such circumstances, employees should make clear they are not speaking on behalf of the Company and that the employee’s personal opinions, views, and statements may not represent the opinions, views, and statements of the Company. This policy does not restrict employees’ right to speak about their terms and conditions of employment, including with the media, nor does it restrict any other right protected by the National Labor Relations Act.

Never give out patient names, addresses, phone numbers, or any other identifying information regarding current or previous patients to the media for any reason.

ACCESS TO PERSONNEL FILES

Personnel and medical files are the property of Newport, and access to the information they contain is made available to authorized personnel only who have a legitimate reason to review information in a file. Any request for information contained in personnel files must be directed to management. Only Human Resources or senior management are authorized to release information about current or former employees. Disclosure of personnel information to outside sources will be limited. However, Newport will cooperate with requests from authorized law enforcement or local, state, or federal agencies conducting official investigations and as otherwise legally required.

An employee may review or copy their personnel file, with the exception of records relating to the investigation of a possible criminal offense, letters of reference, ratings, or reports or records that were obtained prior to employment at any time. Employees have access to their electronic employee file and payroll records.

WORKPLACE SAFETY

Newport’s Culture of Safety is a shared value and belief among employees, supervisors, and leaders regarding the primary importance of ensuring that the organization’s process and equipment causes no harm to clients, visitors, or staff. It means that everyone, every day, uses behaviors throughout the organization that results in a safe, reliable, and productive performance. It means that everyone, every day, focuses on safe behaviors and a safe environment, even when no one is looking. We have a blameless Culture of Safety, without retaliation, for those who report unsafe and disruptive behaviors. We actively encourage our staff to notify their supervisor of any unsafe practices that are being witnessed. Please comply with all safety policies, procedures and regulations, and contribute to the efforts to maintain the Culture of Safety.

INCLEMENT WEATHER

Residential/Inpatient

Our residential treatment facilities are open 24 hours per day, 365 days per year. As such, Newport Healthcare must maintain appropriate staffing levels even during periods of inclement weather.

This policy constitutes an advisory to find appropriate means of transportation to report for work in the case of inclement weather, particularly those identified by the employing department as “essential.” Essential employees are generally defined as nursing, programming, culinary, facilities and security, however this is not intended to be an all-inclusive listing. As employees of Newport, we are all considered to be essential, dependent upon the needs of our programs, particularly in a 24/7 care environment. The supervisor will notify employees within each program who are essential as events unfold. Essential employees are also encouraged to bring toiletries and a change of clothes in the event they are asked to cover additional shifts or are concerned that they cannot make it back to work the following day.

If the essential employee chooses not to drive during the event, is concerned about road closures, or if a State of Emergency has been declared, the employee should prepare to come in prior to the storm to ensure their safety. Employees scheduled to work any shift during these events may come in early for “rest time” with prior approval from their supervisor/manager. If the employee is required to remain on company premises or so close that they cannot use the time effectively for their own purposes, the employee will be paid for this time. Once the roads have opened and/or the State of Emergency has been lifted, employees should plan to report to work as scheduled.

Should an essential employee be at work when the event occurs, and they are scheduled to work another shift, the employee may request to stay at the facility with prior approval from supervisor/manager, being compensated for any time in which the employee works or is required to be on site or close by as defined above.

Each employee who is designated as “non-essential” must make a determination as to personal safety. Those non-essential employees who are not able to report to work will be required to use PTO or vacation time (where applicable) for the time they were scheduled to work. There are some non-essential roles that would allow the employee to work from home. Supervisors must make that determination and approve in advance of the weather event.

Should a State of Emergency be in effect to include a travel ban, the non-essential employees who are scheduled to work will be paid for four (4) hours of regular time, as the reason they were not able to

come to work was beyond their control. Non-exempt employees will not be eligible for overtime for these hours. If an employee is approved to work from home, they will not be compensated for any additional time beyond the hours they work.

Outpatient and School Closures

The company will make every effort to operate during regularly scheduled hours. However, certain weather events may create the need to adjust those hours to ensure the safety of our employees and our clients. Parents have the right to not send their kids to school/treatment if they deem it unsafe and it will be marked as lawfully absent.

The program director, in consultation with their immediate supervisor, will ultimately make the determination as to whether or not the need exists to adjust the regularly scheduled hours of operation. The parameters used for making adjustments to the hours will primarily be determined by when a State of Emergency is being enforced. Upon the decision being made to adjust the regularly scheduled hours of operation, notification will be made through the emergency alert system. The individual schools and outpatients will determine how to alter their schedule to accommodate required clinical programming.

The following personnel will be deemed essential if it is determined that the outpatient and school will remain open during weather events that do not result in a State of Emergency being issued: residential director, clinician, direct care staff member, and a teacher. Individuals employed in those roles should make arrangements prior to the weather-related event to report as scheduled. The company will make lodging arrangements for those employees considered to be essential when deemed necessary.

Employees will be paid for their regularly scheduled hours during those rare occasions that the outpatient and school are closed when a State of Emergency is in effect. Each employee who is designated as nonessential must make a determination as to personal safety. If the location is open and the non-essential employee is not able to report to work as scheduled, the employee will use PTO or vacation time (where applicable) for that time. Employees who are in roles that do not provide direct care to our clients may have the ability to work from home. The program director will review each of those positions to determine whether or not the need exists for that to occur and approve if warranted.

SAFE OPERATIONS OF VEHICLES

Employees who drive their own vehicle on company business or who drive a company owned or leased vehicle have a responsibility for their own health and safety and the health and safety of others while driving.

Every driver is responsible for the following:

• The safety of the vehicle

• The safety of the passengers

• The safety of pedestrians and other motorists

• Understanding and abiding by the provisions included within Newport policies and procedures as well as state and federal laws

• Supplying the required information to their designated Human Resources Representative

Driver Eligibility

If the employee is likely to be driving as part of their work with Newport, they will need to go through a thorough review of their past driving records. Individuals who drive company vehicles or who are

required to use their personal automobile for business travel must maintain a valid driver’s license. Where applicable, drivers will comply with DOT Commercial Driver License (CDL) regulations.

Upon obtaining a Motor Vehicle Report (MVR), points will be assigned for each violation that has occurred over the last 42 months using the Newport Schedule below:

*This point allocation overrides any points that may appear on a driver’s MVR.

The following actions will be taken depending on the number of points that have been assigned over the last 42 months:

Points Action

0 – 7

8 or 9

10 or above

Driver permitted to drive on Newport business

Driver will be required to attend a defensive driving course (at driver’s expense) before they will be permitted to drive on Newport business.

Driver will not be permitted to drive on company business and should not be hired if driving is essential to work.

Ongoing Driving Monitoring

Once you have been identified as having a safe driving record, Human Resources will conduct regular monitoring. MVRs will be completed on all drivers at least every 12 months.

Drivers should be aware that if their MVR shows that they have accumulated 10 points or more in a 42month period, they will be suspended from driving activities at work. This could result in the individuals’ employment being terminated if driving is an essential part of their job.

Insurance Requirements

Drivers using their personal vehicle for business are responsible for providing their own insurance. A copy of the driver’s current insurance coverage summary or declarations page (specifying policy limits, period, etc.) shall be given to the designated Human Resources Representative and updated when insurance is renewed. Newport requires that the following minimum liability limits are covered by the insurance policy:

• $100,000 per person/$300,000 per accident (or $300,000 combined single limit).

• Ensure the insurance policy allows the driver to use the vehicle for company business.

Transporting Clients

Employees who are responsible for transporting clients in company vehicles should familiarize themselves with the Transporting Clients policy in the company Policies and Procedures Manual that can be found on the company intranet.

Vehicle Safety Rules

All drivers are responsible for applying caution and following safety rules when transporting clients and/or driving company vehicles. Employees will be subject to disciplinary action if found to be driving in an unsafe manner.

• Drivers will follow all applicable state and federal laws.

• Driving while under the influence of drugs or alcohol will be cause for immediate termination.

• Obey speed limits; excessive speed is a major cause of accidents.

• Buckle up; ensure that all passengers are wearing seat belts as well.

• Do not call, text, or email while driving; pull over and park in a safe place before doing so.

• Signal well in advance of turning or changing lanes.

• Maintain reasonable distance; allow for speed, road, and weather conditions.

• Do not tailgate.

• Never assume right-of-way. Always yield to avoid collision.

• Merge into traffic without forcing the vehicle in.

• Obey all traffic signs and signals with a full and complete stop.

• Do not pass any vehicles at intersections, railroad crossings, or where vision may be limited.

• Unsafe vehicles should not be driven until the condition is corrected.

• Before changing a flat tire, always move the vehicle off the main road to a safe, well-lit area.

• If a driver is on prescribed medication, this information should be reported to the designated Human Resources Representative who will determine if driving is still acceptable.

• Accidents are to be reported immediately to Human Resources. Accident investigation forms are to be completed by the driver at the scene of the accident.

• Tickets and motor vehicle violations are to be reported to the designated Human Resources Representative and are the responsibility of the driver.

DRUGS AND ALCOHOL POLICY

To ensure a safe working environment for all, the Company sets forth the following drug and alcohol related standards of conduct:

• Consuming alcohol at any time during an individual’s shift, including during a meal break, is prohibited. Engaging in any illegal or unauthorized use of drugs at any time while on or off-duty is prohibited. This includes, but is not limited to, while the individual is on or off the premises of the Company, as well as during the employee’s meal period. If an individual’s use of prescription and/or over-the-counter medications may impair their ability to perform the essential functions of the job safely, they must notify Human Resources to discuss accommodations, including any measures to ensure everyone’s safety. This information will be maintained confidentially and will be shared with Company personnel only on a need-to-know basis.

• To the extent permitted by state or local law, the Company prohibits recreational marijuana usage, even while off-duty. Unless otherwise prohibited by law, individuals who test positive as a result of recreational marijuana usage on any drug test required under this Policy may be subject to disciplinary action. Individuals who use marijuana medicinally should not report to work or remain on duty while using marijuana and should consult with Human Resources, although lawful medicinal marijuana usage, alone, will not be an automatic bar to employment.

• Engaging in the unlawful or unauthorized manufacture, distribution, solicitation, sale, purchase, transfer or possession of drugs or alcohol while on Company-paid time, on Company premises, in Company vehicles, or while otherwise engaged in activities for or on behalf of the Company is prohibited. In addition, an individual’s illegal conduct involving drugs or alcohol during non-work times may also result in discipline, up to and including termination of employment. This prohibition does not prohibit the authorized possession of any client prescribed medication so long as the employee’s possession of said medication is solely related to one’s job duties and distributed to clients consistent with applicable care plans.

• Testing positive on any drug or alcohol test required by the Company, including but not limited to reasonable suspicion testing, is prohibited.

• Failing to stay in contact with the Company or its medical review officer while awaiting the results of a drug test is prohibited.

• Refusal to submit to any drug or alcohol test that is required under Company policy is prohibited. Individuals who refuse to submit to testing required by this policy will be terminated. “Refusal to submit to a test” includes, but is not limited to: refusing or failing to appear or excessive delay in reporting for a required test within a specified time, as determined by the Company, after being directed to do so; refusing or failing to provide a specimen, or adulteration or substitution of a specimen, or attempting to adulterate or substitute a specimen; failing to complete any paperwork required by the collection facility; failing to remain at the testing site until the test is completed; failing or refusing to submit to a second test that may be required by the collector or the Company; or, failing to cooperate with any aspect of the testing process.

Violations of this policy are subject to disciplinary action up to and including termination.

Newport Healthcare and its affiliates, subsidiaries, and related companies (the “Company”) have a vital interest in maintaining safe, healthy, and efficient working conditions for its employees, clients, and visitors. The use of alcohol, illegal or unauthorized drugs, or controlled substances while on the job poses serious safety and health risks not only to the user but to all those who work or come into contact with the user. The manufacture, possession, sale, or distribution of alcohol, illegal or unauthorized drugs, or controlled substances in the workplace also pose unacceptable safety and health risks. The goal of establishing this policy is to carefully balance a respect for individual privacy with the commitment of the Company to maintain a safe, productive, drug free work environment. The policy applies to all applicants for employment, employees of Newport Healthcare, and independent contractors.

Testing

The Company requires pre-employment drug tests as a condition of employment, as well as for certain independent contractors prior to providing services to clients. The Company will rescind any offer of employment to an applicant who fails to successfully complete the pre-employment drug screen.

The Company may also require drug and/or alcohol testing of individuals upon reasonable suspicion that an individual may be impaired while at work. An individual who is required to submit to a reasonable suspicion test will be suspended after the completion of the drug and alcohol tests, pending receipt of the test results.

To the extent permitted under applicable law, the Company additionally reserves the right to conduct post-accident and/or random drug testing. Employees who are subjected to random drug testing requirements will be notified of such in advance.

All testing processes will comply with state and local requirements, to the extent any apply.

The Company also reserves the right to evaluate the individual’s conduct that triggered the drug and/or alcohol test, to determine if the conduct in and of itself warrants discipline, up to and including termination.

Self-Identification

The Company maintains a policy of non-discrimination and will endeavor to make reasonable accommodations to assist individuals recovering from substance and alcohol dependencies, and those who have a medical history which reflects treatment for substance abuse conditions. However, current violations of this policy will not be tolerated, and individuals may not request an accommodation to avoid discipline for a policy violation. The Company encourages employees to seek assistance before their drug and alcohol use renders them unable to perform their essential job functions or jeopardizes the health and safety of themselves or others.

Employees needing help in dealing with drug abuse/dependence are encouraged to use our Employee Assistance Program (MetLife: 1-888-319-7819) and health insurance plans, as appropriate. Employees may not use this self-identification provision to avoid taking a test when required under this policy or to avoid being disciplined for receiving a positive test result or for refusing to submit to a test.

Applicable Law

Whenever necessary, implementation of this Policy shall be modified to comply with requirements of applicable federal, state and local laws or regulations.

Drug Free Workplace

In order to maintain a drug-free workplace, the Company has established a drug-free awareness program to educate individuals on the dangers of drug abuse, alcohol, tobacco and our Drug and Alcohol workplace policy, the availability of any drug-free counseling, rehabilitation and individual assistance programs and the penalties that may be imposed for violations of the Drug and Alcohol workplace policy.

In accordance with the Drug Free Workplace Act, if you are alleged to have violated any criminal drug statute, and are subsequently convicted, you must notify Human Resources within five (5) days of such conviction. Within ten (10) days of such notification or other actual notice, the Company will advise the

contracting agency of such conviction.

Rehire Following Substance Abuse Violation

If a former employee seeks to be rehired following a violation of Newport’s Drug Free Workplace policy, the former employee will need to apply for an open position no sooner than six (6) months after their termination date. The company will evaluate the former employee’s suitability for rehire. If considered for rehire, the company will require the former employee to submit to random drug and/or alcohol test as a condition of reinstatement. The employee will be required to sign a letter agreeing to submit to follow-up testing, to be conducted randomly, over the next 12 months. Such results may be reported, as appropriate and required, to the employee’s accrediting or licensing agency.

INSPECTIONS

All of Newport’s facilities, computers, lockers, furnishings, equipment, desks, and vehicles are property of Newport and are provided to employees for their use in the conduct of Newport business. No employee has a right to or expectation of privacy in such property. Newport retains the right to search and inspect all Newport property, as well as other items brought onto Newport premises at any time, with or without notice or employee consent.

SAFETY/WORKERS’ COMPENSATION

Newport maintains a strong commitment to providing a safe, efficient, and productive work environment. Newport wishes to ensure that employees will perform their duties safely and efficiently in a manner that protects their interests and those of their co-workers. Newport also desires to promote efficiency in the workplace and to provide the highest quality services. It is the basic safety policy of Newport that no task is so important that an employee must violate a safety rule or take the risk of injury or illness in order to get the job done.

If an employee suffers a work-related injury or illness, no matter how minor, it must be reported to the individual’s supervisor and/or Human Resources as soon as reasonably possible so that the employee can receive the proper treatment and Newport can take steps to help prevent similar injuries or illnesses from occurring. All recordkeeping will be maintained by Human Resources. Employees who witness another employee get hurt or become ill should not attempt to move the individual unless failure to do so would result in further injury or danger. In the event of an injury to another employee, a supervisor should be called immediately.

Newport’s workers compensation program covers all eligible employees. For more information, please contact Human Resources or refer to the Workers Safety & Injury on the Job policy which can be found in the company Policies and Procedure Manual located on the company intranet.

SMOKING POLICY

Smoking is not permitted on Newport property. Smoking is also not permitted while on shift off premises when in the presence of clients. This includes the use of e-cigarettes, vaporizers, or any other tobacco products, including smokeless ones.

Weapons

In the interest of maintaining a workplace that is safe and free of violence, employees may not, at any time while on any property that is owned, leased or controlled by Newport, possess or use any weapons.

Weapons include, but are not limited to: guns, knives or swords with blades, explosives and any chemical whose purpose is to cause harm to another person.

Employees who violate this policy will be subject to disciplinary actions, up to and including termination.

Violence in the Workplace

Newport is committed to providing a working environment free of workplace violence, which includes verbal or physical threats of violence, aggressive behavior, violent outbursts, or use of weapons of any kind. Workplace violence will not be tolerated under any circumstances and will lead to disciplinary action, up to and including termination.

Any employee who has been subjected to or witnessed inappropriate behavior by anyone, including supervisors, co-workers, or visitors, should report the incident promptly to his or her supervisor and to management. Employees that fear they are in immediate danger should dial 911. Supervisors who receive complaints from employees or who observe inappropriate behavior should inform management immediately. Every complaint of workplace violence that is reported to a member of Newport management will be investigated in as confidential a manner as possible. In addition, Newport will not tolerate retaliation against any employee for cooperating in an investigation of inappropriate behavior or for making a complaint.

Specific examples of conduct which may be considered a threat or an act of inappropriate behavior under this policy include, but are not limited to:

• Intimidating or threatening physical or aggressive conduct directed toward another individual;

• Threatening an individual or his or her family, friends, or property with physical harm;

• The destruction or threat of destruction of Newport property or another’s property;

• Harassing or threatening phone calls or text messages;

• Surveillance;

• Stalking; or

• Veiled threats of physical harm or intimidation.

Violations of this policy may lead to disciplinary action, up to and including termination.

Employees should review and familiarize themselves with the Weapons Confiscated on Property policy found in the Policies and Procedures Manual that can be found on the company intranet.

SOLICITATION AND DISTRIBUTION POLICY

The following rules apply to employee solicitation and distribution of written materials on Newport Healthcare premises:

• Employees cannot solicit or distribute literature for any purpose at any time in immediate patient care areas.

• In areas other than immediate patient care areas, employees cannot solicit for any purpose during working time.

• Employees may not distribute literature during working time or in working areas or in immediate patient care areas.

• Employees and non-employees are prohibited from posting or hanging literature or other materials on the official bulletin boards, walls, windows, or other surfaces located on Newport Healthcare property.

• Employees are prohibited from using Newport Healthcare’s communication systems, including email, for non-work purposes.

• Non-employees cannot solicit or distribute literature on Newport Healthcare property at any time.

Definitions

Immediate patient care areas are patients’ rooms, places where patients receive treatment or are engaged in therapeutic activities, and the halls and corridors immediately adjacent to these areas.

Solicitation includes, but is not limited to, approaching someone in person or through employer-owned property such as computers, smartphones, email systems, and intranets for any of the following purposes:

• Offering anything for sale.

• Asking for donations.

• Collecting funds or pledges.

• Seeking to promote, encourage, or discourage participation in or support for any organization, activity, or event, or membership in any organization.

• Distributing or delivering membership cards or applications for any organization.

Distribution includes, but is not limited to, disseminating or delivering in person or through employerowned property such as bulletin boards, computers, smartphones, emails, and intranets any literature or other materials including circulars, notices, papers, leaflets, or other printed, written or electronic matter (except that distributing or delivering membership cards or applications for any organization is considered solicitation and not distribution).

Working time refers to the working time of the person doing the soliciting as well as the working time of the individual being solicited but does not include the time before or after an employee’s shift, meal periods, or other break times (whether paid or unpaid).

Working areas include areas controlled by Newport Healthcare where employees are performing work and does not include cafeterias, break rooms, and parking lots.

Communication systems include, but are not limited to, employer-owned IT systems, such as email systems; televisions; bulletin boards; copy machines; telephones; and public-address systems.

Conduct Not Prohibited by this Policy

This Policy does not restrict solicitation, or the distribution of literature related to Newport Healthcare’s business functions or limited employer-sponsored charitable solicitation.

Besides imposing lawful restrictions on employee solicitation during working time and employee distribution of written materials during working time and in working areas, this policy is not intended to preclude or dissuade employees from engaging in legally protected activities, including activities protected by the National Labor Relations Act.

Discipline

Employees who violate any provision of this policy may be subject to discipline, up to and including termination of employment.

CONFLICT OF INTEREST AND CONFIDENTIALITY

GIFTS AND SOLICITATION

Employees are prohibited from accepting gifts from clients or their families. Employees are also prohibited from soliciting clients or their families and from entering into business and/or personal arrangements with clients or their families for a minimum of two years after the client leaves Newport

OUTSIDE EMPLOYMENT

While Newport does not seek to interfere with the off-duty and personal conduct of its employees, certain types of off-duty conduct may interfere with Newport’s legitimate business interests. For this reason, employees are expected to conduct their personal affairs in a manner that does not adversely affect Newport’s or their own integrity, reputation, or credibility. Illegal off-duty conduct on the part of an employee that adversely affects Newport’s legitimate business interests or the employee’s ability to perform his or her job will not be tolerated.

While employed at Newport, employees are expected to devote their energies to their jobs with Newport. The following types of outside employment may create a conflict of interest and are generally discouraged and/ or prohibited:

• Employment that conflicts with an employee’s work schedule, duties, and responsibilities;

• Employment that creates a conflict of interest or is incompatible with the employee’s employment with Newport;

• Employment that impairs or has a detrimental effect on the employee’s work performance with Newport;

• Employment that requires the employee to conduct work or related activities on Newport’s property during Newport’s working hours or using Newport’s facilities and/or equipment; and

• Employment that directly or indirectly competes with the business or the interests of Newport.

Employees who wish to engage in outside employment that may create a real or apparent conflict of interest must submit a written request for consideration to management explaining the details of the outside employment. Newport assumes no responsibility for outside employment. Newport will not provide workers’ compensation coverage or any other benefit for injuries occurring from or arising out of outside employment.

This policy is not intended to preclude or dissuade employees from engaging in activities protected by the National Labor Relations Act.

CONFIDENTIAL INFORMATION AND TRADE SECRETS

Employees will acquire, will become acquainted with, and will have access to trade secrets, confidential information, and property relating to Newport and its clients’ business. All information obtained in the course of your employment is to be used for conducting Newport business only. Never discuss or disclose such trade secrets, confidential information, or property, either directly or indirectly with or in the presence of persons outside Newport, or those employees who do not have a need to know, either during employment or at any time thereafter.

Information in any form, including but not limited to documents, tapes, lists, computer printouts, studies, surveys, reports, drafts, pictures, charts, maps, drawings, programs, equipment, blueprints, vendor lists,

customer lists, all financial reports, all accounts payable/receivable information, payroll information, records, files, and other materials pertinent to Newport or its clients, may not be removed from the facilities without the advance permission of upper management.

This same level of confidentiality must be maintained regarding co-workers, employee relations matters, and Newport operations. For example, employees should make sure that all confidential papers and files are locked away at night and limit the papers that they take out of the office. Employees should not discuss confidential information in elevators, hallways, restaurants, and in any place where they may be overheard. Employees should not leave confidential documents in unattended conference rooms or behind when a conference or meeting is over.

Employees are expected to keep proprietary and confidential information secure from outside visitors and all other people who do not have a legitimate reason to see or use such information. Newport rules regarding document control, restricted access to areas of the facility, and other such procedures must be strictly observed by each employee.

If you observe a violation of this policy, you should report it immediately to your supervisor or management. Newport will investigate and take appropriate preventative and/or corrective action. Violation of this policy may result in disciplinary action, up to and including termination. Employees should refer to the Policies and Procedure Manual for much more information pertaining to Confidentiality which can be found on the company intranet

This policy does not restrict employees’ ability to discuss their terms and conditions of employment or otherwise restrict employees’ ability to engage in activities protected by the National Labor Relations Act.

CONFLICTS OF INTEREST

It is the policy of Newport to conduct its affairs in strict compliance with the letter and spirit of the law and to adhere to the highest principles of business ethics. Accordingly, conduct that conflicts with the essential enterprise-related interests of Newport and would substantially disrupt Newport’s operations is prohibited. All employees must avoid activities which are in conflict or give the appearance of being in conflict with the enterprise-related interests of Newport. The following list is not exclusive but illustrates the type of potentially compromising situations which must be avoided. Any exceptions must be reported to Human Resources and written approval for continuation must be obtained. Newport reserves the right to take any corrective action it deems necessary under the circumstances. Employees are encouraged to consult with management before engaging in any activity or relationship that might violate this policy, and more information can be found in the Policies and Procedures Manual located on the company intranet.

• Revealing confidential information to outsiders or misusing confidential information. Unauthorized divulging of confidential information is a violation of this policy whether or not for personal gain and whether or not harm to Newport is intended.

• Accepting or offering substantial gifts, excessive entertainment, favors or payments which may be deemed to constitute undue influence or otherwise be improper or embarrassing to Newport;

• Participating in civic or professional organizations that might involve divulging confidential information of Newport;

• Being involved in a supervisor/subordinate romantic or close personal relationship that might impair the employee’s ability to exercise good judgment on behalf of Newport;

• Investing or holding an outside directorship in suppliers, customers, or competing companies,

including financial speculations, where such investment or directorship might influence in any manner a decision or course of action of Newport;

• Improperly using or disclosing to Newport any proprietary information or trade secrets of any former or concurrent employer or other person or entity to whom obligations of confidentiality exist;

• Unlawfully discussing prices, costs, sales or markets with competing companies or their employees;

• Making any unlawful agreement with distributors with respect to prices;

• Improperly using or authorizing the use of any inventions which are the subject of patent claims of any other person or entity.

Each employee must take every necessary action to ensure compliance with these guidelines and to bring problem areas to the attention of management for review.

ANTI-BRIBERY AND ANTI-CORRUPTION

Newport is committed to conducting business with the highest ethical standards, free from any form of bribery or corruption. We strictly prohibit any form of bribery, including offering, giving, requesting, or receiving anything of value intended to influence the decision-making process of any individual or organization, whether in the public or private sector.

All employees, contractors, and representatives of Newport must adhere to the following principles:

• Prohibition of Bribes and Kickbacks: No employee or representative shall directly or indirectly offer, give, solicit, or accept bribes, kickbacks, or other forms of improper payments in connection with Newport’s business activities.

• Third-Party Due Diligence: Employees must exercise caution and perform due diligence when engaging third parties, such as consultants, agents, and contractors. All third-party engagements should be carefully reviewed to ensure they comply with anti-bribery and anti-corruption standards.

• Transparency and Record-Keeping: All transactions and business dealings must be accurately documented in our financial records to reflect the true nature of transactions, and comply with applicable laws and regulations.

• Reporting Violations: Employees who suspect or become aware of any bribery or corruption involving Newport must report it immediately through Newport’s reporting mechanisms, such as Newport’s Compliance Hotline. Retaliation against employees who report in good faith will not be tolerated.

• Compliance and Training: All employees are required to complete regular training on anti-bribery and anti-corruption policies to ensure adherence to this Code of Ethics and applicable laws.

Maintaining integrity and transparency in our business practices is essential to our success and reputation, and we expect all employees and business partners to uphold these standards.

CORPORATE COMPLIANCE PLAN

The Corporate Compliance Plan can be found in the Policies and Procedure Manual located on the company intranet

CONFIDENTIAL COMPLIANCE HOTLINE

The company is committed to meeting and where appropriate, exceeding all applicable regulatory and accreditation requirements, and specifically, to protecting patients’ privacy and safeguarding their personal and health information. To support these goals, we have created this Hotline for employees to report potential compromises of protected health information and other privacy and security concerns,

and violations of the law, company compliance-related policies, and/or accreditation standards. This Hotline is not for concerns related to personnel issues or other Human Resources-related reports. Those should be handled in accordance with the steps outlined in the Open-Door policy contained within this handbook.

Confidential Compliance Hotline: (833) 221-0934

TECHNOLOGICAL SECURITY

PASSWORDS AND DATA PRIVACY

It may be necessary to assign and/or change “passwords” and personal codes for e-mail, voicemail, and computers. Newport may keep a record of all passwords and codes used and/or may be able to override any such password system. These investigative measures are not intended to be unreasonably intrusive but may be necessary where there is a need to protect information, property, Newport assets, or to maintain a safe work environment. An employee has no right or expectation to privacy in electronic communication or information sent or received through Newport networks, or on PDAs issued or paid for by Newport.

Employees should not use cell phones, smart phones, iPads, cordless phones, laptops, or fax communications for communicating “confidential” or sensitive information or any “trade secrets.” (As used herein, “trade secrets” is defined as information, including a formula, pattern, compilation, program, device, method, technique, or process, that derives independent actual or potential economic value from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use, and is the subject of efforts that are reasonable under the circumstances to maintain its secrecy.)

Newport is committed to protecting personal, client, and corporate information and data privacy. Employees contribute to this commitment by demonstrating their understanding of reporting obligations for the protection of physical and electronic data, access, devices, electronic communication, and policy expectations.

INFORMATION SECURITY INCIDENT MANAGEMENT

It is the responsibility of each Newport Healthcare employee to report perceived security incidents or IT policy violations.

Anyone that suspects a potential security incident of any kind should submit the incident for review via the corporate Intranet or this link Submit a Security Incident

IT POLICY AND SECURITY TRAINING

All Newport Healthcare employees should access the company intranet to understand their employee responsibilities and acceptable use of information. All Newport Healthcare employees are responsible for the protection of all sensitive data. Employees are responsible for completing annual Security Awareness Training.

RESTRICTIONS ON COMPUTER USE

Newport provides employees with computers where appropriate. Employees may be expected to use the internet to perform their job duties. Employees may only use the internet for work-related purposes during work time. Employees should not use the internet for personal matters during work hours but may access it for personal matters on breaks or before or after work, assuming that such use is not excessive and does not interfere with the employee’s own work performance or the work performance of others.

Newport may monitor employees’ use of the internet. As such, employees should have no expectation of privacy when using Newport’s computers or networks. Newport expects employees to abide by all Newport policies and procedures when using Newport computers, including but not limited to the

prohibition on displaying, transmitting, or downloading any material in violation of Newport policies and guidelines, or that is otherwise pornographic, obscene, offensive, discriminatory, derogatory, harassing, or unlawful.

VOICEMAIL SYSTEMS

Newport’s voicemail system should be used for business-related purposes only. Newport may review, access, disclose, and monitor any and all messages sent over Newport’s voicemail system for any purpose. As such, employees should have no expectation of privacy when using Newport’s voicemail system.

VIDEO SURVEILLANCE AND GPS

The safety of Newport’s staff and clients is of the utmost concern, and we are committed to providing a safe environment for all individuals who are on our property or are in our company vehicles. One step in achieving this is the installation of video cameras in some public areas of the location. Cameras are installed at ingress and egress locations, i.e., med rooms, care coordinator offices. Each company vehicle is equipped with cameras and a GPS tracking mechanism. The cameras record activity, and the video can be viewed live or at a later time at management’s discretion.

Please note that the company reserves the right to conduct video surveillance of any public portion of its premises at any time. However, as noted, currently the video cameras are located at ingress/egress areas. Employees and clients may be subject to surveillance at any time while using any public area of Newport’s buildings and premises and should not have any expectation of privacy in Newport’s public areas. No video surveillance or recording will be conducted in any private areas such as restrooms, bedrooms, or changing rooms.

As explained above, the purpose of the Company’s surveillance and GPS systems is to protect employees’ and clients’ safety. The Company will not use information gleaned from its video surveillance system and GPS tracking to take any reprisals against employees engaging in activity protected by the National Labor Relations Act, nor are these systems intended to in any way interfere with employees’ right to engage in such activity.

Employees who have concerns or questions regarding this activity may contact their designated Human Resources representative.

INTERNET AND ELECTRONIC COMMUNICATIONS

Newport wishes to foster an environment of open communications in which you can enjoy work. We recognize that some employees spend large portions of their day at work and that there will be occasions where it will be reasonable or even necessary to use the e-mail system and/or the internet for personal and non-work communications. To that end, Newport does not prohibit all e-mail or internet usage unrelated to your work. However, such communications should be limited, should not interfere with your work performance, and must always comply with Newport’s standards of conduct and other Newport policies, practices, and guidelines.

All employees are responsible for using common sense and good judgment in visiting websites and choosing the content and recipients of e-mail messages. Your internet and e-mail usage cannot violate Newport’s policies against discrimination, harassment, solicitation, or protection of confidential, sensitive, or trade secret information. In addition, your use of the internet and e-mail may not violate applicable laws, such as copyright and trademark laws. Newport also reserves the right to inspect and

retrieve information from personal computers, phones, and other mobile devices which are regularly used to conduct Newport business. The electronic and information systems, which include all desktop and laptop computers, servers, printers, laptops, routers, other peripherals, software, and data files, are the property of Newport. An employee has no right or expectation to privacy in electronic communication or information sent or received through Newport systems. Newport reserves the right to access and review electronic files, messages, mail, and other digital archives, and to monitor the use of electronic communications as necessary to ensure that no misuse or violation of Newport policy or any law occurs.

Newport reserves the right to control e-mail and internet use for business or productivity purposes. Newport may monitor e-mail messages as a routine matter, as directed by business requirements, or in the course of an investigation triggered by indications of impropriety. Newport also reserves the right to capture and use internet correspondence, personal file directories, and other information stored on Newport computers, to support operational, maintenance, auditing, security, and investigative activities.

SOCIAL NETWORKING AND SOCIAL MEDIA

Newport acknowledges that employees may utilize the internet outside of work time or the workplace for personal business. In some circumstances, however, such use may impact Newport. Therefore, whether or not Newport’s resources or internet system are used to do so, employees publishing information on the internet in any fashion, including but not limited to websites, chat rooms, message boards, Weblogs (“blogs”), or social and/or professional networking sites such as Facebook, X, Snapchat, Instagram, TikTok, LinkedIn, etc. are expected to do so responsibly and must adhere to the following guidelines:

• Employees may not make posts or publish statements to the internet purporting to speak on behalf of Newport unless specifically authorized to do so and prominently identifying that the individual is employed by Newport

• Employees’ communications concerning Newport must not violate any Newport policies, practices, or guidelines, whether or not your status as an employee is specifically mentioned in such communication.

• Employees may not personally attack, nor post any personal information about Newport employees, clients, or vendors or make any statement or posting that violates the privacy or publicity rights of any other person.

• Employees may not post any material that is defamatory, libelous, threatening, or harassing including, but not limited to, statements concerning Newport, its partners, employees, clients, customers, and vendors. Employees are prohibited from posting any content or statements inconsistent with Newport’s anti-discrimination and harassment policy and Newport’s policy protecting confidential information.

• Employees may not disclose any sensitive, proprietary, or confidential information about Newport or any Newport client or former client.

• Employees may not state or suggest that Newport has endorsed any statement or posting by them, or otherwise attribute views or opinions expressed in such statements or postings to Newport.

• Newport’s trademarks, copyright-protected material, and other images or intellectual property owned by Newport may not be used without prior written consent.

• Employees must respect and comply with all copyright laws and terms of use on the sites to which information is published.

• Employees should not make referrals or recommendations for friends/associates if their site indicates that they are associated with Newport. It may give the appearance that Newport endorses the individual being recommended.

• Each employee is personally and legally responsible for all content that the employee may post or publish on the internet. Regardless of the employee’s position or compliance with these policies, practices, and guidelines, Newport will not indemnify any employee from legal action that may result from that employee’s personal internet use or online activities.

Newport will monitor compliance with this policy in a variety of ways, including but not limited to publicly accessible information posted, created, or exchanged on social media, without prior notice to the employee, to the extent permitted by law. Failure to comply with these policies could lead to disciplinary action up to and including termination. The above policies, practices, and guidelines are not intended to be exhaustive, and Newport reserves the right to take appropriate action in any circumstance involving an employee’s posting of content on the internet, in accordance with applicable law.

This policy is not intended to preclude or dissuade employees from engaging in activities protected by state or federal law, including the National Labor Relations Act, such as discussing wages, benefits, or other terms and conditions of employment, forming, joining, or supporting labor unions, raising complaints about working conditions for their own and their fellow employees’ mutual aid or protection, or legally required activities.

INTERNAL COMMUNICATIONS

The company utilizes multiple forms of communication to share information with employees including emails, fliers, posters, videos, staff meetings, the employee handbook, the Policies and Procedures Manual, the company intranet, and UKG. It is the employee’s responsibility to regularly check their email and to be aware of the information provided through any of these sources.

EMPLOYEE EMAIL SIGNATURE

As Newport continues to expand services to help more families, defining the company’s identity, i.e. “branding”, is increasingly important. Emails serve as an opportunity to present Newport and PrairieCare to the external world, and it is important that all employees adhere to one, consistent email signature style for each. Instructions can be found on the company intranet. Examples are as follows:

Suzie Smith (she/her) Family Therapist Newport Healthcare Empowering Lives. Restoring Families.® 555-555-1111 suzie.smith@newporthealthcare.com www.NewportHealthcare.com

CONFIDENTIALITY NOTICE: This email message, including any attachments, is protected under the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA) and 42 CFR Part 2. Further disclosure of this information is prohibited unless written consent is obtained from the person to whom it pertains. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message.

555-555-1111 suzie.smith@prairie-care.com www.prairie-care.com

CONFIDENTIALITY NOTICE: This email message, including any attachments, is protected under the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA) and 42 CFR Part 2. Further disclosure of this information is prohibited unless written consent is obtained from the person to whom it pertains. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message.

EXPENSE AND TRAVEL POLICY

The policy applies to all employees within Newport Healthcare and its subsidiaries. Directors and above may, at their discretion, impose greater control than required by this policy or may approve exceptions where necessary. There will be established periods of “mission critical” travel only. During those periods, all travel must be essential to business operations and be approved in advance by a Vice President or above.

TRAVEL EXPENSES

All employees are expected to adhere to the travel policy, which has been designed to cover the most typical expenses, while ensuring that the most cost-efficient options are selected. Employees are encouraged to check with their manager prior to incurring an expense that is questionable and may not be covered. Newport will reimburse employees for all reasonable and necessary expenses within established guidelines while traveling on authorized company business. Newport does not reimburse for personal travel expenses but may if it is a company-sponsored trip. Laundry or dry cleaning may be reimbursed if the traveler has a stay of five days or more. The employee’s manager is responsible for accurately reviewing expense reports prior to submission for reimbursement.

Non-Reimbursable Expenses

Newport assumes no obligation to reimburse employees for expenses that are not in line with the established policy. Newport will not reimburse traffic tickets or personal items including alcohol. Newport will also not reimburse for anything charged to the hotel room (e.g., use of the mini-bar, concierge, or maid service, pay-per-view movies, gift shop items, toiletries, phone calls, hotel gym, magazines, newspapers, personal items, etc.) or unreasonable or unnecessary expenses. You may have room service or a meal according to the guidelines in the meals section below.

Spouse/Companion Travel

Newport will not reimburse travel and/or entertainment expenses incurred by a spouse or other individual accompanying an employee on business unless it is a company-sponsored event, and the guest is invited or has been pre-approved.

EXPENSE REPORTING

Expense reports are an integral part of reimbursement and are required to satisfy IRS requirements for the deductibility of expenses for tax purposes. The expenses must be substantiated as to the amount, dates, place, and business purpose. An example of acceptable documentation to describe the business purpose would be “to discuss agenda for regional meeting.” Unacceptable documentation would simply state “lunch.” Entertainment and gift expenses must also establish the business relationship of the person being entertained or receiving the gift. In order to be reimbursed, the expense report must be completed properly and signed by both the employee and the employee’s manager.

Employees should report all reimbursable expenses, with the exception of relocation expenses, on an expense report that includes the required information accompanied by original itemized receipts. If an employee submits an expense report that is completed improperly or lacks any required documentation, it will be returned for correction and processing may be delayed. If returned, the employee will have to submit the corrected expense report for payment.

It is important that expense reports be submitted in a timely manner both for reimbursement to the employee as well as for accurate financial reporting for Newport. With that in mind, expense reports should be submitted within two weeks of the expense. Expense reports submitted after 30 days of expense will not be reimbursed unless extenuating circumstances exist and the VP, Controller must approve the exception.

Itemized receipts are required for all reimbursable expenses.

Original itemized receipts must be submitted with the expense report with descriptions of each expense.

Expense Reimbursement Turnaround Time

Expense reports that are complete and have proper approval are generally reimbursed within two (2) weeks of receipt in Accounts Payable.

Expense Report Form and Process

Employees are required to utilize the authorized system in place or Newport’s official Expense Report form to request reimbursement of expenses. The Expense Report form can be found on the company intranet. Use of other forms or means of reimbursement is not permitted. The Expense Report form contains instructions for the completion of the expense report, as well as a tab upon which all receipts are saved. Upon completion of the expense report, the employee is required to submit the expense report to their manager for review and approval. The manager will note any exceptions during their review and send the expense report back to the employee for correction and resubmission, if necessary. Once the expense report is approved, the manager is required to submit the expense report to Accounts Payable at: ap@newportacademy.com. Every two weeks, Accounts Payable will provide a summary of each employee’s approved expense report amounts to our payroll team, so that the expenses can be included in the employee’s paycheck for that pay cycle. While approved expenses are processed through payroll, the Company utilizes a non-taxable pay code for the expense reimbursement payment. Accordingly, the expense reimbursement is not taxed to the employee.

TRAVEL ARRANGEMENTS

Reservation Procedures

Employees must have advanced permission from their department head for business-related travel. The Company utilizes the Onriva platform for booking employee-related travel procurement. Within Onriva, an employee will establish their profile and input either their Company-issued credit card or their personal credit card information. If an employee has a Company credit card, all travel reservations should be charged to that card vs. a personal card so that the Company can take advantage of the points/rebates, etc. The Onriva booking tool will provide options for travel and associated pricing of travel alternatives. Employees are required to utilize the Onriva booking tool for all airfare, hotel and rental car reservations. Reservations must be made as early as possible and at least seven days prior to departure to take advantage of advance purchase discounts

As a general rule, employees are expected to drive if the trip is five hours or less. Use good judgment when making air travel decisions. For example, if airfare for a trip costs $800.00 and to drive the trip would take six (6) hours, you should drive unless you are pressed for time.

Airline Class of Service

All travel must be booked in coach class at the lowest logical fare. You must be willing to be flexible on departure times, flight connections, airports, etc. Newport will not reimburse airline ticket upgrades, frequent flyer upgrades, or extra leg room unless 6’2 or taller. The exception to this is if the flight time is five (5) or more hours, the employee may upgrade to business class. Otherwise, if an employee wishes to upgrade at their personal expense, they may do so.

Airline Frequent Flyer Programs

Traveling employees may retain frequent flyer program benefits. However, participation in these programs must not influence flight selection that would result in incremental costs to Newport. Employees should purchase the most cost-effective fare regardless of whether they will receive frequent flyer benefits.

Air Travel Payment Procedures

When an employee makes a reservation via Onriva, the credit card saved in each employee’s travel profile within Onriva will be used. A copy of the confirmation statement will be emailed to the employee.

Cancelled or Unused Tickets

Unused ticket credits may only be used for future company business travel. All unused airline tickets/credits will be stored in Onriva for future business travel.

LODGING

Hotel reservations should also be made through Onriva unless otherwise approved for special events. Employees should use properties in either the economy or budget to moderate categories. The maximum per hotel stay is $250 per night. Rates outside of this policy must be pre-approved by your department head.

Travelers are responsible for paying for hotel charges with their personal funds unless they possess a Company credit card. Upon completion of your trip, submit the eligible expenses on the hotel bill, via the Onriva platform or an approved Expense Report form to Newport for reimbursement.

Employees are responsible for canceling hotel rooms as soon as possible to avoid unnecessary charges. Employees will be held responsible and may not be reimbursed for “no-show” charges unless there is a good reason for the “no-show.” If canceling a hotel room yourself, be sure to get a cancellation number so as to prevent any doubt of the cancellation.

MEALS

Newport will reimburse employees for the expense of personal meals incurred when traveling for business purposes. Newport will reimburse up to $75 per day for meals plus no more than 20% gratuity. Receipts for more than one person must be provided with the names of guests listed on the back of the receipt. If the meal is a business meal, you must include the business purpose of the meeting.

GROUND TRANSPORTATION

Rental Car Guidelines

Prior to selecting a car rental, employees are expected to determine the most cost-efficient mode of local travel which can include options such as Uber, Lyft, or Turo ride sharing. After evaluating the options, if it is determined that a rental car is needed, it should be booked through Onriva. Newport has a preferred customer arrangement with Enterprise/National, which is preloaded into the Onriva travel platform, and employees are required to book rental cars through Enterprise/National to take advantage of Newport’s preferred rental rates unless some extenuating circumstance exists. All employees should enroll in the National Emeral Club program upon onboarding with Newport. If you need assistance enrolling, please contact your local HR Representative. If a car is rented for personal use prior to or after a business trip, the employee will be expected to pay for the additional days. Employees should rent a compact or intermediate car depending on the number of individuals. Groups of four (4) or more travelers may rent a full-size, four-door vehicle or minivan.

When economical and practical, employees should refuel the automobile prior to its return or request the fuel purchase option at the time of pick up. The automobile rental contract and receipts must be attached to the expense report. Newport will not reimburse additional insurance offered by the rental company. The employee will be expected to pay for the additional coverage if he/she opts to take it.

If an employee is in an accident while operating an automobile on company business, he/she must report it IMMEDIATELY to their manager and an insurance claim must be submitted through Newport’s insurance carrier, even if the traveler believes any injury or damage is minimal.

Newport does not reimburse or pay for navigational equipment. Free navigational apps are available for download. Please see your local IT representative if you need assistance with downloading the app.

Personal Car Usage Guidelines

Newport reimburses employees for the use of their personal automobiles when used for company business at the designated rate set by the IRS. Mileage that is normally driven to and from work is not reimbursed.

Employees who use their car on company business must have personal automobile insurance and the policy should contain an endorsement that states “business use.”

Parking

Parking expenses will be reimbursed. Employees should always use self-parking (versus valet) while keeping safety in mind. If employees feel their safety is at risk, then valet parking may be used.

Tolls

Toll expenses will be reimbursed. Additional costs due to passing through tolls without paying or because the laws were not understood will not be reimbursed. Toll express services through the rental car service may be purchased for convenience.

EMPLOYEE BENEFITS

Newport is committed to providing employees with a benefits program that is both comprehensive and competitive. Our benefits program offers medical, dental, and vision coverage, along with other benefits that provide financial security for our employees and their families. Benefits available to employees and the eligibility requirements for each benefit plan are described in each plan’s Summary Plan Description available from Human Resources or on the company intranet. For a detailed explanation of specific benefits, refer to each plan’s Plan Document.

Eligibility

Employees are eligible for benefits if they are a full-time employee working 30 or more hours per week.

New Employees

New employees of Newport become eligible for benefits on the first day of the month following 30 days of employment for all benefits including retirement, which is addressed under “Retirement Savings 401(k)”. Newport’s benefits operate on a calendar year, from January - December.

Open Enrollment

Benefit-eligible employees can enroll in, or make changes to, their benefit plan elections during the annual open enrollment period, which is usually held for two weeks in the last quarter of each year with benefit elections effective on January 1st the following year.

Qualified Life Event

Employees cannot change their benefit elections during the year unless they experience a qualifying life event. Qualified life events include:

• Marriage or divorce

• Death of your spouse, domestic partner, or dependent

• Birth or adoption of a child

• Your Spouse or Domestic partner terminating or obtaining new employment (that affects eligibility for coverage)

• Change in your employment status that affects benefit eligibility (working at least 30 hours per week)

• Loss of eligibility for a dependent

• Change in your residence (zip code) that prevents you from participating in a region-specific medical plan (affecting your eligibility for coverage)

The requested change must be consistent with the qualifying life event and requires documentation to be provided to the Benefits Administrator within 30 days of the event. If the change is not requested within 30 days of the event, the employee will not be able to change their elections until the next open enrollment period or after experiencing another qualified life event.

BENEFITS

• Medical – Medical coverage is currently offered with three plan options available.

• Health Savings Account (HSA) – If an employee enrolls in the High Deductible Health Plan (HDHP), they have the option to elect an HSA, which serves as a personal savings account for healthcare expenses. Whether the employee elects to contribute to this account or just open it,

Newport will contribute up to $500 for enrolled individuals, $1,000 for enrolled employee + spouse, and $1,500 for enrolled families.

• Dental and Vision – Dental and vision benefits are offered

• Flexible Spending Account (FSA) – FSA’s enable employees to put aside money for important expenses and help reduce income taxes at the same time. Funds may be used for healthcare and/or dependent care. Unless enrolled in the medical High Deductible Health Care Plan, this plan is available to eligible employees.

• Basic Life and Accidental Death & Dismemberment (AD&D) – Newport provides eligible employees basic life insurance and AD&D coverage at no cost to you.

• Supplemental Life and Accidental Death & Dismemberment (AD&D)–Employees can purchase additional coverage.

• Short-Term Disability (STD) – Employees are eligible to purchase STD insurance. If an employee is unable to work due to an illness or non-work-related injury, the employee may receive STD benefits for up to 180 days. STD benefits provide employees with 60% of their weekly salary, up to a maximum benefit of $2,500/week.

• Long-Term Disability (LTD) – Employees are eligible to purchase LTD insurance which pays a monthly benefit in the event the employee cannot work because of a long-term illness or injury. LTD provides the employee with 60% of their monthly salary up to a $10,000 monthly maximum after 180 consecutive days of a qualified non-work-related illness or injury.

• Critical Illness, Accident, and Hospital Indemnity Insurance – Employees are eligible to purchase these voluntary benefits to help offset out-of-pocket costs related to unexpected incidents.

COMMUTER ASSISTANCE

The commuter benefit plan allows employees the opportunity to set aside pre-tax money for qualified transit and parking expenses incurred while getting to and from work. This benefit can only be elected as a new hire, during open enrollment, or following a qualified life event.

ADOPTION ASSISTANCE

Adoption assistance is available to employees who complete at least 180 days of continuous service after obtaining an eligible status. This continuous service must be satisfied prior to the date of the final adoption decree(s). The benefit reimburses up to $1,500 per qualified adoption. Qualifying expenses must be incurred through private adoption or licensed adoption agencies.

EMPLOYEE ASSISTANCE PLAN

EAP is provided at no cost to the employee. This program provides employees with 24/7/365 easy-touse services to help with the everyday challenges of life. Experienced counselors provided through LifeWorks one of the nation’s premier providers of EAP services can talk to employees and provide advice for work, life, and employee well-being, to include:

• Family: Going through a divorce, caring for an elderly family member, returning to work after having a baby

• Work: Job relocation, building relationships with co-workers and managers, navigating through reorganization

• Money: Budgeting, financial guidance, retirement planning, buying or selling a home

• Legal Services: Issues relating to civil, personal and family law, financial matters, real estate and estate planning

• Identity Theft Recovery: ID theft prevention tips and help from a financial counselor if an employee is victimized

• Health: Coping with anxiety or depression, getting the proper amount of sleep, how to kick a bad habit like smoking

• Everyday Life: Moving and adjusting to a new community, grieving over the loss of a loved one, military family matters

Convenient and confidential help when employees want it, how they want it. This program includes up to five (5) phone or video consultations with licensed counselors for the employee and their eligible household members, per issue, per calendar year. Call (888) 319-7819 to speak with a counselor or schedule an appointment. When calling, just select “Employee Assistance Program” when prompted to immediately be connected to a counselor.

If an employee is simply looking for information, the program offers easy to use educational tools and resources, online and through a mobile app. Log on to metlifeeap.lifeworks.com, username: metlifeeap and password: eap. To download the app onto a mobile device, search “LifeWorks” on iTunes App Store or Google Play. Log in with the username: metlifeeap and password: eap

NEWPORT PERKS

Enjoy discounts, rewards, and perks on thousands of the brands you love in a variety of categories:

• Travel

• Entertainment

• Restaurants

• Health & Wellness

• Beauty & Spa

• Sports & Outdoors

• Auto

• Education

• Electronics

• And so much more!

RETIREMENT SAVINGS 401(K)

The 401(k) plan allows employees to invest up to 100% of their earnings on a pre-tax or after-tax basis through automatic regular payroll deductions. In addition, Newport will match a percentage of employee contributions. All employees who are at least 21 years old and who have completed 30 days of service with Newport are eligible to participate on the first day of the following month once the age and service requirements are met Additional information regarding the plan and company matching contributions can be found on the Benefits page of the company intranet and online at www.netbenefits.com or call Fidelity at 1-800-835-5097.

ANNUAL SCHOLARSHIP ESSAY CONTEST

The Newport Healthcare Center for Research and Innovation (CRI) supports the professional

development and continuing education of Newport Healthcare staff. One of the ways it does so is by offering an annual fall scholarship essay contest for all staff who are currently pursuing an academic degree. To be considered, staff must:

• Work for Newport at least part time;

• Have been enrolled in an accredited university or college during the same calendar year;

• Be seeking a degree; and

• Be in good standing with the company.

One month prior to the application deadline, an announcement will be sent to staff regarding the specific requirements for the contest. Information will also be available on the company intranet. Scholarship recipients will be announced on the first of the month after each deadline and the winning essay will be shared via an all-staff email and on the company intranet.

TUITION AND STUDENT LOAN REIMBURSEMENT ASSISTANCE

Newport recognizes the importance of an employee’s growth and encourages eligible staff to advance their level of education. These programs provide an opportunity for employees to expand their knowledge, skills, and abilities.

Tuition Eligibility

Active, full-time (30+ hours a week) employees with a minimum of one year of continuous employment with Newport are eligible. Employees must have a status of “active” with an overall satisfactory performance rating with no disciplinary/corrective actions (within six months) at the time of application approval and reimbursement of tuition. Maximum reimbursement is $1,800 per year.

Educational assistance shall be provided for courses that are directly related to the employee’s present job, or which may enhance the employee’s potential for advancement, as determined solely by Newport.

Employees interested in tuition reimbursement must complete the Employee Tuition Reimbursement Application prior to the commencement of any coursework for which the employee desires to be reimbursed. Only courses pre-approved by the employee’s manager and the Benefits team will be considered for reimbursement.

Benefit Repayment

Benefits received by employees under this policy will be subject to repayment if the employee voluntarily separates or is terminated “for cause” from Newport within one (1) calendar year of the tuition assistance payments. “For cause” is defined as fraud, embezzlement or theft, willful misconduct damaging to Newport and its reputation, intentional violation of any law or regulation, any unauthorized disclosure of any trade secret or confidential information of Newport, continued failure to perform duties owed to Newport, and being charged with a felony or a misdemeanor involving moral turpitude.

This is a voluntary benefit program which may be discontinued or modified, including the option to suspend the program for new requests, at any time, based on business considerations.

Application

1. Employee submits Employee Tuition Reimbursement Application to his/her manager prior to enrollment.

2. Application is reviewed by manager.

a. If approved, the application is forwarded to the Total Rewards Director for final approval.

b. If declined, the manager discusses the reason for denial of application with the employee.

3. Employee retains Employee Tuition Reimbursement Application and Reimbursement Form to complete after passing the course.

Reimbursement

1. Employee completes class with the minimum required grade of “B”

2. Employee submits the required documentation outlined in this policy to the benefits email.

3. Once approved, the payment is processed for reimbursement to the employee. Reimbursement will appear on the employee’s paycheck.

Student Loan Reimbursement Eligibility

This program assists employees with the financial burden associated with paying for a degree through student loans.

Active, full-time (30+ hours a week) employees with a minimum of one year of continuous employment with Newport are eligible for consideration for student loan repayment. Employees must have a status of “active” with an overall satisfactory performance rating with no recent (within six months) disciplinary/corrective actions or during the period in which payments are received.

To be eligible for consideration, a loan must be for:

• U.S. based education loan borrowed by the employee for the employee’s own education from an accredited institution.

• An undergraduate or graduate degree that directly relates to the employee’s job (as determined solely by Newport).

Repayment Requirements

Employees interested in student loan repayment must complete the Employee Student Loan Repayment Application and receive written approval.

Benefit Amount

Employees with written approval will receive a benefit of $75.00 per month ($37.50 per pay period) (maximum $900 annually) in their bi-weekly paycheck. Per IRS regulations, student loan repayment benefits are typically considered taxable; therefore, all applicable taxes will be deducted from the assistance; however, due to recent legislation, these benefits are not considered taxable income by the IRS through 2025.

Benefit Termination and Repayment

Benefits under this program will cease if an employee is subject to disciplinary/corrective actions or becomes inactive due to leave or termination. Employees returning from leave may reapply.

Benefits received by employees under this policy will be subject to repayment if the employee voluntarily separates or is terminated “for cause” from Newport within one (1) calendar year of the loan assistance payments. “For cause” is defined as fraud, embezzlement or theft, willful misconduct

damaging to the Company and its reputation, intentional violation of any law or regulation, any unauthorized disclosure of any trade secret or confidential information of the Company, continued failure to perform duties owed to the Company, and being charged with a felony or a misdemeanor involving moral turpitude.

Employees may periodically be required to provide updated documentation to demonstrate continued eligibility. Payments for loans that are in forbearance may be paused until the loan is active again.

Employees may utilize Tuition Assistance or Student Loan Repayment benefits in a calendar year, but not both.

SPEAKERS BUREAU

Support and Training to be a Presenter

Launched in 2022, the Newport Healthcare Speakers Bureau offers an annual spring event designed to provide a professional development opportunity for qualified and interested staff. It offers support and training on presentation development, presenting, and a pathway for doing so in front of an audience. Participation is considered voluntary and does not replace any current job responsibilities. Under these circumstances, non-exempt staff may not be compensated for such activities. To be considered, staff must:

• Have been with Newport for at least six months;

• Be licensed/certified (or be close to being licensed/certified); and

• Be in good standing with the company.

Presenting at Conferences

Newport supports the dissemination of knowledge and fostering a sense of community in the behavioral health field through various efforts, including coordinating with staff to present at conferences. This may involve employees, or those providing contract services for Newport Healthcare, in which case they must be in good standing with the company and agree to the following:

• A plan to be with the company at least until after the dates of presentation.

• Participation is considered voluntary and does not replace any current job responsibilities.

• In the case of a resignation, termination, or separation from the company, participation may not continue.

Interested individuals can contact the Speakers Bureau at: speakersbureau@newporthealthcare.com

TIME AWAY FROM WORK

HOLIDAYS

Newport Healthcare observes the following holidays:

• New Year’s Day

• Martin Luther King, Jr. Day

• Memorial Day

• July 4th

• Labor Day

• Thanksgiving Day

• Christmas Day

FLOATING HOLIDAY

The company also recognizes that there are other religious or cultural holidays that employees might wish to observe and therefore Newport offers one (1) floating holiday per year to allow full-time employees to take one floating holiday of their choice in conjunction with any federal, state, religious or cultural holiday or celebration.

• When requesting the Floating Holiday in UKG, employees are required to list the specific religious or cultural holiday or celebration in the comment section.

• The request must be scheduled and approved through UKG in advance by the employee’s supervisor.

• Floating holidays will not be carried over to the next calendar year, nor may they be cashed out if not taken or paid upon termination of employment.

• The floating holiday must be taken in full eight (8) hour increments.

• The holiday premium double time pay does not apply to the floating holiday.

PAID TIME AWAY BENEFITS

See state-specific addenda for state-specific paid time off policies.

FLEXIBLE TIME OFF (FTO)

The Flexible Time Off Policy (“FTO”), which is a flexible paid time off policy, applies to a designated group of leaders within the Company.

Employees are encouraged to take time off from work. This will help them avoid exhaustion and ensure they have some time to clear their minds from their work responsibilities and duties. The company will track the FTO time taken for eligible employees for records purposes only.

FTO cannot be used in increments exceeding 2 weeks (10 consecutive workdays). Any time taken off in excess of 10 consecutive days will be unpaid. Employees should never assume that a request for FTO will be granted and therefore are advised not to make any non-refundable reservations until FTO requests have been approved. For the purposes of this policy, a “workday” means a day during which the employee is not on company premises and/or is not actively engaged in company-related activities.

FTO time cannot be used in increments exceeding ten consecutive workdays for any leave provided in compliance with state or federal law, including but not limited to leave taken under the FMLA, CFRA, Pregnancy Disability Leave, Bone or Organ Donor Leave, Military Leave, Military Spouse Leave, Paid

Sick Leave (see Sick Leave policy), or any other leave given to comply with applicable law. All time taken off for any leave that qualifies under these laws in excess of ten consecutive workdays will be unpaid.

FTO is granted to employees with the express condition that eligible employees remain responsible for completing their duties in a timely manner. Therefore, employees taking FTO must meet all established goals despite the absences. With the exception of those on a legally protected leave (such as state or federal family and medical leave), if an eligible employee is unable to meet job expectations due to the use of FTO, the company reserves the right to temporarily revoke the use of FTO. Further, if gross abuse of this leave is observed, disciplinary action may be taken, which may include termination of employment.

Eligible employees must request FTO time off in UKG.

All FTO requests will be subject to supervisor or Human Resources approval and may be granted or denied to meet the operational needs of the organization and ensure that all patient needs are adequately met. All requests for FTO should be made through UKG at least 14 days in advance. Any requests not made at least 14 days in advance may not be granted unless extenuating circumstances apply.

Newport relies on its employees to contribute productively to the company’s success and profitability. Vacation is granted to certain employees with the express condition that eligible employees remain responsible for completing their duties in a timely manner. In the event an eligible employee’s FTO time begins to impede his or her performance, the employee may be counseled accordingly.

Employees who participate in the FTO program do not accrue or otherwise bank any paid time off and therefore are not paid out any balance at the time of termination of their employment.

FTO requests that are not scheduled in advance may not be approved, and time taken off under this policy that has not been approved in advance may be unpaid in accordance with and as permitted by applicable laws. Abuse of FTO time or taking FTO time off without prior approval may also lead to discipline, up to and including termination. Further, any employee whose work performance is negatively impacted by taking excessive time off will be disciplined or may have their compensation reduced due to unsatisfactory performance.

PAID PARENTAL LEAVE

The purpose of this policy is to ensure that parents have time to bond with their new child, adjust to their new family situation, and balance their professional obligations while receiving full pay for up to three weeks. This benefit is intended as a supplement where state paid family leave programs are not available.

Newport will provide three weeks of Paid Parental Leave to eligible employees for the birth or adoption of a child. To be eligible, an employee must be a regular, full-time employee who has completed one full year of continuous service and does not have a state-paid family leave plan available to them. All Paid Parental Leave must be taken within one year following the birth or adoption of the child. Paid Parental Leave under this policy will run concurrently with any applicable local, state or federal laws and this policy does not extend or provide additional leave to that which the employee is entitled to under any state or federal leave program. Employees will not receive more than 100% of their regular rate of pay during the Paid Parental Leave period.

Employees must provide at least 30 days’ notice of their intended leave to their department head. In cases where advance notice is not feasible, employees should provide as much notice as possible.

Employees are also required to complete the necessary forms and submit them to Human Resources for processing.

FAMILY AND MEDICAL LEAVE ACT (FMLA)

Newport provides up to 12 weeks of unpaid, job-protected leave for eligible employees for the following reasons:

• For incapacity due to pregnancy, prenatal medical care, or childbirth;

• To care for the employee’s child after birth, or placement for adoption or foster care;

• To care for the employee’s spouse, son, daughter, or parent who has a serious health condition; or

• For a serious health condition that makes the employee unable to perform the employee’s job.

Eligible employees whose spouse, son, daughter or parent is on covered active duty or call to covered active-duty status may use their 12-week leave entitlement to address certain qualifying exigencies. Qualifying exigencies may include attending certain military events, arranging for alternative childcare, addressing certain financial and legal arrangements, attending certain counseling sessions, and attending post-deployment reintegration briefings.

FMLA also includes a special leave entitlement that permits eligible employees to take up to 26 weeks of leave to care for a covered service member during a single 12-month period. A covered service member is:

(1) a current member of the Armed Forces, including a member of the National Guard or Reserves, who is undergoing medical treatment, recuperation or therapy, is otherwise in outpatient status, or is otherwise on the temporary disability retired list, for a serious injury or illness*; or (2) a veteran who was discharged or released under conditions other than dishonorable at any time during the five-year period prior to the first date the eligible employee takes FMLA leave to care for the covered veteran, and who is undergoing medical treatment, recuperation, or therapy for a serious injury or illness.*

* The FMLA definitions of “serious injury or illness” for current service members and veterans are distinct from the FMLA definition of “serious health condition.”

During FMLA leave, Newport will maintain the employee’s health coverage under any “group health plan” on the same terms as if the employee had continued to work. Employees must pay their portion of any insurance premium while on leave. Newport will require employees who are able to return to work but fail to do so following expiration of their leave to reimburse it for insurance premium payments made on behalf of the employee during leave. If the employee fails to do so, the coverage will be canceled back to the last date of the last payment made.

Upon return from FMLA leave, most employees will be restored to their original or equivalent positions with equivalent pay, benefits, and other employment terms, unless the employee is designated a “key employee.” Key employees may have limited reinstatement rights.

Use of FMLA leave will not result in the loss of any employment benefit that accrued prior to the start of an employee’s leave. Consistent with the other kinds of unpaid leaves offered by Newport, paid leave will not accrue during unpaid portions of an employee’s FMLA leave. As such, the employee will not receive holidays, bereavement leave, or jury duty pay during unpaid FMLA leave. Employees are eligible if they have worked for Newport for at least 12 months, have 1,250 hours of service with Newport in the previous 12 months, and if at least 50 employees are employed by Newport within 75 miles of where the Employee works.

A serious health condition is an illness, injury, impairment, or physical or mental condition that involves either an overnight stay in a medical care facility, or continuing treatment by a health care 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 or other daily activities.

Subject to certain conditions, the continuing treatment requirement may be met by a period of incapacity of more than three (3) consecutive calendar days combined with at least two (2) visits to a health care provider or one (1) visit and a regimen of continuing treatment, or incapacity due to pregnancy, or incapacity due to a chronic condition. Other conditions may meet the definition of continuing treatment.

An employee may take a maximum of 12 weeks of FMLA leave in a 12-month period, or 26 weeks for specific military family leave-related situations explained above. Newport uses a rolling 12-month period for the purpose of calculating FMLA leave.

An employee does not need to use this leave entitlement in one block. Leave can be taken intermittently or on a reduced leave schedule when medically necessary. Employees must make reasonable efforts to schedule leave for planned medical treatment so as not to unduly disrupt Newport’s operations. Leave due to qualifying exigencies may also be taken on an intermittent basis.

Newport may ask employees taking leave intermittently or on a reduced schedule for planned medical treatments to transfer temporarily to a different position with the same pay and benefits that more effectively accommodates the leave. Newport may request the same of employees who take family leave on a reduced schedule per an agreement with Newport.

Newport may require employees to use all accrued paid leave at the beginning of their FMLA leave. Employees must comply with Newport’s normal paid leave policies when using paid leave concurrently with FMLA leave. Once an employee exhausts his or her paid leave benefits, or if no paid leave benefits are available, the FMLA leave is without pay.

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, the employee must provide notice as soon as practicable and generally must comply with Newport’s normal call-in procedures.

Employees must provide sufficient information for Newport 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 member is unable to perform daily activities, the need for hospitalization or continuing treatment by a health care provider, or circumstances supporting the need for military family leave. Employees also must inform Newport if the requested leave is for a reason for which FMLA leave was previously taken or certified.

Employees also may be required to provide a certification and periodic recertification supporting the need for leave, consistent with any applicable state law. In certain circumstances, Newport may request a second or third medical opinion, which it will obtain at its own expense.

Newport may also require documentation confirming family relationship, foster care, or adoption for employees taking family leave. If the employee fails to timely provide the appropriate certification, Newport may delay or deny approval for leave. Absences that occur after leave is denied may result in disciplinary action pursuant to Newport’s attendance policy.

Employees must contact Human Resources at least two (2) days before expiration of their FMLA leave to indicate whether they are able or intend to return to work. If the leave was taken for a serious medical

condition of the employee, Newport will require a return-to-work certification from the employee’s health care provider.

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

Newport will also inform employees if leave will be designated as FMLA-protected and the amount of leave counted against the employee’s leave entitlement. Newport will also notify the employee if it determines that the leave is not FMLA-protected.

FMLA makes it unlawful for any employer to:

• Interfere with, restrain, or deny the exercise of any right provided under FMLA; and

• Discharge or discriminate against any person for opposing any practice made unlawful by FMLA or for involvement in any proceeding under or relating to FMLA.

MILITARY LEAVE

All employees are eligible for military service leave to the extent permitted by state and federal law. An employee requesting such leave must promptly submit to management a copy of the employee’s induction papers or orders.

An employee may use accrued PTO or vacation time (where applicable) at the beginning of an unpaid military duty leave. All employee benefits cease during the unpaid portion of a military duty leave unless otherwise required by law, although the employee may continue his or her participation in group health care plans sponsored by Newport pursuant to COBRA by electing to do so and by paying the full premiums. If, however, the military service is for thirty (30) or fewer days, health benefits may continue, and the employee will not be required to pay more than the employee would be required to pay if he or she were actively employed. Upon being released from active duty, an employee may be eligible to reenter Newport’s health care plan(s).

Returning service members are treated as if they have been continuously employed and will be reinstated in accordance with the applicable state or federal law governing the leave. In order to be reinstated to employment, an employee must report back to Newport within specified periods after the conclusion of his or her military service.

UNPAID LEAVE OF ABSENCE

The purpose of this policy is to allow employees a limited amount of unpaid time away from work when the company can accommodate the request. Full-time and part-time employees who have completed six (6) months of continuous service are eligible to request an unpaid leave of absence for a period of up to six (6) weeks.

If foreseeable, employees must request a personal leave in writing at least thirty (30) days before the requested time is to begin. If the leave request is necessitated by an emergency, the employee or a member of the immediate family must notify the supervisor as soon as is practical; this should be followed up with a written explanation of the nature of the leave and the expected length of the absence. In such emergency situations, the written explanation must normally be submitted within three days of the beginning of the leave.

Unpaid leave may be granted at the company’s discretion, provided the leave does not seriously disrupt the company’s operations. The request must be reviewed and approved by two (2) levels of management. Unpaid leaves are not granted until all accrued PTO or vacation time (where applicable) has been exhausted.

During an approved unpaid leave of absence, employees are responsible for making regular payments for entire insurance benefit premiums or the coverage will be canceled, and COBRA will be offered. Employees are not eligible to continue to accrue PTO or vacation time (where applicable) while they are out on an unpaid leave of absence.

Reinstatement cannot be guaranteed to employees returning from personal leave. However, the company will endeavor to place employees returning from personal leave in their former position or in a position comparable in status and pay for which they are qualified.

TIME OFF FOR VOTING

In the event that an employee does not have sufficient time outside of working hours to vote in a statewide or national election, the employee may take off enough working time to enable him or her to vote. Such time off shall be taken at the beginning or the end of the regular working shift, whichever allows for more free time, and the time taken off shall be combined with the voting time available outside of working hours. Under these circumstances, an employee will be allowed a maximum of two (2) hours on the Election Day without loss of pay. Where possible, the employee shall give their supervisor at least two (2) days’ notice that time off to vote is needed. Employees are encouraged but not required to use absentee ballot voting to avoid the need to take time off to vote.

TIME OFF TO APPEAR AS A WITNESS

Employees will be granted unpaid leave to act as witnesses upon presentation of a copy of a subpoena or other court order to their supervisor or management. The employee may use any accrued PTO or vacation time (where applicable), holiday leave, and/or sick leave if available while on witness duty.

Employees will be paid their normal wage or salary if required by a subpoena to appear in court on Newport business, upon presentation of a copy of a subpoena or other court order to their supervisors or management. However, employees will not be paid for their time off if summoned to appear in court because of a subpoena on matters not pertaining to Newport business or matters where they are personally involved in legal action.

BEREAVEMENT LEAVE

Newport provides regular full-time employees with up to three (3) days of paid bereavement leave to attend the funeral and attend to personal matters related to the death of a member of their immediate family. For the purposes of this policy, immediate family includes parents, spouse/domestic partner, children, sibling or comparable step-relation, grandparents, father/mother-in-law, son/ daughter-in-law. One (1) day will be provided for extended family.

An employee who is eligible for paid bereavement leave may also use accrued PTO or vacation time (where applicable) for a death that does not meet the criteria set forth above or for time off in excess of this policy.

You must submit a time off request for approval prior to the commencement of a bereavement leave or for any extension of the leave. While on bereavement leave, you will be paid your regular rate of pay for

each scheduled workday missed. You may be required to furnish satisfactory evidence to support your request for bereavement leave.

Should you have any questions about the information contained in this handbook, please contact your HR Representative.

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