Page 11 - Footprint Employee Handbook 2021

The Company may require any employee involved in a work-related accident occurring on or off the Company
premises, whom the Company reasonably believes may have contributed to the accident, to undergo drug and
alcohol impairment testing as soon as practicable after the accident.

Random Selection
All employees are subject to periodic unannounced drug testing on a random selection basis. The selection is truly
random, which means that employees chosen for the test may be selected again in the next selection process. All
specimen collection activities required as part of the random testing program will be conducted during regularly
scheduled working hours, or immediately before or after normally scheduled working hours. Employees will be
compensated at their normal wage for any time spent in completing such testing either just prior to or just after
regularly scheduled working hours.

Specimen Collection and Testing Procedures
“Specimen” means urine, blood, breath, saliva, hair, or other substances from the person tested.
In order to ensure testing accuracy, appropriate professional personnel will supervise the collection of urine and
blood specimens, and the specimens will be collected, handled, transported, tested, and stored in a strict chain of
custody manner. Employees and applicants tested will be required to present reliable identification (driver’s license)
to the person collecting the samples.

Laboratories that are duly approved to conduct drug and alcohol impairment testing by the National Institute on Drug
Abuse, the Department of Health and Human Services, or the College of American Pathologists will test specimens.

The Company reserves the right to test for any of the following: Marijuana metabolites, cocaine metabolites,
amphetamines, opiates, alcohol, LSD, barbiturates, benzodiazepines, propoxyphene, phencyclidine, methadone,
methaqualone, meperidine, tranquilizers, inhalants, solvents, psychoactive mushrooms, peyote, mescaline, or other
poisons. For employees testing positive, drugs will be confirmed by gas chromatography/mass spectrometry or other
methods of confirmatory analysis provided for by the National Institute on Drug Abuse, the Department of Health
and Human Services, or the College of American Pathologists (“confirmatory test”).

Employees Seeking Treatment
We support the efforts of employees who seek treatment for drug and alcohol abuse. An employee may continue
working while receiving treatment to the extent that he/she does not violate this policy.

Footprint strongly encourages employees who believe that they may have a problem with alcohol or drugs (legal or
illegal) to seek assistance before a violation of this policy is found. Footprint will make reasonable efforts to
accommodate an employee’s request for leave of absence for treatment unless the request is made subsequent to
violation of this policy. Employees who continue to work are subject to the same job performance and conduct
standards and Company policies and procedures as all employees.

Confidentiality of Test Results
Test results will be reported directly to the Human Resources Department. All drug test results shall be maintained
in a confidential manner and will only be disclosed as authorized by the test subject or as authorized, permitted, or
required by applicable law. Employees may request test results in writing to the Company’s Human Resources
Department.

Test Results
An employee whose specimen tests positive will be given the opportunity to explain the positive result in a confidential
setting upon request of the employee/applicant. If the results are due to the use of prescription drugs, the
employee/applicant will be given the opportunity to verify the prescription. If determined that the positive result is due
to the legitimate use of a prescription drug, the final result will be reported as negative. If a prescription cannot be
verified, the final result will be reported as positive.

Consequences of Positive or Altered Results
Except as provided below, any employee who tests positive on any drug or alcohol impairment test required by the
Company and who does not timely and successfully refute the test results by explanation will be subject to
disciplinary action up to and including termination of employment. Any employee who dilutes, alters, switches, or
manipulates test results will be subject to disciplinary action up to and including termination of employment.

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