Spoke Employee Handbook

Content

This handbook is designed to acquaint you with Spoke Health, and provide you with information about Spoke’s dedication to patients, to your work place, and to some of the policies affecting your employment. You are required to read, understand, and comply with all provisions of the handbook. It describes many of your responsibilities as an employee and outlines the programs developed by the Spoke to benefit employees. One of our objectives is to provide a work environment that is conducive to both personal and professional growth.

No employee handbook can anticipate every circumstance or question about policy. As we continue to grow, the need for change may arise. Spoke has the right to revise, supplement and rescind policies or portions of the handbook from time to time as it deems appropriate, in its sole and absolute discretion. Where changes can be anticipated in advance, Spoke will attempt to notify employees of such changes.

The handbook is not a contract of employment. Unless an employee has a current employment agreement signed by an executive officer of Spoke and by the employee, employment at Spoke is at-will, that is, terminable at the will of either the employee or Spoke, for any reason, at any time. Nothing in this handbook shall be construed to limit, in any way, an employee’s rights under Section 7 of the National Labor Relations Act.

Employee Handbook
Updated ___________

 About Spoke

Spoke delivers a best-in-class surgery savings and patient concierge program, designed to improve the lives of patients and their families while also reducing the cost of health care. We have developed and continue to strengthen the most important core competency: engaging and managing providers to the benefit of payers and patients.

Providers offer Spoke the lowest bundled surgical rates because we designed our program specifically to meet the needs of providers. We’ve learned that reducing the cost of health care requires that we empower providers.

By doing so, we generate sufficient savings to our clients for them to support our efforts to improve the lives of patients and their loved ones.

Mission

Our mission is to create a healthcare market in which patients and providers directly transact business, producing the greatest value on both sides of their relationship based on each party’s respective greatest needs.

Heritage and History

Spoke was established as a standalone entity in January 2016 but was originally founded in 2014 as part of Spoke, a development company that is now Spoke’s big sister. Spoke was founded by Jason Coppage and Greg Mogab to build an online consumer tool for international medical tourism, medtrip.com. MEDtrip eventually became the industry standard for all products in the international arena; you can see Jason and Greg’s impact on the industry by visiting any site focused on the international market.

Spoke pivoted to the U.S. market starting late 2015 after Richard Coyte joined Jason and Greg as a partner and co-founder.

Spoke was rebranded as Spoke Health and spun off from Spoke as a separate entity January 1, 2016.

Spoke came out of stealth mode in March 2017 after it was selected as the top healthcare startup that month, and was immediately approached by some of the largest players in the American payer market.

Normally people would write, “and the rest is history,” but for us, history is a fond memory but the future is where the fun is found.

Motto – a call to action

How are your patients doing today?!

Singular Focus – the patient

Spoke’s responsibility is to the patient. We enter a person’s life at a time of anxiety and perhaps great fear, fear for their wellbeing and that of their family’s; fear of trying to navigate a complex healthcare and insurance system; and fear of the financial burdens of such an expensive medical event and the fact that no one can tell him or her what they will ultimately pay.

Our job – your job – is alleviate as much of that fear as possible and, if we’re lucky, provide some comfort. You can do that because:

  • you’re only offer is to be helpful:
    • you are not trying to sell them something,
    • your only focus is on helping them and their loved ones;
  • you give them confidence they are making wise choices:
    • you understand the system and can clearly explain the patient’s options and
    • your only focus is on helping them and their loved ones not the interests of their employer or their health plan or their physicians;
  • and you guarantee exactly what the patient will pay:
    • you are not estimating their out-of-pocket,
    • you are promising the patient will not receive a bill after the surgery that their health plan will not cover, and
    • depending on the client, you can actually offer financial assistance through Spoke’s incentive program.

Strategic Goals

Spoke will accomplish its mission by relentlessly pursuing and continuously achieving its strategic goals:

  • Make patients aware of the power they have in the healthcare market;
  • Help them use that power;
  • Empower providers to run their businesses in the way they believe delivers the highest quality of care as well as maximizing a return on their investments;
  • Create an environment in which patients and providers truly understand their respective best interests;
  • Facilitate transactions that strike a balance between a provider’s obligation to deliver the highest quality of care and a patient’s responsibility for their own health and wellness;
  • Raise awareness that self-insured employers are the most powerful healthcare “shoppers” and could have tremendous influence on the direction of our healthcare system, while also significantly reducing their healthcare spend; and
  • Reach an audience within both the patient and the provider populations sufficient to push the market to the tipping point to an efficient, consumer-driven marketplace.

WE ACHIEVE THESE GOALS BY…

FOCUSING ON THE NEEDS OF OUR PATIENTS

Code of Conduct

Spoke believes in conducting business honestly, ethically and responsibly. As a company, and as individuals, we must always act with integrity and conduct our business with respect and compassion. Our customers and the people we serve trust us to do the right thing, and you play an important role in protecting these relationships.

Inclusive Behaviors

Spoke is committed to diversity and inclusion. In order to reinforce this commitment, annual performance appraisals must include an assessment of each individual’s (staff member’s) attention to diversity and inclusion. Examples of some behaviors that support diversity and inclusion are noted below. Appropriate/applicable expectations and behaviors exhibited that could be noted in an employee’s annual performance appraisal may vary based on position, especially between manager and non-manager roles.

Inclusiveness:

  • Values and supports differences in others, contributing to an inclusive work environment.
  • Demonstrates the ability and willingness to communicate effectively with people of diverse backgrounds and experiences to create a collaborative, collegial, and caring community.
  • Increases cooperation, honesty, openness and a welcoming environment for all and speaks up when others are being excluded or treated inappropriately.
  • Is sensitive to varying communication styles and cultural norms.
  • Actively supports work/life integration in the workplace.
  • Demonstrates a willingness to listen to and accept new ideas, alternatives and perspectives.
  • Acknowledges the support and contributions of others in achieving results.

Interpersonal Communication:

  • Establishes rapport; builds and maintains effective working relationships
  • Actively listens to others; seeks to understand and then to be understood
  • Uses diplomacy and tact; can diffuse high-tension situations comfortably
  • Handles disagreement or conflict respectfully, working towards a mutually agreeable solution.
  • Demonstrates empathy and compassion for others
  • Respects others and their differences

Teamwork/Collaboration:

  • Shows respect, compassion and empathy for others, even in difficult situations, and builds an environment of trust.
  • Works effectively and cooperatively with others, willingly admitting mistakes and offering apologies.
  • Acknowledges the support and contributions of others, involving them as appropriate when outcomes will impact their work.
  • Has a positive attitude and understands how his/her behaviors impact others.

Adaptability:

  • Anticipates and adapts to changing priorities and additional demands.
  • Is flexible, open and receptive to new information, ideas and approaches.
  • Embraces, promotes and implements change.
  • Modifies one’s preferred way of doing things when it benefits the whole, focusing on long-term vision rather than short-term gains.
  • Is self-aware; seeks and acts upon performance feedback.
  • Seeks and acts on opportunities for development; takes measures to ensure personal well-being and balance.

Innovation:

  • Shows foresight and imagination to see possibilities, opportunities and trends.
  • Identifies opportunities in challenges and shows initiative to make changes.
  • Demonstrates innovative, creative and informed risk taking.
  • Looks for advancement in products, processes, services, technologies or ideas.
  • Engages, involves and obtains input from a diverse audience to ensure diverse perspectives are considered.

Managing & Developing People:

  • Involves team members in team initiatives and decision making as appropriate.
  • Considers and accepts diverse input and perspectives.
  • Communicates important information and decisions in a timely manner.
  • Recognizes and develops talent.
  • Provides helpful and timely feedback.
  • Delegates and provides good exposure for their team members.
  • Makes work challenging, meaningful, and engaging for their team.
  • Supportive of opportunities for team members’ professional growth and development.
  • Attends topical training (e.g. unconscious bias training), applies learning to evolving assignments.
  • When hiring for an open position, takes actions to increase diversity of candidate pool.

Demonstration of these attributes, or lack thereof,
is a central component to performance reviews and promotions.

Social Responsibility and Corporate Citizenship

Spoke’s Corporate Social Responsibility (CSR) policy refers to our responsibility toward our environment. Spoke’s existence is not lonely. It’s part of a bigger system of people, values, other organizations and nature. The social responsibility of a business is to give back to the world just as it gives to us.

What is corporate social responsibility?

Spoke’s CSR policy outlines our efforts to give back to the world as it gives to us.

Policy elements

We want to be a responsible business that meets the highest standards of ethics and professionalism.
Our social responsibility falls under two categories: compliance and proactiveness. Compliance refers to Spoke’s commitment to legality and willingness to observe community values. Proactiveness is every initiative to promote human rights, help communities and protect our natural environment.

Legality.

Spoke as a company as well as a group of conscientious world citizens, will:

  • Respect the law
  • Honor its internal policies
  • Ensure that all its business operations are legitimate
  • Keep every partnership and collaboration open and transparent

Business ethics

We’ll always conduct business with integrity and respect to human rights. We’ll promote:

  • Safety and fair dealing
  • Respect toward the consumer
  • Anti-bribery and anti-corruption practices

Examples of Corporate Social Responsibility

Protecting the environment
Spoke recognizes the need to protect the natural environment. Keeping our environment clean and unpolluted is a benefit to all. We’ll always follow best practices when disposing garbage and using chemical substances. Stewardship will also play an important role.

Protecting people
We’ll ensure that we:

  • Don’t risk the health and safety of our employees and community.
  • Avoid harming the lives of local and indigenous people.
  • Support diversity and inclusion.

Human rights
Spoke is dedicated to protecting human rights. We are a committed equal opportunity employer and will abide by all fair labor practices. We’ll ensure that our activities do not directly or indirectly violate human rights in any country (e.g. forced labor).

Proactiveness
Spoke will not wait for others to act but, rather, will always strive to identify opportunities to contribute and a leader by summoning, and collaborating with all stakeholders to identify and implement comprehensive solutions.

Donations and aid
Spoke may preserve a budget to make monetary donations. These donations will aim to:

  • Advance the arts, education and community events.
  • Alleviate those in need.

Volunteering
Spoke will encourage its employees to volunteer. They can volunteer through programs organized internally or externally. Spoke may sponsor volunteering events from other organizations.

Preserving the environment
Apart from legal obligations, Spoke will proactively protect the environment. Examples of relevant activities include:

  • Recycling
  • Conserving energy
  • Organizing reforestation excursions
  • Using environmentally-friendly technologies

Supporting the community
Spoke may initiate and support community investment and educational programs. For example, it may begin partnerships with vendors for constructing public buildings. It can provide support to nonprofit organizations or movements to promote cultural and economic development of global and local communities.

Learning
We will actively invest in R&D. We will be open to suggestions and listen carefully to ideas. Spoke will try to continuously improve the way it operates.

You Are Empowered

When you see an opportunity for Spoke, either as a company or as a group of empowered citizens, to positively impact our local or global community, raise your hand and lead us to take action. You will have our support!

Demonstration of these attributes, or lack thereof,
is a central component to performance reviews and promotions.

No Contract, Employment At-will, Purpose, Additional Documents

Contractual Disclaimer

Spoke does not intend that anything in this Handbook constitute an employment contract or an offer of an employment contract, express or implied, or that this Handbook be in any way deemed by any person, including Spoke or any employee, to create any legally binding rights to continuing employment or to specific terms or conditions of employment.

Employment At Will

Employees of Spoke are not hired for any specific term. Accordingly, their employment relationships with Spoke are “at will” relationships. Employment at will means that employees are free to resign from their positions at any time, with or without cause, upon oral or written notice to Spoke. Similarly, Spoke may end the employment relationship with any employee or change an employee’s status (for example, modify a position, promote or demote an employee, adjust compensation, etc.), with or without cause, for any reason or no reason, subject only to applicable laws (such as the laws against discrimination), upon oral or written notice to the employee. The decision to stay or to leave, whether it is the employee’s decision or the decision of Spoke, is in the sole discretion of the party making that decision.

No persons other than a Spoke executive can enter into an agreement for employment for a specified period of time, or make any agreement or representation contrary to this employment at will policy. Further, any such agreement must be in writing and signed by either the President.

Purpose of the Employee Handbook

On behalf of your colleagues, we welcome you to Spoke and wish you every success here.

We believe each employee contributes directly to Spoke’s growth and success, and we hope you will take pride in being a member of our team.

This handbook is designed to acquaint you with the organization and provide you with information about working here. The handbook is not all-inclusive, but it is intended to provide you with a summary of some of the organization’s guidelines.

The policies and procedures are not to be construed as restrictions on individual rights and prerogatives, but as safeguards and guidelines for the attainment of the objectives of a harmonious and orderly organization. The language used in this handbook and any verbal statements made by management are not intended to constitute a contract of employment, either express or implied, nor are they a guarantee of employment for a specific duration. Although disciplinary actions are expressly indicated for violations of the provisions of these rules, the intent is prevention of infractions rather than administration of penalties.

Any suggestions, recommendations, questions or feedback on the policies and procedures specified in this manual are welcome. Please feel free to discuss them with your manager.

These policies and procedures apply to all areas of operations within Spoke Health and related entities. These policies are in effect as of the May 1, 2017. HR policies must be kept current and relevant. Therefore, from time to time it will be necessary to modify and amend some sections of the policies and procedures, or for new procedures to be added. All such amendments shall be properly disseminated to all employees. It is the responsibility of every employee to be updated with all future changes and enhancements of these policies.

Personnel Records

Spoke may maintain personnel files on each employee. These files contain necessary job-related documentation regarding the employee’s employment with Spoke, and are the sole property of Spoke. Employees must promptly report any change of name, address, telephone number and/or family status (births, marriage, death, divorce, legal separation, etc.), legal resident status and emergency contact information to Human Resources. One of the reasons to report all such changes immediately is that an employee’s income tax status and benefits may be affected by these changes.

Personnel files belong to Spoke and may not be removed from the premises. Upon request, Spoke allows each employee to inspect and obtain a copy of any part of his or her own personnel file annually. (A former employee may also inspect and copy his or her personnel file once after termination of employment.) Requests to inspect the personnel file should be made to Human Resources, who will schedule a convenient time for the review. The files must be reviewed in the presence of a person responsible for managing Spoke’s personnel data. The employee or former employee will be required to pay the reasonable cost of any copies made. By law, certain types of documents may be withheld, such as documents legally required to be maintained in a separate file, documents pertaining to confidential reports from previous employers, documents pertaining to an active criminal, disciplinary, or regulatory investigation, and documents that identify any person who made a confidential accusation against the employee making the request.

Security of Protected Health Information

Spoke has adopted a policy that protects the privacy and confidentiality of protected health information (PHI) whenever it is used by company representatives. The private and confidential use of such information will be the responsibility of all individuals with job duties requiring access to PHI in the course of their jobs.

Definition of Protected Health Information
PHI refers to individually identifiable health information received by the company’s group health plans or received by a health care provider, health plan or health care clearinghouse that relates to the past or present health of an individual or to payment of health care claims. PHI information includes medical conditions, health status, claims experience, medical histories, physical examinations, genetic information and evidence of disability.

The HIPAA Compliance Officer
The company has designated the corporate benefits plan director as the HIPAA compliance officer (HCO), and any questions or issues regarding PHI should be presented to the HCO for resolution. The HCO is also charged with the responsibility for:

  • Issuing procedural guidelines for access for PHI.
  • Developing a matrix for personnel who will need access to PHI.
  • Developing guidelines for describing how and when PHI will be maintained, used, transferred or transmitted.

Annual Activities Necessitating Use of PHI
Annually or more frequently as necessary, Spoke performs enrollment, changes in enrollment and payroll deductions; provides assistance in claims problem resolution and explanation of benefits issues; and assists in coordination of benefits with other providers. Some or all of these activities may require the use or transmission of PHI. Thus, all information related to these processes will be maintained in confidence, and employees will not disclose PHI from these processes for employment-related actions, except as provided by administrative procedures approved by the HCO. General rules follow:

Disclosures that do not qualify as PHI-protected disclosures include:

  • Disclosure of PHI to the individual to whom the PHI belongs.
  • Requests by providers for treatment or payment.
  • Disclosures requested to be made to authorized parties by the individual PHI holder.
  • Disclosures to government agencies for reporting or enforcement purposes.
  • Disclosures to workers’ compensation providers and those authorized by the workers’ compensation providers.
  • Information regarding whether an individual is covered by a plan for claims processing purposes may be disclosed.
  • Information external to the health plan is not considered PHI if the information is being furnished for claims processing purposes involving workers’ compensation or short- or long-term disability and medical information received to verify Americans with Disabilities Act (ADA) or Family and Medical Leave Act (FMLA) status.

Records Retention

Personnel records and disclosures of PHI will be maintained for a period of six years as required by federal law, unless a state law requires a longer retention period. Records that have been maintained for the maximum interval will be destroyed in a manner to ensure that such data are not compromised in the future in accordance with the company record destruction policy.

Additional Policy Documents YOU MUST READ

In addition to the information provided in this handbook, employees are responsible for adhering to the policies contained in Spoke’s Information Security Policies and Procedures (“ISPP”). You can find a copy at https://policy.spokehealth.com, and you can request a copy from your supervisor.

Hiring

Equal Opportunity Employer

Spoke is dedicated to the principles of equal employment opportunity in any term condition or privilege or employment.

Spoke provides equal employment opportunities (EEO) to all employees and applicants for employment without regard to race, color, religion, sex, national origin, age, disability or genetics. In addition to federal law requirements, Spoke complies with applicable state and local laws governing nondiscrimination in employment in every location in which Spoke has facilities. This policy applies to all terms and conditions of employment, including recruiting, hiring, placement, promotion, termination, layoff, recall, transfer, leaves of absence, compensation and training.

Spoke expressly prohibits any form of workplace harassment based on race, color, religion, gender, sexual orientation, gender identity or expression, national origin, age, genetic information, disability, or veteran status. Improper interference with the ability of Spoke’s employees to perform their job duties may result in discipline up to and including discharge.

Immigration Law

Pursuant to applicable state and federal laws, Spoke employs only United States citizens and aliens who are authorized to work in the United States, and Spoke does not discriminate on the basis of citizenship or national origin. Each new employee must complete a Form I-9 and present documentation specified on the Form I-9 to verify his or her identity and employment eligibility. Former employees who are rehired must also complete a Form I-9. If the documentation provided by the employee when completing the Form I-9 includes an expiration date for when employment eligibility expires, the employee must present Spoke with new or updated documentation verifying his or her identity and continued employment eligibility and must update the Form I-9 before the date employment eligibility expires. An employee who misrepresents information about his or her eligibility for employment may be subject to disciplinary action up to and including discharge. If a new employee is unable to provide the necessary documentation within three (3) working days from the date of hire, he/she must provide proof that he/she has applied for the required documents. If this is not provided, the employee will be terminated.

Americans with Disabilities Act

The Americans with Disabilities Act (ADA) and the Americans with Disabilities Amendments Act (ADAAA) are federal laws that require employers with 15 or more employees to not discriminate against applicants and individuals with disabilities and, when needed, to provide reasonable accommodations to applicants and employees who are qualified for a job, with or without reasonable accommodations, so that they may perform the essential job duties of the position.

It is the policy of Spoke to comply with all federal and state laws concerning the employment of persons with disabilities and to act in accordance with regulations and guidance issued by the Equal Employment Opportunity Commission (EEOC). Furthermore, it is Spoke policy not to discriminate against qualified individuals with disabilities in regard to application procedures, hiring, advancement, discharge, compensation, training or other terms, conditions and privileges of employment.

Procedures Related to the ADA

When an individual with a disability requests accommodation and can be reasonably accommodated without creating an undue hardship or causing a direct threat to workplace safety, he or she will be given the same consideration for employment as any other applicant. Applicants who pose a direct threat to the health, safety and well-being of themselves or others in the workplace when the threat cannot be eliminated by reasonable accommodation will not be hired.

Spoke will reasonably accommodate qualified individuals with a disability so that they can perform the essential functions of a job unless doing so causes a direct threat to these individuals or others in the workplace and the threat cannot be eliminated by reasonable accommodation or if the accommodation creates an undue hardship to Spoke. Contact human resources (HR) with any questions or requests for accommodation.

All employees are required to comply with Spoke’s safety standards. Current employees who pose a direct threat to the health or safety of themselves or other individuals in the workplace will be placed on leave until an organizational decision has been made in regard to the employee’s immediate employment situation.

Individuals who are currently using illegal drugs are excluded from coverage under Spoke ADA policy.

The HR department is responsible for implementing this policy, including the resolution of reasonable accommodation, safety/direct threat and undue hardship issues.

Terms Used in This ADA Policy

As used in this ADA policy, the following terms have the indicated meaning:

Disability: A physical or mental impairment that substantially limits one or more major life activities of the individual, a record of such an impairment, or being regarded as having such an impairment.

Major life activities: Term includes caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating and working.

Major bodily functions: Term includes physical or mental impairment such as any physiological disorder or condition, cosmetic disfigurement or anatomical loss affecting one or more body systems, such as neurological, musculoskeletal, special sense organs, respiratory (including speech organs), cardiovascular, reproductive, digestive, genitourinary, immune, circulatory, hemic, lymphatic, skin and endocrine. Also covered are any mental or psychological disorders, such as intellectual disability (formerly termed “mental retardation”), organic brain syndrome, emotional or mental illness and specific learning disabilities.

Substantially limiting: In accordance with the ADAAA final regulations, the determination of whether an impairment substantially limits a major life activity requires an individualized assessment, and an impairment that is episodic or in remission may also meet the definition of disability if it would substantially limit a major life activity when active. Some examples of these types of impairments may include epilepsy, hypertension, asthma, diabetes, major depressive disorder, bipolar disorder and schizophrenia. An impairment, such as cancer that is in remission but that may possibly return in a substantially limiting form, is also considered a disability under EEOC final ADAAA regulations.

Direct threat: A significant risk to the health, safety or well-being of individuals with disabilities or others when this risk cannot be eliminated by reasonable accommodation.

Qualified individual: An individual who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires.

Reasonable accommodation: Includes any changes to the work environment and may include making existing facilities readily accessible to and usable by individuals with disabilities, job restructuring, part-time or modified work schedules, telecommuting, reassignment to a vacant position, acquisition or modification of equipment or devices, appropriate adjustment or modifications of examinations, training materials or policies, the provision of qualified readers or interpreters, and other similar accommodations for individuals with disabilities.

Undue hardship: An action requiring significant difficulty or expense by the employer. In determining whether an accommodation would impose an undue hardship on a covered entity, factors to be considered include:

  • The nature and cost of the accommodation.
  • The overall financial resources of the facility or facilities involved in the provision of the reasonable accommodation, the number of persons employed at such facility, the effect on expenses and resources, or the impact of such accommodation on the operation of the facility.
  • The overall financial resources of the employer; the size, number, type and location of facilities.
  • The type of operations of Spoke, including the composition, structure and functions of the workforce; administrative or fiscal relationship of the particular facility involved in making the accommodation to the employer.

Essential functions of the job: Term refers to those job activities that are determined by the employer to be essential or core to performing the job; these functions cannot be modified.

The examples provided in the above terms are not meant to be all-inclusive and should not be construed as such. They are not the only conditions that are considered to be disabilities, impairments or reasonable accommodations covered by the ADA/ADAAA policy.

Employee Classifications

For purposes of salary administration, eligibility for overtime wages, and employee benefits, Spoke classifies its employees as follows:

At-Will Employees. Spoke employees are employed “At-Will.” This means that either the employee or Spoke may terminate the relationship with or without cause at any time, and without advance notice, procedure, or formality. Spoke’s At-Will employment policy may be modified only by a written contract signed by Kate Brown or Greg Powers.

Full-Time Personnel. employees who are regularly scheduled to work a minimum of 40 hours per week. Full-time regular employees are eligible for all legally required benefits (e.g. social Security, unemployment, workers’ compensation insurance) as well as the voluntary benefits Spoke is able to offer its employees in similar positions.

Part-Time Personnel. employees who are regularly scheduled to work fewer than 40 hours per week. Part-time employees receive all legally required benefits (e.g. social Security, unemployment, workers’ compensation insurance), but, except as specifically provided in this Handbook or in any benefits policies, part-time employees may not be eligible for all of the voluntary benefits Spoke offers to its regular full-time employees.

Salaried Personnel. employees who are paid a set annual salary, so their pay for each pay period will be based on a pro rata portion of their annual salary, subject to any applicable withholdings and reductions (e.g. for taxes, FICA) or additions (e.g. overtime pay for nonexempt salaried employees). Certain Salaried Personnel are exempt from overtime laws depending on their duties.

Hourly Personnel. employees who are paid by the hour, so their pay depends on the number of hours they work during a pay period. Hourly Personnel are generally considered “nonexempt” from overtime laws, with some exceptions. Hourly Personnel are hired to work a specific number of hours per week, and, if they work more than 40 hours in any work week, they are entitled to overtime pay (see policy Overtime: Exempt/Nonexempt Personnel, below).

Temporary Personnel. full-time or part-time employees whom Spoke employs for a specific period of time and are not expected to establish a continuity of service. Temporary employees are not regular employees and are not eligible for benefits except those required by law. Temporary employees whose employment continues past any initially stated time period do not in any way become regular or have any other change in their status as temporary employees unless and until they receive written notice of a change.

Overtime: Exempt/Nonexempt Personnel. Each employee is either “nonexempt” or “exempt” under applicable federal and state wage and hour laws. Spoke will pay overtime wages to nonexempt employees who work more than 40 hours in any given work week, excluding meal periods. Exempt employees do not receive overtime because the overtime provisions of federal and state wage and hour laws do not apply to the types of jobs they hold. Spoke may need nonexempt employees to work overtime on occasion. Employees will receive advance notice of necessary overtime whenever reasonably possible. An employee’s supervisor must approve all overtime work in advance. The standards for who is exempt or nonexempt change from time to time; the current laws are described in materials posted in the lunch room area. Employees with questions about their status as exempt or nonexempt should check with their supervisor or management. Only a written notice from management may change an employee’s exempt or nonexempt status.

Paid Interns. temporary employees and must abide by all Company policies. Generally, Paid Interns will work part-time and will be paid an hourly wage. Paid Interns are not entitled to receive any benefits, with the exception of those mandated by local, state, and federal laws.

The Hiring Process

Spoke adheres to a strict hiring process, which is outlined “Recruiting and Hiring Procedures” available at https://recruiting.spokehealth.com. That document also provides templates required for each stage of the process.

Orientation and Training

Spoke will invest in you as soon as you become our colleague. That includes an extensive orientation and training program. Some of the content of the session will depend on your roles and responsibilities, while other parts will be applicable to all employees.

A description of that program can be found at https://training.spokehealth.com.

Compensation Procedures

Payroll Procedures

Spoke processes payroll on a semimonthly cycle (twice per month). Pay days generally fall on the 2nd and 17th of each month. All required deductions, such as federal, state and local taxes, and all authorized voluntary deductions will be withheld automatically from the employee’s paychecks. Please refer to the payroll calendar posted in the employee break room.

Employees should review their paychecks for errors. If a mistake is found, you should bring the paycheck error to the attention of your supervisor within two (2) days of being issued. If Spoke determines an error was in fact made, the error will be corrected.

Spoke prohibits improper deductions from an exempt employee’s salary except under the circumstances set forth in the federal Fair Labor Standards Act (“FLSA”) and/or state law. If an employee believes that an improper deduction has been made from his/her paycheck, the employee must bring this to the attention of management as soon as possible. If an improper deduction was made, Spoke will reimburse the exempt employee for the amount improperly deducted.

No cash advances will be given to any employee except in extremely rare circumstances and only with advance written approval of Kate Brown or Greg Powers. If an employee quits, resigns, or abandons his or her employment, unless other arrangements are made, the employee’s final paycheck will either be: (1) direct deposited into the bank account previously identified by the employee; (2) will be available for pickup on the next regular payday at Spoke’s offices; or (3) will be mailed to the employee at his/her last known address listed in the employee’s personnel file.

Workweek

For purposes of these pay procedures, a “workweek” begins at 12:00 a.m. each Sunday and ends at 11:59 p.m. the following Saturday.

Overtime Pay Procedures

It is Spoke’s policy that Nonexempt Personnel are not to work overtime unless approved the employee’s supervisor in writing in advance. Although Spoke will pay employees for any unauthorized overtime worked, working unauthorized overtime may result in disciplinary action, up to and including termination.

Nonexempt Employees will be paid overtime at the rate of one and one-half (1 ½) times the employee’s regular rate of pay for hours actually worked (excluding meal periods, uncompensated breaks or paid holidays) in excess of: (1) forty (40) hours per week; (2) twelve (12) consecutive hours worked per workday; or (3) twelve (12) consecutive hours worked without regard to the starting and ending time of the workday.

Garnishments

Garnishment of wages can result when an unpaid creditor has taken the matter to court. A garnishment is legal permission for creditors to collect part of an employee’s net disposable wages directly from Spoke before an employee receives it. Spoke is required by law to carry out the court’s order.

In the case of garnishment, Spoke will respond to wage inquires made by the court in accordance with the law. A copy of “The Request for Garnishment and Wage Information” form, which explains the details of the garnishment and how it affects wages, will be mailed to the employee and the creditor’s attorney. Employees are encouraged to resolve these matters privately to avoid Spoke’s involvement.

Leaves and Breaks

Paid Vacation

Only Full-Time, Salaried Personnel (exempt and nonexempt) may be eligible for paid vacation and sick leave. Part-time Personnel are not eligible for paid vacation or sick leave.

Full-Time Salaried Personnel are eligible to earn up to 5.00 hours of paid vacation leave per pay period, which, over a full year, equals fifteen (15) paid vacation days. Vacation pay is paid at the employee’s regular daily wage.

Spoke requires that eligible employees submit a written request for vacation leave to their supervisor as soon as possible prior to the start of his or her vacation. The grant or denial of a request for vacation leave will depend on the timeliness of the request, the number of employees available to cover for the employee in his or her absence, and other factors as determined in the sole discretion of Spoke.

Any accrued but unused vacation days will be paid to employees when their employment with Spoke terminates.

Paid Sick Leave

Only Full-Time Salaried Personnel (exempt and nonexempt) may be eligible for paid sick leave. Part-time Personnel are not eligible for paid sick leave.

Full-Time Salaried Personnel are eligible to earn 1.67 hours of paid sick leave per pay period, which, over a full year, equals five (5) paid sick days. Sick leave pay is paid at the employee’s regular daily wage.

Accrued sick leave must be used in the year it is earned, and unused sick leave will not be carried over to the following year. *Unused sick leave will not be paid upon termination of employment.

To use accrued sick leave, the employee must make a request to his or her supervisor as soon as is reasonably possible. For an employee’s own illness for which three (3) or more sick days are used, Spoke, in its sole discretion, may request the employee to provide certification from his or her health care provider verifying their health condition.

* Employees that reside in California (or in other states that require carry over) may carry over accrued paid sick leave to the following year of employment. This leave time is be capped at 48 hours or 6 days.

Holidays

All Full-Time Personnel are eligible for at least seven (7) paid holidays each calendar year, such days to be determined annually by Spoke. There may be 1-2 additional paid holidays depending on the calendar and the production schedule. If an employee desires time off for purposes of religious observances on days that are not observed as holidays by Spoke, Spoke will make reasonable efforts to accommodate this. Full-Time Personnel will be paid for an eight (8) hour shift. However, these hours are not included when calculating an employee’s eligibility for overtime pay during the week of a paid holiday. Part-Time Personnel are not eligible for paid holidays.

Jury Duty

Spoke encourages employees to fulfill their civic responsibilities by serving on jury duty when required. If an employee is required to report for jury duty, the employee must present the jury summons to his or her supervisor as soon as possible after it is received so that arrangements can be made for the employee’s absence. Employees who are selected to sit on a jury must notify their supervisor of that fact and the estimated length of the trial as soon as possible. Employees must notify their supervisors when they are released from jury duty so they can be scheduled for their return to work. Employees are expected to report for work whenever the court schedule permits. An employee’s pay during the period of his or her absence for jury duty will be in accordance with applicable state or federal law.

Bereavement/Funeral Leave

Up to three (3) days of paid leave per calendar year will be allowed in case of the death of an employee’s spouse (including a civil union partner), child, parent, parent-in-law, sibling, brother-in-law, sister-in-law, grandparent, or grandchild. Employees must provide notice to their supervisor of their intent to take funeral leave so arrangements can be made for the employee’s absence.

For Salaried Personnel eligible for paid vacation or sick leave, the three days of paid leave will not count against the employee’s accrued and unused vacation or sick leave. The three days of paid leave will not be carried over from year to year.

Military Duty Leave

Spoke complies with all applicable laws governing leaves for military service. Employees should check with Human Resources if they have any question about military leave.

Personal Leave for Protection from Domestic Abuse or Violent Crimes

Any employee who has been employed full time for at least twelve (12) months and who is the victim of domestic abuse, stalking or sexual assault, as defined by applicable law, or any other crime that a court finds to be an act of domestic violence, may request or take up to three (3) working days of leave from work in any twelve (12) month period, without pay. Leave under this policy is only allowed if the employee is using the leave to protect himself or herself by:

  • seeking a civil protection order to prevent domestic abuse;
  • obtaining medical care or mental health counseling or both for himself or herself or for his or her children to address physical or psychological injuries resulting from the act of domestic abuse, stalking, or sexual assault or other crime involving domestic violence;
  • making his or her home secure from the perpetrator of the act of domestic abuse, stalking, or sexual assault or other crime involving domestic violence or seeking new housing to escape the perpetrator; or
  • seeking legal assistance to address issues arising from the act of domestic abuse, stalking, or sexual assault or other crime involving domestic violence and attending and preparing for court-related proceedings arising from the act or crime.

Whenever possible, except in cases of imminent danger to the health or safety of the employee or the employee’s children, anyone seeking leave under this policy must provide Spoke with reasonable advance notice of the need for this leave. Spoke, in its sole discretion, may require employees who request this leave to provide copies of documents confirming the reason for their request, such as police reports or court orders confirming the underlying facts. Request for such leave shall be made to Human Resources. Spoke shall keep all information related to the employee’s leave pursuant to this policy, and the reasons for such leave, confidential to the extent reasonably possible.

Employees who have any concern about domestic abuse, stalking, or any other violent or threatening crime should immediately talk with their supervisor or other management personnel or Human Resources about their concerns and how this leave policy works. Spoke shall keep all information related to the employee’s concerns confidential to the extent reasonably possible. Any employee who obtains a restraining order against anyone else based on any violence or threatened violence should promptly report that to Spoke and provide Spoke with a copy of the order.

Family and Medical Leave

Spoke’s family and medical leave is available to employees with at least 12 months of service and who have worked at least 1,250 hours within the preceding 12-month period. If eligible, an employee may be able to take up to 12 weeks of unpaid leave during a 12-month period for the following reasons:

  • The birth of a child or to care for a child within the first 12 months after birth;
  • The placement of a child with the employee for adoption or foster care and to bond with and care for the child (within the first 12 months of placement);
  • To care for an immediate family member who has a serious health condition;
  • For a serious health condition that makes the employee unable to perform the functions of his/her position; or
  • If the employee experiences a qualifying exigency that arises out of the fact that a spouse, parent, or child has been called to or is on active duty in the Armed Forces.

Injured Service Member Leave. An employee who is the spouse, parent, child, or next of kin of a member of the Armed Forces who was injured in the line of duty (“injured service member”) may be eligible for up to 26 weeks of FMLA leave in a 12-month period, including the types of leave listed above.

Notice of Leave. When requesting leave, the employee must provide notice of the need for leave at least 30 days in advance or as soon as practicable.

Medical and other Certifications. Employees will be required to provide a medical certification if the leave request is: 1) for the employee’s own serious health condition, 2) to care for a family member’s serious health condition, or 3) military caregiver leave. Failure to provide the requested medical certification in a timely manner may result in denial of the leave until it is provided. If an employee refuses to provide a medical certification, his or her leave request may be denied and the employee may be disciplined.

Spoke, at its expense, may require a medical examination by a health care provider of its own choosing if it has a reasonable question regarding the medical certification provided by the employee. In lieu of a second opinion, Company may contact the health care provider directly to clarify or authenticate a medical certification, including certifications for military caregiver leave. Second opinions may not be required for military caregiver leave.

Separate certification may also be required regarding the nature of the family member’s military service and/or the existence of a qualifying exigency.

Fitness-for-Duty Certifications. Because Company wishes to ensure the well-being of all employees, any employee returning from FMLA leave for his/her own serious health condition will need to provide a Fitness for Duty (FFD) statement signed by his/her treating physician. Any employee who fails to provide an FFD statement will be prohibited from returning to work until it is provided. An employee who fails to provide an FFD certification may be disciplined or terminated.

Maintenance of Benefits. Company will maintain health care benefits for the employee while on FMLA leave, but the employee is responsible for paying the normal monthly contribution. If the employee elects not to return to work at the end of the leave period, the employee will be required to reimburse Company for the cost of premiums paid for maintaining coverage during the leave period. All other benefits cease to accrue during the unpaid portion of the leave.

Concurrent Leave. Employees must use any accumulated sick leave, vacation time, or paid time off (PTO) to the extent available during FMLA leave unless such leave is covered under Workers’ Compensation, in which case the employee may only use accumulated leave time only for the purpose of satisfying any waiting period. Absences in excess of these accumulated days will be treated as FMLA leave without pay.

Married Couples Who Work for Company. If an employee and his/her spouse both work for Company, they are both eligible for leave. The amount of leave allowed for the employee and the employee’s spouse may be limited to a combined total of 12 weeks of FMLA leave in a 12-month period if the leave is taken for:

  • The birth, adoption, or foster placement of a child;
  • To care for and bond with such child who does not suffer from a serious health condition;
  • To care for a parent with a serious health condition; or
  • A combination of the above.

For injured Service Member leave, the employee and his/her spouse may be limited to a combined total of 26 weeks of leave in a 12-month period, including the types of leave listed above in this paragraph.

Intermittent Leave. It may be medically necessary for some employees to use intermittent FMLA leave. Company will work with employees (and employees are required to work with the organization) to arrange reduced work schedules or leaves of absence in order to care for a family member’s serious medical condition or due to the employee’s own serious medical condition. Fitness for Duty statements generally are not required when an employee returns from intermittent FMLA leave.

Leave because of the birth or adoption of a child must be completed within the 12-month period beginning on the date of birth or placement of the child. It may not be taken intermittently without special permission from Human Resources.

Return from Leave. Employees will be terminated when they have exhausted their FMLA leave and do not return to work, unless they are entitled to additional leave as a reasonable accommodation under the Americans with Disabilities Act.

Attendance Policy. Qualifying FMLA leave will not be counted as an absence under the organization’s attendance policy.

State and Local Laws. When state and local laws offer more protection or benefits, the protection or benefits provided by those laws will apply.

This policy is intended to comply with the Family and Medical Leave Act, and to the extent that the FMLA changes, those changes shall supersede any conflicting provisions in this policy.

Meal Breaks

All Nonexempt Personnel who are scheduled to work a shift of five (5) consecutive hours or more are required to take a thirty (30) minute unpaid meal break during their shift. The timing of when such a break is taken must be approved by the Plant Manager, Production Supervisor, or other management personnel. Employees are not permitted to forego their meal break or use it at the end of their shift by leaving early.

These meal breaks shall be recorded on the employee’s time sheet by clocking out and in. Employees are not paid for the thirty (30) minute meal break period. If an employee is scheduled to work 5 hours or more during a shift, Human Resources will assume that the employee took their thirty-minute meal break and deduct that time from the total hours worked, unless the employee promptly notifies Human Resources otherwise.

Any exceptions must be approved and reported immediately to Human Resources.

Rest Breaks

In addition to the thirty (30) minute unpaid meal break described above, all Nonexempt Personnel shall receive a fifteen (15) minute paid rest period for each four (4) hour work period. Employees do not need to clock out and in during this rest period. The timing of when such break is taken must be approved by the Plant Manager, Production Supervisor, or other management personnel. Employees are not permitted to combine their 30 minute meal break with their 15 minute break(s).

Salaried Exempt Personnel may take breaks and meal periods when business permits.

Nursing Mothers

Employees who are also nursing mothers are entitled to a reasonable period of time during the workday, typically during the employee’s break(s), to express (e.g. “pump”) breast milk for her nursing child during the first two years after birth. Spoke will make reasonable efforts to provide the employee with a reasonably private room or other location in close proximity to their work area for this purpose. Employees to whom this policy applies should notify Human Resources to discuss their particular schedule and needs.

Performance at Work

Profession Development and Promotions

Spoke is dedicated to the success of its employees and has adopted a robust program for goal setting, performance reviews, and promotions. The policies and procedures can be found at https://employees.spokehealth.com.

Progressive Disciplinary Policy

Spoke’s progressive discipline policy and procedures are designed to provide a structured corrective action process to improve and prevent a recurrence of undesirable employee behavior and performance issues. It has been designed consistent with Spoke organizational values, human resource (HR) best practices and employment laws.

Outlined below are the steps of Spoke’s progressive discipline policy and procedure. Spoke reserves the right to combine or skip steps depending on the facts of each situation and the nature of the offense. The level of disciplinary intervention may also vary. Some of the factors that will be considered are whether the offense is repeated despite coaching, counseling or training, the employee’s work record, and the impact the conduct and performance issues have on the organization.

The following procedures shall be followed:

Step 1: Counseling and verbal warning
Step 1 creates an opportunity for the immediate supervisor to schedule a meeting with an employee to bring attention to the existing performance, conduct or attendance issue. The supervisor should discuss with the employee the nature of the problem or the violation of company policies and procedures. The supervisor is expected to clearly describe expectations and steps the employee must take to improve performance or resolve the problem.

Within five business days of this meeting, the supervisor will prepare written documentation of a Step 1 meeting. The employee will be asked to sign this document to demonstrate his or her understanding of the issues and the corrective action.

Step 2: Written warning
Although Spoke hopes that the employee will promptly correct any performance, conduct or attendance issues that were identified in Step 1, Spoke recognizes that this may not always occur. The Step 2 written warning involves more formal documentation of the performance, conduct or attendance issues and consequences.

During Step 2, the immediate supervisor and a division manager or director will meet with the employee to review any additional incidents or information about the performance, conduct or attendance issues as well as any prior relevant corrective action plans. Management will outline the consequences for the employee of his or her continued failure to meet performance or conduct expectations.

A formal performance improvement plan (PIP) requiring the employee’s immediate and sustained corrective action will be issued within five business days of a Step 2 meeting. A warning outlining that the employee may be subject to additional discipline up to and including termination if immediate and sustained corrective action is not taken may also be included in the written warning.

Step 3: Suspension and final written warning
There may be performance, conduct or safety incidents so problematic and harmful that the most effective action may be the temporary removal of the employee from the workplace. When immediate action is necessary to ensure the safety of the employee or others, the immediate supervisor may suspend the employee pending the results of an investigation.

Suspensions that are recommended as part of the normal progression of this progressive discipline policy and procedure are subject to approval from a next-level manager and HR.

Depending on the seriousness of the infraction, the employee may be suspended without pay in full-day increments consistent with federal, state and local wage-and-hour employment laws. Nonexempt/hourly employees may not substitute or use an accrued paid vacation or sick day in lieu of the unpaid suspension. Due to Fair Labor Standards Act (FLSA) compliance issues, unpaid suspension of salaried/exempt employees is reserved for serious workplace safety or conduct issues. HR will provide guidance so that the discipline is administered without jeopardizing the FLSA exemption status.

Pay may be restored to the employee if an investigation of the incident or infraction absolves the employee.

Step 4: Recommendation for termination of employment
The last and most serious step in the progressive discipline procedure is a recommendation to terminate employment. Generally, Spoke will try to exercise the progressive nature of this policy by first providing warnings, a final written warning or suspension from the workplace before proceeding to a recommendation to terminate employment. However, Spoke reserves the right to combine and skip steps depending on the circumstances of each situation and the nature of the offense. Furthermore, employees may be terminated without prior notice or disciplinary action.

Management’s recommendation to terminate employment must be approved by HR and the division director or designate. Final approval may be required from the CEO or designate.

Appeal Process
Employees will have the opportunity to present information that may challenge information management has used to issue disciplinary action. The purpose of this process is to provide insight into extenuating circumstances that may have contributed to the employee’s performance or conduct issues while allowing for an equitable solution.

If the employee does not present this information during any of the step meetings, he or she will have five business days after that meeting to present such information.

Performance and Conduct Issues Not Subject to Progressive Discipline

Behavior that is illegal is not subject to progressive discipline, and such behavior may be reported to local law enforcement authorities.

Similarly, theft, substance abuse, intoxication, fighting and other acts of violence at work are also not subject to progressive discipline and may be grounds for immediate termination.

Documentation
The employee will be provided copies of all progressive discipline documentation, including all PIPs. The employee will be asked to sign copies of this documentation attesting to his or her receipt and understanding of the corrective action outlined in these documents.

Copies of these documents will be placed in the employee’s official personnel file.

Important note: Nothing in this policy provides any contractual rights regarding employee discipline or counseling, nor should anything in this policy be read or construed as modifying or altering the employment-at-will relationship between Spoke and its employees.

Termination

Employees are expected to maintain appropriate performance and conduct standards during any notice periods initiated by either Spoke or employee. An employee may be denied the opportunity to complete a notice period if the employee is unable to maintain these standards, and the termination date will be moved up accordingly.

Below are the two categories of terminations and examples, however, there may be other reasons not listed below which form the basis for termination.

Voluntary Termination

Resignation of Employment – An employee resigning for personal reasons or to accept a position outside of Spoke is asked to give notice in writing to their supervisor as soon as this is known. For professional and managerial employees, a notice of one (1) month is considered appropriate. For employees in non-exempt positions, a minimum resignation notice of two (2) weeks is expected.

Job Abandonment – An employee who fails to report for work without proper notification for two (2) working days will be considered as having abandoned his/her position and will be treated as a voluntary termination. This includes employees who fail to return from a leave of absence on the specified date of the leave ending.

Involuntary Termination
Position Elimination – If an employee is terminated as a result of his or her position being eliminated due to economic reasons or reorganization of functions, the employee will be eligible for severance compensation benefits as described in Spoke’s Severance Policy.

Expiration of Family Medical Leave Act and/or Short Term Disability (STD) Benefits – An eligible employee whose total available Family and Medical Leave time (up to 12 weeks) has expired and who has not returned to work may be terminated. In the event an employee is receiving STD benefits, the employee will remain on the payroll until these benefits end, at which time employment will be terminated. In this situation, Spoke may fill the employee’s position at any time after FMLA has been exhausted.

Unsatisfactory Performance – An employee who is unable to bring his or her performance to an acceptable level following opportunities to do so may be involuntarily terminated.

Attendance/Other Policy Infractions – An employee may also be involuntarily terminated for poor attendance.

Misconduct – An employee may be immediately terminated for serious misconduct. Examples of serious misconduct include, but are not limited to:

  • Failure to adhere to the policies contained in Spoke’s Security Policy Document (https://policy.spokehealth.com)
  • Unauthorized disclosure of confidential or proprietary information concerning Spoke, any Company employee, client organization or member.
  • Falsification of any Company document, including employment application, timesheet, leave request, member or client record.
  • Violation of Spoke’s Harassment Policy.
  • Violation of Spoke’s Workplace Violence Policy. Reference Workplace Violence for details.
  • Violation of Spoke’s Drug Free Workplace Policy. Reference Drug Free Workplace for details.
  • Unauthorized or inappropriate use or appropriation of Company equipment, supplies, and computer/telephone systems.
  • Theft, fraud or other dishonest acts.
  • Insubordination, defined as refusing or deliberately failing to carry out a reasonable instruction of a supervisor.

The above list is not intended to be all-inclusive. Any employee who is suspected of serious misconduct may be suspended so that the circumstances may be adequately investigated and evaluated.

Termination Process

Spoke is dedicated to its employees, including those leaving Spoke. We must ensure an exiting employee feels that dedication. Spoke has developed termination guidelines to assist in achieving that goal. Those guidelines are available to directors and above upon request.

Employee Conduct

Personal Safety

Spoke takes pride in its practices to ensure the safety, health and well-being of all its employees. This program serves to outline Spoke’s commitment to this philosophy and to provide guidance to all employees on the standards Spoke expects its employees to adhere to. Fact sheets that provide supplemental information for the specific functions of this program are available through human resources (HR).

Fires and Other Emergencies

The facility where employees are assigned has an emergency procedures and evacuation plan to follow in the event of fire or other disaster. This plan is prominently posted in common areas and bulletin boards on each floor of the facility. Exits, fire extinguishers and first aid kits are located on each floor. All employees are expected to familiarize themselves with the location of such equipment.

Company-designated staff trained in first aid practices work on each floor of the facility. Lists of trained staff are posted on each bulletin board.

On-the-Job Injuries and Illnesses

Any job-related injury or illness, regardless of severity, must be reported immediately to an employee’s supervisor or the Spoke safety coordinator for prompt and trained evaluation and medical attention as necessary. The employee’s supervisor will complete an initial safety incident report and forward it to HR.

General Safety Rules

Spoke employees perform a wide range of functions in various locations. Although some safety rules apply only to specific positions, all employees are expected to comply with the rules in this procedure:

  • Use common sense in performing duties.
  • Report any work injury or illness to a supervisor.
  • Report unsafe conditions to a supervisor or safety committee member.
  • Do not use any equipment, vehicles or materials when overly tired, nauseated, feverish or under the influence of any substance that may affect judgment.
  • Keep the work area neat and tidy.
  • Use mechanical devices or request assistance in lifting heavy loads.
  • Wear seat belts when operating any company or rented vehicle or driving a personal vehicle while on company business.
  • Do not use tops of cabinets or bookcases for extra storage or displays.
  • Be sure that aisles or exits are kept clear; do not let cords interfere with walkways.
  • Keep paper clips, tacks, pins and other objects off the floors.
  • Properly store all sharp objects when not in use.
  • Open and close doors cautiously, and use extra caution at blind hallway intersections.
  • Open only one file cabinet drawer at a time to avoid tipping over the cabinet. Cabinets should also be loaded form bottom to top and emptied in the reverse order.
  • Report or clean up all spills immediately.
  • Use stepstools, platforms or ladders for climbing. Never use chairs.
  • Report or replace frayed electrical cords.

Emergency Evacuation Plans and Re-Entry

In any emergency, employees should follow alarms or other alerts to evacuate the building or area near the premises. Employees should always follow the basic evacuation procedures and remember that personal safety is paramount and takes precedence. Employees should do the following:

  • Check the work area for anything needing to be secured, and store it quickly.
  • Secure locks on all secured containers and cabinets.
  • Leave the work area, and report to the designated assembly area.

The director of facilities will coordinate with fire, police or other emergency preparedness personnel to determine when the building may be re-entered. This information will then be passed through safety committee members

Material Safety Data Sheets

Required by the Occupational Safety and Health Administration (OSHA), a material safety data sheet (MSDS) is a detailed description of each hazardous chemical located in the workplace and includes information regarding potential health risks, symptoms and treatment measures to be taken if exposure occurs.

Spoke will keep MSDSs on all hazardous substances and materials on its premises in areas adjacent to the equipment for which the MSDS pertains. Employees should help ensure that MSDSs are kept in their respective areas or report missing ones to their supervisor or safety committee representative.

Improper Health and Safety Practices

All employees are expected to abide by safe work practices and adhere to general safety rules to ensure their safety as well as the safety of co-workers.

Infractions of company health and safety practices will be dealt with in accordance with Spoke’s policies on discipline and will be based on the following factors:

  • Severity of the infraction.
  • Whether the infraction endangered only the employee or also co-workers.
  • Whether the infraction was a first or repeat violation.

Sexual Harassment

Spoke is committed to ensuring employees are treated fairly and equitably in an environment free of intimidation and sexual harassment. Sexual harassment is an unacceptable form of behavior which will not be tolerated under any circumstances. It is also unlawful. All complaints of sexual harassment will be treated seriously and promptly, with due regard to confidentiality. Disciplinary action will be taken against any employee who breaches the policy.

Sexual harassment is any unwanted, unwelcome or uninvited behavior of a sexual nature which makes a person feel humiliated, intimidated or offended. Sexual harassment can take many different forms and may include physical contact, verbal comments, jokes, propositions, the displaying of offensive material or other behavior which creates a sexually tense or hostile working environment. Sexual harassment can occur between an employee and a co-worker, supervisor or manager.

Sexual harassment is not just unlawful during working hours or in the workplace itself. The behavior is unlawful in any work-related context, including conferences, work functions, business or field trips, and interactions with clients.

Spoke recognizes comments and behavior which do not offend one person can offend another. Management accepts individuals may react differently and expects this right to be generally respected.

Spoke encourages any employee who feels they have been harassed to contact his/her manager or the HR Department. Spoke Health aims to provide a working environment which is free of workplace harassment or intimidation. Any complaints or reports of sexual harassment will be treated promptly, seriously and sympathetically. They will be investigated thoroughly, impartially and confidentially. Managers and supervisors must act immediately on any reports of sexual harassment. Employees will not be disadvantaged in their employment conditions or opportunities as a result of lodging a complaint.

Appropriate disciplinary action will be taken against anyone in this company’s employment who is found to have sexually harassed a co-worker. Depending on the severity of the case, consequences can include an apology, counseling, dismissal, demotion or other forms of disciplinary action. Immediate disciplinary action will also be taken against anyone who retaliates against a person who has complained of sexual harassment.

Spoke Health has a legal responsibility to prevent sexual harassment. Therefore, managers and supervisors have a responsibility to:

  • Monitor the working environment to ensure acceptable standards of conduct are observed at all times
  • Model appropriate behavior themselves
  • Treat all complaints seriously and take immediate action to investigate and resolve the matter
  • Refer complaints to another manager if they do not feel they are the best person to deal with the case (e.g. if there is a conflict of interest or if the complaint is particularly complex or serious)

All employees have the responsibility to:

  • Comply with the organization’s sexual harassment policy
  • Offer support to anyone who is being harassed and let them know where they can get help and advice (they should not approach the harasser themselves)
  • Maintain complete confidentiality if they provide information during the investigation of a complaint (employees who spread gossip or rumours may expose themselves to defamation or disciplinary actions)

Making a Complaint
If you believe you are being, or have been, harassed, follow the procedure below:

  • Inform the offender the behavior is offensive, unwelcome, and against company policy and should stop (only if you feel comfortable enough to approach them directly)
  • Keep a record of the incident/s
  • If the unwelcome behavior continues, contact your supervisor or manager for support
  • If this is inappropriate, you feel uncomfortable, or the behavior still persists, contact your manager

Receiving a Complaint
When a manager receives a complaint, he/she should follow the procedure below:

  • Listen to the complaint seriously
  • Treat the complaint confidentially
  • Allow the complainant to bring another person to the interview if he/she chooses to
  • Ask the complainant for the full story, including what happened step by step
  • Take notes, using the complainant’s own words
  • Ask the complainant to check your notes to ensure your record of the conversation is accurate
  • Explain and agree next action with the complainant
  • If investigation is not requested:
    • Act promptly
    • Maintain confidentiality
    • Pass your notes on to your manager
  • If investigation is requested, or is appropriate, follow the procedure outlined

Investigating a Complaint

When a manager investigates a complaint, he/she should follow the procedure below:

  • Interview all directly concerned, separately
  • Interview witnesses, separately
  • Keep records of interviews and investigation
  • Do not assume guilt
  • Interview the alleged harasser, separately and confidentially
  • Let the alleged harasser know exactly what he/she is being accused of
  • Give him/her a chance to respond to the accusation
  • Listen carefully and record details
  • Make it clear he/she does not have to answer any questions
  • Ensure confidentiality, minimize disclosure
  • Determine appropriate action based on investigation and evidence collected
  • Check to ensure the action meets the needs of the complainant and company

Outcomes as they affect the complainant should be discussed with the complainant to ensure that needs are met, where appropriate.

Potential Outcomes
If the complaint is found to be justified, the complainant may be entitled to any or all of the following:

The complainant may receive:

  • Commitment the behavior will cease
  • Private apology (verbal or written)
  • Re-credit of any leave taken due to the harassment
  • Other compensation deemed appropriate by the manager or HR Department

Drug and Alcohol

In compliance with the Drug-Free Workplace Act of 1988, Spoke has a longstanding commitment to provide a safe, quality-oriented and productive work environment consistent with the standards of the community in which Spoke operates. Alcohol and drug abuse poses a threat to the health and safety of Spoke employees and to the security of Spoke’s equipment and facilities. For these reasons, Spoke is committed to the elimination of drug and alcohol use and abuse in the workplace.

This policy applies to all employees and all applicants for employment of Spoke. The human resource (HR) department is responsible for policy administration.

Substance Abuse Awareness

Illegal drug use and alcohol misuse have many serious adverse health and safety consequences. Information about those consequences and sources of help for drug or alcohol problems is available from the HR department, which has been trained to make referrals and to assist employees with drug or alcohol problems.

Employee Assistance

Spoke will assist and support employees who voluntarily seek help for such problems before becoming subject to discipline or termination under this or other Spoke policies. Such employees will be allowed to use accrued paid time off, placed on leaves of absence, referred to treatment providers and otherwise accommodated as required by law. Such employees may be required to document that they are successfully following prescribed treatment and to take and pass follow-up tests if they hold jobs that are safety-sensitive or require driving, or if they have violated this policy previously. Once a drug test has been scheduled, unless otherwise required by the Family and Medical Leave Act or the Americans with Disabilities Act, the employee will have forfeited the opportunity to be granted a leave of absence for treatment, and possible discipline, up to and including discharge, will be enforced.

Employees should report to work fit for duty and free of any adverse effects of illegal drugs or alcohol. This policy does not prohibit employees from the lawful use and possession of prescribed medications. Employees must, however, consult with their doctors about the medications’ effect on their fitness for duty and ability to work safely, and they must promptly disclose any work restrictions to their supervisor. Employees should not, however, disclose to Spoke underlying medical conditions unless directed to do so.

Work Rules

Whenever employees are working, are operating any Spoke vehicle, are present on Spoke premises or are conducting company-related work offsite, they are prohibited from:

  • Using, possessing, buying, selling, manufacturing or dispensing an illegal drug (to include possession of drug paraphernalia).
  • Being under the influence of alcohol or an illegal drug as defined in this policy.

Possessing or consuming alcohol

The presence of any detectable amount of any illegal drug or illegal controlled substance in an employee’s body system, while performing company business or while in a company facility, is prohibited.

Spoke will also not allow employees to perform their duties while taking prescribed drugs that are adversely affecting their ability to safely and effectively perform their job duties. Employees taking a prescribed medication must carry it in the container labeled by a licensed pharmacist or be prepared to produce it if asked.

Any illegal drugs or drug paraphernalia will be turned over to an appropriate law enforcement agency and may result in criminal prosecution.

Required Testing

Pre-employment

Applicants might be required to take and pass a drug test before beginning work or receiving an offer of employment. Refusal to submit to testing will result in disqualification of further employment consideration.

Reasonable suspicion

Employees are subject to testing based on (but not limited to) observations by the supervision of apparent workplace use, possession or impairment. HR, the plant manager or the director of operations should be consulted before sending an employee for testing. All levels of supervision making this decision must use the Observation Checklist to document specific observations and behaviors that create a reasonable suspicion that the person is under the influence of illegal drugs or alcohol. If the results of the Observation Checklist indicate further action is justified, the manager or supervisor should confront the employee with the documentation and with a union representative present (for all unionized employees) or with another member of management (for all nonunionized employees). Under no circumstances will the employee be allowed to drive himself or herself to the testing facility. A member of supervision/management and a union rep (if appropriate) must escort the employee; the supervisor/manager will make arrangements for the employee to be transported home.

Post-accident

Employees are subject to testing when they cause or contribute to accidents that seriously damage a Spoke vehicle, machinery, equipment or property or result in an injury to themselves or another employee requiring offsite medical attention in which there is a reasonable basis for concluding that drug use could have contributed to the incident. A circumstance that constitutes probable belief will be presumed to arise in any instance involving a work-related accident or injury in which an employee who was operating a motorized vehicle (including a Spoke forklift, pickup truck, overhead cranes and aerial/man-lifts) is found to be responsible for causing the accident. In any of these instances, the investigation and subsequent testing must take place within two hours following the accident, if not sooner. Under no circumstances will the employee be allowed to drive himself or herself to the testing facility.

Follow-up

Employees who have tested positive, or otherwise violated this policy, are subject to discipline, up to and including discharge. Depending on the circumstances and the employee’s work history/record, Spoke may offer an employee who violates this policy or tests positive the opportunity to return to work on a last-chance basis pursuant to mutually agreeable terms, which could include follow-up drug testing at times and frequencies determined by Spoke for a minimum of one year but not more than two years as well as a waiver of the right to contest any termination resulting from a subsequent positive test. If the employee either does not complete the rehabilitation program or tests positive after completing the rehabilitation program, the employee will be subject to immediate discharge from employment.

Collection and Testing Procedures

Employees subject to alcohol testing should be driven to a Spoke-designated facility and directed to provide breath specimens. Breath specimens should be tested by trained technicians using federally approved breath alcohol testing devices capable of producing printed results that identify the employee. If an employee’s breath alcohol concentration is .04 or more, a second breath specimen should be tested approximately 20 minutes later. The results of the second test should be determinative. Alcohol tests may, however, be a breath, blood or saliva test, at Spoke’s discretion. For purposes of this policy, test results generated by law enforcement or medical providers may be considered by Spoke as work rule violations.

Applicants and employees subject to drug testing should be driven to a Spoke-designated medical facility and directed to provide urine specimens. Applicants and employees may provide specimens in private unless they appear to be submitting altered, adulterated or substitute specimens. Collected specimens should be sent to a federally certified laboratory and tested for evidence of marijuana, cocaine, opiates, amphetamines, PCP, benzodiazepines, methadone, methaqualone and propoxphane use. (Where indicated, specimens may be tested for other illegal drugs.) The laboratory should screen all specimens and confirm all positive screens. There must be a chain of custody from the time specimens are collected through testing and storage.

The laboratory should transmit all positive drug test results to a medical review officer (MRO) retained by Spoke, who should offer persons with positive results a reasonable opportunity to rebut or explain the results. Individuals with positive test results may also ask the MRO to have their split specimen sent to another federally certified laboratory to be tested at the applicant’s or employee’s own expense. Such requests must be made within 72 hours of notice of test results. If the second facility fails to find any evidence of drug use in the split specimen, the employee or applicant will be treated as passing the test. In no event should a positive test result be communicated to Spoke until such time that the MRO has confirmed the test to be positive.

Consequences

Applicants who refuse to cooperate in a drug test or who test positive will not be hired and will not be allowed to reapply/retest in the future.

Employees who refuse to cooperate in required tests or who use, possess, buy, sell, manufacture or dispense an illegal drug in violation of this policy will be terminated. If the employee refuses to be tested, yet Spoke believes he or she is impaired, under no circumstances will the employee be allowed to drive himself or herself home.

The first time an employee tests positive for alcohol or illegal drug use under this policy, the result will be discipline up to and including discharge.

Employees will be paid for time spent in alcohol or drug testing and then suspended pending the results of the drug or alcohol test. After the results of the test are received, a date and time will be scheduled to discuss the results of the test; this meeting will include a member of management/supervision, a union representative (if requested), and HR. Should the results prove to be negative, the employee will receive back pay for the times/days of suspension.

Confidentiality

Information and records relating to positive test results, drug and alcohol dependencies, and legitimate medical explanations provided to the MRO should be kept confidential to the extent required by law and maintained in secure files separate from normal personnel files. Such records and information may be disclosed among managers and supervisors on a need-to-know basis and may also be disclosed when relevant to a grievance, charge, claim or other legal proceeding initiated by or on behalf of an employee or applicant.

Inspections

Spoke reserves the right to inspect all portions of its premises for drugs, alcohol or other contraband; affected employees may have union representation involved in this process. All employees, contract employees and visitors may be asked to cooperate in inspections of their persons, work areas and property that might conceal a drug, alcohol or other contraband. Employees who possess such contraband or refuse to cooperate in such inspections are subject to appropriate discipline, up to and including discharge.

Crimes Involving Drugs

Spoke prohibits all employees, including employees performing work under government contracts, from manufacturing, distributing, dispensing, possessing or using an illegal drug in or on company premises or while conducting company business. Spoke employees are also prohibited from misusing legally prescribed or over-the-counter (OTC) drugs. Law enforcement personnel should be notified, as appropriate, when criminal activity is suspected.

Spoke does not desire to intrude into the private lives of its employees, but recognizes that employees’ off-the-job involvement with drugs and alcohol may have an impact on the workplace. Therefore, Spoke reserves the right to take appropriate disciplinary action for drug use, sale or distribution while off company premises. All employees who are convicted of, plead guilty to or are sentenced for a crime involving an illegal drug are required to report the conviction, plea or sentence to HR within five days. Failure to comply will result in automatic discharge. Cooperation in complying may result in suspension without pay to allow management to review the nature of the charges and the employee’s past record with Spoke.

Definitions

Company premises. includes all buildings, offices, facilities, grounds, parking lots, lockers, places and vehicles owned, leased or managed by Spoke or on any site on which Spoke is conducting business.

Illegal drug. a substance whose use or possession is controlled by federal law but that is not being used or possessed under the supervision of a licensed health care professional. (Controlled substances are listed in Schedules I-V of 21 C.F.R. Part 1308.)

Refuse to cooperate. to obstruct the collection or testing process; to submit an altered, adulterated or substitute sample; to fail to show up for a scheduled test; to refuse to complete the requested drug testing forms; or to fail to promptly provide specimen(s) for testing when directed to do so, without a valid medical basis for the failure. Employees who leave the scene of an accident without justifiable explanation prior to submission to drug and alcohol testing will also be considered to have refused to cooperate and will automatically be subject to discharge.

Under the influence of alcohol. an alcohol concentration equal to or greater than .04, or actions, appearance, speech or bodily odors that reasonably cause a supervisor to conclude that an employee is impaired because of alcohol use.

Under the influence of drugs. a confirmed positive test result for illegal drug use per this policy. In addition, it means the misuse of legal drugs (prescription and possibly OTC) when there is not a valid prescription from a physician for the lawful use of a drug in the course of medical treatment (containers must include the patient’s name, the name of the substance, quantity/amount to be taken and the period of authorization).

Reasonable Suspicion and Post-Accident Testing Protocol

  • The employee will be advised that Spoke believes that there is reasonable suspicion to believe that he or she is affected by illegal drugs or alcohol (or due to the nature of the accident the policy mandates this) and that this test is being offered to confirm or deny this suspicion.
  • The employee will be transported to any one of Spoke’s contracted testing facilities (e.g., health services, prompt care or the emergency department). One member of management or a designated attendant will accompany the employee along with a union representative, if requested by the employee. Under no circumstances will the employee be allowed to drive himself or herself to the testing facility.
  • Prior to leaving for the testing facility, supervision/management will contact the testing facility to inform it that a staff member from Spoke will be arriving and will need a drug or alcohol test completed.
  • The employee should be provided water to drink prior to leaving Spoke premises.
  • The employee should be given reasonable time—not to exceed 15 minutes—to secure photo ID in Spoke of a Spoke representative.
  • The employee to be tested must present a photo ID (i.e., a driver’s license or state ID card) to the testing facility staff before the specimen can be obtained. Ensure that the employee brings the photo ID with him or her when leaving Spoke premises.
  • The employee to be tested must sign a consent form provided by the testing facility. Refusal to sign is addressed under the “Consequences” section of this document.
  • A Spoke representative must sign as a witness to the collection procedure, along with the tested employee.
  • After returning to Spoke or when leaving the testing facility, the supervisor/manager must make arrangements to transport the person home (unless testing results are immediate). Under no circumstances will the tested employee be allowed to drive himself or herself home.

Enforcement

The HR department is responsible for policy interpretation, administration and enforcement.

Violence, Horseplay and Weapons

Spoke strives to provide a safe workplace for all employees. Spoke does not tolerate any type of workplace violence or threats of violence by any Company employee against any other employee, guest, visitor or third party. To ensure that Spoke’s objectives in this regard are attained, the following conduct is prohibited:

  • The use of any threatening behavior or acts of violence or intimidation by an employee against another employee, guest, or visitor while on or about Company premises.
  • Causing physical injury to another person.
  • The possession of firearms, knives or other dangerous weapons while on or about Company premises.
  • Aggressive or hostile behavior that creates a reasonable fear of injury to another person or subjects another person to emotional distress.
  • The use while on or about Company premises of any language or gesture which Spoke, at its sole discretion, deems abusive, obscene or threatening.
  • Intentionally damaging Company property or property of another employee.
  • Horseplay or other conduct which Spoke, in its sole discretion, deems dangerous or potentially dangerous to fellow employees, guests, or visitors.

This list is not intended to be an exhaustive list of prohibited conduct.

Reporting of Violent Behavior

Any employee who has reason to believe there is a risk of violence from another employee, guest, visitor, or any family member, friend, former spouse, or anyone else should immediately report those concerns to the Production Supervisor and/or Human Resources. Reports can be made anonymously and Spoke will investigate all reported incidents. Reports or incidents warranting confidentiality will be handled appropriately and Spoke will make every effort to disclose information to others only on a need-to-know basis.

Enforcement
Any employee who Spoke determines has committed a violation of this policy will be subject to disciplinary action, up to and including termination. Non-employees engaging in violent behavior on Spoke’s premises will be reported to the proper authorities.

Smoking

In keeping with Spoke’s intent to provide a safe and healthy work environment, smoking in the workplace is not permitted. Smoking is permitted only outside of the building in specifically designated locations. To prevent unsightly cigarette butts from collecting in the designated smoking locations, employees who wish to smoke must dispose of their cigarette butts in the proper receptacles. Smoking is only permitted before and after work hours, on scheduled breaks, and during meal periods.

Attire and Grooming

Spoke strives to maintain a workplace environment that is well functioning and free from unnecessary distractions and annoyances. As part of that effort, Spoke requires employees to maintain a neat and clean appearance that is appropriate for the workplace setting and for the work being performed. To that end, Spoke department heads may determine and enforce guidelines for workplace-appropriate attire and grooming for their areas; guidelines may limit natural or artificial scents that could be distracting or annoying to others.

Procedures

All Spoke staff members are expected to present a professional, businesslike image to clients, visitors, customers and the public. Acceptable personal appearance, like proper maintenance of work areas, is an ongoing requirement of employment with Spoke.

Supervisors should communicate any department-specific workplace attire and grooming guidelines to staff members during new-hire orientation and evaluation periods. Any questions about the department’s guidelines for attire should be discussed with the immediate supervisor.

Any staff member who does not meet the attire or grooming standards set by his or her department will be subject to corrective action and may be asked to leave the premises to change clothing. Hourly paid staff members will not be compensated for any work time missed because of failure to comply with designated workplace attire and grooming standards.

Specific requirements

Certain staff members may be required to meet special dress, grooming and hygiene standards, such as wearing uniforms or protective clothing, depending on the nature of their job. Uniforms and protective clothing may be required for certain positions and will be provided to employees by Spoke.

At the discretion of the department head, in special circumstances, such as during unusually hot or cold weather or during special occasions, staff members may be permitted to dress in a more casual fashion than is normally required. On these occasions, staff members are still expected to present a neat appearance and are not permitted to wear ripped, frayed or disheveled clothing or athletic wear. Likewise, tight, revealing or otherwise workplace-inappropriate dress is not permitted

Reasonable accommodation of religious beliefs

Spoke recognizes the importance of individually held religious beliefs to persons within its workforce. Spoke will reasonably accommodate a staff member’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 in light of safety issues for staff members. Those requesting a workplace attire accommodation based on religious beliefs should be referred to the human resource (HR) department.

Addressing workplace attire and hygiene problems

Violations of the policy can range from inappropriate clothing items to offensive perfumes and body odor. If a staff member comes to work in inappropriate dress, the staff member will be required to go home, change into conforming attire or properly groom, and return to work.

If a staff member’s poor hygiene or use of too much perfume/cologne is an issue, the supervisor should discuss the problem with the staff member in private and should point out the specific areas to be corrected. If the problem persists, supervisors should follow the normal corrective action process.

Attendance and Punctuality

Employees are expected arrive on time, ready to work for all scheduled work-days. Employees are expected to request time off in advance. Spoke understands and appreciates the vast differences in every person’s life and the challenges posed when balancing life with work. Therefore, under a ‘no fault’ philosophy; all reasons for unscheduled or unapproved absence or tardiness are treated the same.

It is Spoke’s policy to make reasonable accommodation to employees with regard to attendance issues under intermittent Family Medical Leave and/or the Americans with Disabilities Act. It is the employee’s responsibility to ask for such accommodations when applicable.

Non-Exempt/Hourly Employees

In some environments, such as production or call-center areas, requirements for adherence to schedule may be defined more specifically and are managed based on impact to performance. [As an example, the absence or lateness of an employee who is responsible for covering a phone queue has a more direct and immediate impact to the department’s performance than an employee in a less production-type role.] In this case, it is helpful to understand specifically how attendance will be managed and tracked. The following standards outline performance improvement actions that may be taken in response to increasing levels of unplanned/unscheduled absenteeism, lateness and early departures for non-exempt employees.

Attendance will be tracked on a rolling 12-month basis as opposed to a calendar year. These standards are contingent on a full-time work schedule and should be pro-rated for part-time employees.

Unscheduled Absences

As soon as an employee knows an absence is necessary, he or she should follow the call-in procedures established by the department. The absence must be reported within one hour of the specified start-time. This notification should include a reason for the absence, and an indication of when the employee will return to work.

Strict Adherence to Telecommuting Polices

Employee eligibility for telecommuting is established on a case-by-case basis and depends on a number of specific criteria and management approval. Not every role or employee will qualify for participation in the program.

Telecommuting employees must follow the policies outlined in Spoke Security Policy Document found at https://policy.spokehealth.com.

Any deviation from those policies is cause for immediately termination.

Bulletin Boards

Bulletin boards are located in various public areas at all office locations. Bulletin boards are only to be used for the posting of official Company notices and announcements and postings required by governmental agencies.

Company Stationary

Stationery or forms on which Spoke’s name appears may never be used for personal purposes. Spoke’s letterhead is to be used only for authorized communications

Visitor Policy

Spoke is committed to protecting the safety and security of all persons accessing its facilities and premises. Spoke also adheres to security practices designed to protect the interests of our customers, employees and patients.

Managers and employees are responsible for adherence to company policy. Failure to do so may result in disciplinary action up to and including termination.

Scope

This policy applies to all individuals seeking access to Spoke’s premises, specifically including employees, contractors, clients, tenants, and employees’ acquaintances, friends and family members, regardless of whether the purpose of the visit is for business or personal reasons.

Visitor Log

All visitors to a Spoke facility or premises must provide the information requested in a visitor log, an example of which is below.

Spoke’s Security Officer and office administrator shall:

  • place a visitor log conspicuously inside each point-of-access to the facility or premises;
  • ensure every visitor provides all information required in the visitor log;
  • contact the Spoke personnel with whom the visitor is meeting to verify the visitor is authorized to enter;
  • ensure every visitor is issued a visitor pass;
  • either personally escort the visitor to his/her destination within the facility or premises, or have the visitor wait to be escorted by the Spoke personnel with whom the visitor is meeting;
  • ensure every visitor signs-out by providing his/her departure time on the visitor log;
  • maintain the visitor log on a daily basis; and
  • retain visitor logs for no less than six months in a secure location within the Spoke facility or premises.

Applying the Policy

Access to Spoke’s premises by non-employees requires:

  • Signing into the visitor log located at the point of access, for example at the front desk;
  • Obtaining and wearing a visitor pass;
  • Being escorted by the appropriate Spoke personnel;
  • Not attempting to access any area or office not critical to achieving the purpose of the visit;
  • Signing out of the visitor log and returning the visitor pass; and
  • Exiting the building immediately thereafter.

Visitors have the following responsibilities:

Visibly display your security badges while at Spoke’s facilities and premises.

  • Do not share your security badge with anyone else – the badge was issued to only you.
  • Safeguard your security badge from loss or unauthorized usage. This means that you must immediately report lost/missing badges to Spoke’s Security Officer.
  • Do not allow anyone else (including other Badge Holders) access to the facility or premises or to any area or office to which you were granted access by your escort.
  • Do not prop open any security door, attempt to evade or defeat any security control measures or access restricted areas.
  • Use log-in/log-out readers, where present, each time you enter or leave the facility.

Escorting Visitors

Visitors must be escorted at all times by either an employee of Spoke or a vendor partner with escort privileges. Certain contractors and vendors can obtain approval for escorting visitors with management approval. Spoke’s employees, contractors and vendors (“Visitor Escorts”) have responsibility for the conduct and safety of the escorted visitor. Visitor Escorts have the following obligations:

  • Confirming that the visitor has registered with security (or reception). Registration includes security /reception verifying the visitor’s identification using government-issued photo identification, such as a driver’s license, passport or military identification.
  • Staying with the visitor the entire time the visitor remains inside The Hartford’s facility.
  • Facilitating a safe evacuation of the visitor if an emergency situation or evacuation drill occurs.
  • Making sure that the visitor complies with all company policies and guidelines.

Emergency and Evacuation Requirements

Spoke’s employees and vendor partners/contractors assigned to Spoke’s facilities must familiarize themselves with building emergency procedures and evacuation routes and staging areas.

Property Removal

Spoke’s vendor partners removing equipment or property from Spoke’s facility must (a) complete a property removal form provided by Spoke’s Security Officer and (b) be escorted from the facility or premises by an authorized Spoke employee.

For Further Information and Appropriate Signage

See Spoke’s Visitor Policies at https://policy.spokehealth.com

Use and Protection of Spoke Equipment

In addition to the general restrictions provided here, employees must strictly adhere to the policies contained in Spoke’s Security Policy at https://policy.spokehealth.com.

In general, employees shall not:

  • use any equipment not previously authorized by Spoke in writing, including but not limited to of cell phones, computers, routers, wireless transmission devises, fax machines, or any other physical asset used by employee to carry out his/her work for Spoke (“Work Equipment”);
  • use any Work Equipment for any use other than to carry out his/her work for Spoke or as otherwise authorized by Spoke in advance;
  • access Spoke systems, or those of any entity affiliated with Spoke including but not limited to vendors, contractors, clients, or providers unless authorized by Spoke; such access shall be only for the employee’s work for Spoke and as expressly permitted by Spoke; and
  • perform any work related to patients or providers in a location not expressly authorized by Spoke.

Liability

Employees shall pay for the repair or replacement of Work Equipment damaged by an employee occurring while employee is using the Work Equipment in violation of this section or any policy contained in Spoke’s Security Policy (https://policy.spokehealth.com) or when employee was using the Work Equipment in adherence to Spoke’s policies but caused by employee’s negligence, malfeasance, or misuse.

Technology

Internet Use

Email and Email Monitoring

Gmail Use Policy

Management Tools

Internet Surfing/Web Browsing and Monitoring

Social Media Activities and Monitoring

Software: adding, removing, modifying

Data Security Controls

Company-owned information held on third-party websites

If you produce, collect and/or process business-related information in the course of your work, the information remains the property of Spoke. This includes such information stored on third-party websites such as webmail service providers and social networking sites, such as Facebook and LinkedIn.

Sanctions

Failure to comply with these instructions is a disciplinary offense including cause for immediate termination, civil legal action, and/or criminal prosecution.

Benefits

Spoke is dedicated to the wellness and wellbeing of its employees and their loved ones. To that end, Spoke offers employee-benefit programs to the greatest extent possible. Those benefits are outlined in a document titled “Employee Benefits” found at https://employees.spokehealth.com.

Employee and Employer Responsibilities

Whistleblower Protection

Spoke is committed to protecting individuals from interference in making a good-faith report of violation under this policy and from retaliation as a result of such good-faith reporting. Individuals may not retaliate against any other individual on the basis of that individual making a good faith report of a violation. Individuals may not use or attempt to use authority or influence related to their position or association to interfere with another individual’s rights to make a report of violation as provided for in this policy.

Retaliation prohibited

In accordance with the provisions of applicable law, an individual shall not be discharged, receive or be threatened with adverse employment action, or otherwise be retaliated against regarding the individual’s compensation, terms, conditions, location, or privileges of employment on the basis that the individual, or a person acting on behalf of the individual, makes a good faith report of violation, or because an individual is requested by a public body or court to participate in an authorized investigation, hearing, inquiry, or court action.

An individual whom Spoke finds to have taken such retaliatory action against an individual who has filed a report of violation is subject to action deemed appropriate by Spoke, which may include discipline up to and including termination.

Confidentiality; Anonymous and Other Reporting

Good faith reports of violation will be kept confidential except on a need to know basis and in order to investigate and take appropriate action in response to the report of violation as determined by Spoke. In some instances, reporting may also be required under law or Spoke policy.

In the event individuals are uncertain about their reporting obligation, they should consult with a member of Spoke’s executive team.

Procedures; Implementation; Clarifications and Revisions

Spoke is authorized to enact procedures to implement this policy and to make interpretations and clarifications and revisions of this policy in accordance with applicable law; provisions of collective bargaining agreements consistent with law and Spoke policy; and other policies, rules, and requirements applicable to Spoke. Nothing in this policy shall be interpreted to preclude anyone from reporting criminal matters to law enforcement agencies or exercising any reporting rights protected by applicable law.

Required cooperation

To the greatest extent allowed by law, policy, and contract, all individuals are required to cooperate and provide requested information to Spoke personnel authorized under this policy or procedures enacted to implement this policy, and/or to investigate and determine the merits of reports of violation and/or complaints of retaliation. Any individual in violation of this policy is subject to action deemed appropriate by Spoke, which may include discipline up to and including termination.

False or misleading information or report of violation

Individuals who knowingly or with disregard for the truth give false or misleading information in conjunction with a report of violation, or knowingly make a false report of violation, are not entitled to the protections of this policy, and shall be subject to appropriate disciplinary, law enforcement, and/or other action. Reports of violation made pursuant to this policy that are not eventually substantiated, yet are still made in good faith, do not subject the reporting individual to such disciplinary action.

Commitment of Spoke

Employees promises to work to the best of his or her ability and to be loyal to Spoke.

Nondisclosure, Non-solicitation, and Inventions

Employees agree to the terms and conditions contained in policy titled “Unfair Competition,” which can be found at (https://employees.spokehealth.com) and which addresses:

  • Nondisclosure
  • Non-solicitation of Spoke Experts
  • Non-solicitation or Persuasion of Clients
  • Disclosure and Assignment of Innovations

Health and Safety

This policy serves to outline Spoke’s commitment to ensuring the safety and wellbeing or our colleagues and to provide guidance to all employees on the standards Spoke expects its employees to adhere to.

Fires and Other Emergencies

The facility where employees are assigned has an emergency procedures and evacuation plan to follow in the event of fire or other disaster. This plan is prominently posted in common areas and bulletin boards on each floor of the facility. Exits, fire extinguishers and first aid kits are located on each floor. All employees are expected to familiarize themselves with the location of such equipment.

Company-designated staff trained in first aid practices work on each floor of the facility. Lists of trained staff are posted on each bulletin board.

On-the-Job Injuries and Illnesses

Any job-related injury or illness, regardless of severity, must be reported immediately to an employee’s supervisor or the Spoke safety coordinator for prompt and trained evaluation and medical attention as necessary. The employee’s supervisor will complete an initial safety incident report and forward it to HR.

General Safety Rules

Spoke employees perform a wide range of functions in various locations. Although some safety rules apply only to specific positions, all employees are expected to comply with the rules in this procedure:

  • Use common sense in performing duties.
  • Report any work injury or illness to a supervisor.
  • Report unsafe conditions to a supervisor or safety committee member.
  • Do not use any equipment, vehicles or materials when overly tired, nauseated, feverish or under the influence of any substance that may affect judgment.
  • Keep the work area neat and tidy.
  • Use mechanical devices or request assistance in lifting heavy loads.
  • Wear seat belts when operating any company or rented vehicle or driving a personal vehicle while on company business.
  • Do not use tops of cabinets or bookcases for extra storage or displays.
  • Be sure that aisles or exits are kept clear; do not let cords interfere with walkways.
  • Keep paper clips, tacks, pins and other objects off the floors.
  • Properly store all sharp objects when not in use.
  • Open and close doors cautiously, and use extra caution at blind hallway intersections.
  • Open only one file cabinet drawer at a time to avoid tipping over the cabinet. Cabinets should also be loaded form bottom to top and emptied in the reverse order.
  • Report or clean up all spills immediately.
  • Use stepstools, platforms or ladders for climbing. Never use chairs.
  • Report or replace frayed electrical cords.

Emergency Evacuation Plans and Re-Entry

In any emergency, employees should follow alarms or other alerts to evacuate the building or area near the premises. Employees should always follow the basic evacuation procedures and remember that personal safety is paramount and takes precedence. Employees should do the following:

  • Check the work area for anything needing to be secured, and store it quickly.
  • Secure locks on all secured containers and cabinets.
  • Leave the work area, and report to the designated assembly area.

The director of facilities will coordinate with fire, police or other emergency preparedness personnel to determine when the building may be re-entered. This information will then be passed through safety committee members

Material Safety Data Sheets

Required by the Occupational Safety and Health Administration (OSHA), a material safety data sheet (MSDS) is a detailed description of each hazardous chemical located in the workplace and includes information regarding potential health risks, symptoms and treatment measures to be taken if exposure occurs.

Spoke will keep MSDSs on all hazardous substances and materials on its premises in areas adjacent to the equipment for which the MSDS pertains. Employees should help ensure that MSDSs are kept in their respective areas or report missing ones to their supervisor or safety committee representative.

Improper Health and Safety Practices

All employees are expected to abide by safe work practices and adhere to general safety rules to ensure their safety as well as the safety of co-workers.

Infractions of company health and safety practices will be dealt with in accordance with Spoke’s policies on discipline and will be based on the following factors:

  • Severity of the infraction.
  • Whether the infraction endangered only the employee or also co-workers.
  • Whether the infraction was a first or repeat violation.

Acknowledgements to be Signed by Employee

Receipt of Employee Handbook

Receipt of Spoke Security Policies

Receipt of Policies Regarding Anti-harassment, Non-discrimination, Drug and Alcohol

Receipt of, and Agreement to, Unfair Competition Provisions

APPENDIX A

ACKNOWLEDGMENT OF RECEIPT OF EMPLOYEE HANDBOOK

The employee handbook describes important information about Spoke, and I understand that I should consult my supervisor regarding any questions not answered in the handbook. I have entered into my employment relationship with Spoke voluntarily and acknowledge that there is no specified length of employment. Accordingly, either I or Spoke can terminate the relationship at will, with or without cause, at any time, so long as there is not violation of applicable federal or state law.

I understand and agree that, other than Spoke executives or designated representative of Spoke, no manager, supervisor, or representative of Spoke has any authority to enter into any agreement for employment other than at-will; only the President of Spoke has the authority to make any such agreement and then only in writing signed by the President of Spoke.

This manual and the policies and procedures contained herein supersede any and all prior practices, oral or written representations, or statements regarding the terms and conditions of your employment with Spoke. By distributing this handbook, Spoke expressly revokes any and all previous policies and procedures which are inconsistent with those contained herein.

I understand that, except for employment at-will status, any and all policies and practices may be changed at any time by Spoke, and Spoke reserves the right to change my hours, wages and working conditions at any time. All such changes will be communicated through official notices, and I understand that revised information may supersede, modify, or eliminate existing policies. Only the President of Spoke has the ability to adopt any revisions to the policies in this handbook.

I understand and agree that nothing in the Employee Handbook creates, or is intended to create, a promise or representation of continued employment and that employment at Spoke is employment at-will, which may be terminated at the will of either Spoke or myself. Furthermore, I acknowledge that this handbook is neither a contract of employment nor a legal document. I understand and agree that employment and compensation may be terminated with or without cause and with or without notice at any time by Spoke or myself.

I further understand that a violation of the policies contained in the Handbook can result in my immediate termination, civil litigation, and/or criminal prosecution.

I have received the handbook, and I understand that it is my responsibility to read and comply with the policies contained in this handbook and any revisions made to it.

Employee Name:
Signature: ________________________________ Date: _________________

This Form must be signed by the employee, dated, and placed in the employee’s file.

APPENDIX B

ACKNOWLEDGMENT OF RECEIPT OF SPOKE SECURITY POLICIES

By signing below, I acknowledge that I have received a copy of Spoke’s Security Policies; that I agree to adhere to the policies and guidelines contained therein.

I have received the handbook, and I understand that it is my responsibility to read and comply with the policies contained in Spoke’s Security Policies and that it is my responsibility to ask my supervisor to fully explain any questions I have about those Policies.

I understand it is my responsibility to ask my supervisor to fully explain any questions I have about the Security Policies and I bear the risk of not doing so.

I further understand that a violation of those Policies can result in my immediate termination, civil litigation, and/or criminal prosecution.

Employee Name:
Signature: ________________________________ Date: _________________

This Form must be signed by the employee, dated, and placed in the employee’s file.

APPENDIX C

ACKNOWLEDGMENT OF RECEIPT OF SPOKE’S POLICIES REGARDING
ANTI-HARASSMENT, NON-DISCRIMINATION, DRUG AND ALCOHOL.

By signing below, I acknowledge that I have received a copy of Spoke’s policies regarding anti-harassment, non-discrimination, and drug and alcohol use.

I agree to comply with all provisions of those Policies, including those relating to my obligation to report to Spoke and all incidents of discrimination and harassment as soon as possible, and no later than three (3) days after the incident.

I understand that it is my responsibility to review the Policies and consult management with any questions I may have concerning its provisions or application to a particular incident, and I bear the risk of not doing so.

I further understand that a violation of those Policies can result in my immediate termination, civil litigation, and/or criminal prosecution.

Employee Name:
Signature: ________________________________ Date: _________________

This Form must be signed by the employee, dated, and placed in the employee’s file.

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