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Handbook 2018


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Guardian Pharmacy, LLC Employee Handbook

January, 2005 Rev. 1 – 07/05 Rev. 2 – 10/06 Rev. 3 – 05/08 Rev. 4 – 07/10 Rev. 5 – 06/15 Rev. 6 – 05/18

4850-5492-0034, v. 1

For South Carolina Employees Only:

PURSUANT TO § 41-1-110 OF THE SOUTH CAROLINA CODE OF LAWS (1976, AS AMENDED) NOTHING IN THIS HANDBOOK IS INTENDED TO CREATE, NOR SHALL IT BE INTERPRETED TO CREATE, A CONTRACT OR AGREEMENT OF EMPLOYMENT, OR ANY PART OF A CONTRACT OR AGREEMENT OF EMPLOYMENT, EITHER EXPRESS OR IMPLIED.

THE RELATIONSHIP BETWEEN G U A R D I A N

P H A R M A C Y , L L C AND ITS EMPLOYEES IS STRICTLY THAT OF EMPLOYMENT AT-WILL.

I ACKNOWLEDGE MY RECEIPT AND UNDERSTANDING OF THE FOREGOING DISCLAIMER. I FURTHER ACKNOWLEDGE THAT ALL PREVIOUSLY ISSUED HANDBOOKS ARE WITHDRAWN BY GUARDIAN PHARMACY, LLC AND ARE OF NO FURTHER FORCE OR LEGAL EFFECT.

Printed Name of Guardian Pharmacy Employee

Signature of Guardian Pharmacy Employee

Date

4850-5492-0034, v. 1

EMPLOYEE HANDBOOK ACKNOWLEDGEMENT FORM

I hereby acknowledge receipt of my copy of the Employee Handbook outlining the guidelines, policies, and procedures of Guardian Pharmacy, LLC (“Guardian Pharmacy”). I understand I am responsible for reading, understanding and complying with the guidelines, policies, and procedures contained in the Handbook. I understand that the employee handbook serves as a guide regarding Guardian Pharmacy’s policies and procedures, but is not intended as a complete reference to all company policies, procedures, and/or work rules. I accept responsibility for contacting my Supervisor or the Human Resources Department if I have any questions, concerns, or need further explanation. I understand that neither the handbook nor any other communication by a management representative is intended to, in any way, create any legally enforceable rights, including, but not limited to, a contract of employment for a specified period of time. I understand my employment is at will and can be terminated at the option of either Guardian Pharmacy or myself at any time with or without notice or cause. The policies in this handbook are not intended and should not be construed to interfere, limit, or prevent an employee from exercising any rights under the NRLA. The information in this Handbook is subject to change without notice. I understand that changes in policies will supersede, modify, or eliminate the information summarized in this handbook and I will be notified of such changes through normal communication channels. As Guardian Pharmacy provides updated policy information, I accept responsibility for reading and abiding by any changes.

Employees have the option of receiving the Code in electronic format or hard copy. Please indicate your choice by initialing the appropriate box below: I choose to receive the employee handbook in electronic format and accept responsibility for accessing it according to the instructions provided to me. I understand that the Handbook is located on the Guardian Pharmacy ADP Portal website at https://workforcenow.adp.com. I choose to receive a hard copy of the employee handbook which is available from my local pharmacy. I understand that this handbook is also located on the Guardian Pharmacy ADP Portal website at https://workforcenow.adp.com. I understand that access and usage is for business purposes only and it is a violation of Company rules to provide the Handbook to any third party without express written consent from the Human Resource Department.

______________________________________

___________________

Printed Name of Guardian Pharmacy Employee

Date

______________________________________________ Signature of Guardian Pharmacy Employee

______________________________________________ Pharmacy Location

4850-5492-0034, v. 1

TABLE OF CONTENTS TOPIC Introduction................................................................................................................................................... 1 Contact List ................................................................................................................................................... 2 Company History .......................................................................................................................................... 3 Statement of Equal Employment Opportunity .............................................................................................. 4 At-Will Employment .................................................................................................................................... 5 Statement of Employer/Employee Relations ............................................................................................. 5-6 Attendance and Punctuality .......................................................................................................................... 6 Benefit Services Long Term Disability Insurance ...................................................................................................... 7 Basic Life and AD&D Insurance ..................................................................................................... 7 Employee Retirement Savings Plan – 401(k) .................................................................................. 7 Group Medical, Dental and Vision Insurance.................................................................................. 7 Health Savings Account (HSA) ....................................................................................................... 8 Short Term Disability Insurance ...................................................................................................... 8 Voluntary Life Insurance ................................................................................................................. 8 Flexible Spending Accounts (FSA)..................................................................................................8 Accident Insurance and Critical Illness Insurance............................................................................ 8 Social Security ................................................................................................................................. 9 Unemployment Compensation......................................................................................................... 9 Worker’s Compensation .................................................................................................................. 9 Cell Phone Usage........................................................................................................................................... 9 Code of Ethics.......................................................................................................................................... 9-10 Conflict of Interest ................................................................................................................................... ....10 Continuing Education ................................................................................................................................. 10 Compensation Strategy .......................................................................................................................... 10-11 Counseling and Corrective Action ......................................................................................................... 11-12 Definitions................................................................................................................................................... 12 Direct Deposit - Payroll .............................................................................................................................. 13 Drug and Alcohol Policy ....................................................................................................................... 13-14 Electronic Communications and Monitoring Policy.............................................................................. 14-16 Employment Application Information ........................................................................................................ 16 Fraud, Waste and Abuse Policy .................................................................................................................. 16 Harassment Prevention Policy ............................................................................................................... 17-18 4850-5492-0034, v. 1

Hazard Communications............................................................................................................................. 18 Health Insurance Portability & Accountability Act (HIPAA) .................................................................... 18 Holidays ................................................................................................................................................. 18-19 Hours of Work ............................................................................................................................................ 19 Inclement Weather ...................................................................................................................................... 19 Lactation/Breastfeeding .............................................................................................................................. 20 Leave Policies Bereavement Leave........................................................................................................................ 20 Family and Medical Leave (FMLA) ......................................................................................... 20-21 Jury Duty........................................................................................................................................ 21 Military Leave........................................................................................................................... 21-22 Personal Leave of Absence ............................................................................................................ 22 Sick Leave / Medical Leave of Absence........................................................................................ 23 Voting ............................................................................................................................................ 23 Licensing..................................................................................................................................................... 24 Non-Disclosure & Confidentiality .............................................................................................................. 24 Outside Employment Policy ....................................................................................................................... 25 Pay Day ....................................................................................................................................................... 25 Payroll Deductions...................................................................................................................................... 25 Performance Appraisals .............................................................................................................................. 26 Personnel Records....................................................................................................................................... 26 Problem Solving.......................................................................................................................................... 27 Professional Image ...................................................................................................................................... 27 Reasonable Accommodations...................................................................................................................... 27 Regulatory and Compliance Policy............................................................................................................. 28 Safety and Security ................................................................................................................................ 28-29 Smoke-Free Workplace .............................................................................................................................. 29 Social Media Policy ............................................................................................................................... 29-31 Termination of Employment ....................................................................................................................... 31 Time Records & Overtime Policy............................................................................................................... 32 Travel and Expense Policy....................................................................................................................... 32-33 Vacation .................................................................................................................................................. 33-34 Vehicle Safety Program .......................................................................................................................... 34-35 Workplace Violence Policy .................................................................................................................... 35-36

4850-5492-0034, v. 1

Employee Handbook - CONFIDENTIAL

May, 2018

INTRODUCTION

Dear Employee: Welcome to Guardian Pharmacy, LLC. It is our hope that your association with the Company will be pleasant and mutually beneficial. Our Company has an uncompromising commitment to fully serve our customers so they in turn can deliver the highest possible level of quality patient care. We seek individuals who are capable of outstanding performance and whose goals include putting the customer first. Further, we seek to foster a working environment in which all employees have the opportunity to fulfill their professional aspirations. In order to make your employment more rewarding and help you become acquainted with your new surroundings, we have provided you with our Employee Handbook. This booklet was written to give you guidance to those most-often-asked questions about personnel policies and benefits. The booklet explains what we expect from you in our combined efforts to serve our customers. Management may from time to time unilaterally make changes to this booklet and may modify Company policies, as we deem necessary. This booklet is not a contract of employment and does not alter the at-will employment relationship with the Company. The policies in this handbook are not intended and should not be construed to interfere, limit or prevent an employee from exercising any of his or her rights under the NLRA. Please take time to read through the material presented and familiarize yourself with the information and policies. If you have any questions, ask your Manager for clarification. We are pleased that you decided to join Guardian Pharmacy, LLC and look forward to working with you.

Fred P. Burke, CEO

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CONTACT LIST

Support Services Office Guardian Pharmacy, LLC 171 17th Street NW, Suite 1400 Atlanta, GA 30363 www.guardianpharmacy.net ADP Portal – https://workforcenow.adp.com Benefits Portal – www.mybensite.com/guardianpharmacy Username: guardianpharmacy Password: benefits Guardian Pharmacy Help Line (Reporting Hotline) …………………...…866-8ASK-GPS (866-827-5477) Guardian Pharmacy, LLC Main Number.......…………………………………………….………………………………404-810-0089 Toll Free Number..…………….…………………………………………………….………..877-482-7379 Main Fax…………………………………………………..…………………………………..404-521-5056 Human Resources Fax………………………………….……………………………………..404-532-5000 President/CEO – Fred Burke ....................................................................................................404-389-1330 EVP/CFO – David Morris ........................................................................................................404-389-1322 EVP, Operations – Kendall Forbes ...........................................................................................404-554-1661 Vice President, Information Technology – David Martin ........................................................404-389-1325 Vice President, Human Resources – Gail Young .....................................................................404-389-1356 VP, General Counsel – Doug Towns ........................................................................................404-554-1638 Director, HR Operations & Employee Relations (East) – Vicki Crabtree ................................404-389-1301 Director, HR Operations & Employee Relations (Central & West) – Shelley Brown............404-554-1628 Director, Talent Acquisition – Barri Busker............................................................................404-389-1333 Director, Total Rewards & HRIS – Jaleynne Raymond..........................................................404-554-1625 Director, Technology Services- Torrey Williams……………………………………………404-554-1689 Manager, Payroll & Benefits Admin – Suzanne Chezem........................................................404-389-1336 Manager, Accounts Payable – Lesia Martin .............................................................................404-389-1353

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COMPANY HISTORY Guardian Pharmacy, LLC (Guardian Pharmacy) was formed in mid-2004 to grow a network of specialty pharmacies throughout the U.S. The investors include the executive management team of Guardian Pharmacy; Fred Burke, David Morris and Kendall Forbes, as well as two investment firms, Bindley Capital and Cardinal Ventures, both in Indiana. Among the first pharmacies to join Guardian Pharmacy were Saliba’s Extended Care Pharmacy in Phoenix, AZ; Southern Pharmaceutical Services in Birmingham, AL; and Senior Care Pharmacy in Statesboro, GA; in addition to our start-up in Jacksonville, FL, Guardian Pharmacy of Jacksonville, LLC. Guardian Pharmacy now consists of over thirty (30) pharmacies in over sixteen (16) different states, employing over 2,000 employees. All of our businesses have a common goal: to provide outstanding service to their customers while growing a profitable local business. Through affiliation with these and all of our service locations, we can achieve our full potential. Five Principles of Service and Quality guide the operations of all Guardian Pharmacies: 1.

The President of the local Guardian Pharmacy is granted full responsibility for local operations. We believe that local business autonomy, coupled with a service oriented Support Services Office to provide support to the local operation, provides the local operation the flexibility needed to tailor service to the individual needs of our Customers.

2.

Guardian Pharmacy ensures an uninterrupted supply of a full line of the highest quality medications and products, packaged to meet the individual needs of our Customers and their Residents. Our goal is to work with our Customers to design dispensing systems to facilitate a safer, more efficient med pass, thus allowing more caregiver time for Resident care.

3.

Guardian Pharmacy provides continuous service 24 hours a day, 7 days a week. Our drivers ensure fast, responsive deliveries so that Residents get their medications on time. We stand ready 24/7 to assist our Customers in providing the best possible outcome for Residents.

4.

Guardian Pharmacy works in partnership with our Customers to ensure the best outcome for Residents at the lowest possible cost. Our computerized billing systems ensure Residents receive maximum reimbursement and the lowest possible cost for their medication needs. We earn the right to serve our Customers and Residents every day.

5.

Guardian Pharmacy’s core values guide how we do business, as individuals and as a company. We conduct business according to the Golden Rule, treating each other and our Customers fairly and honestly. We are performance driven, committed to hard work, initiative, and personal development. We work collaboratively as a team, seeking creative solutions to Customer needs.

This proven formula leads to an extraordinary level of quality and service, so our Customers can in turn deliver the highest possible level of patient care. In summary, Guardian Pharmacy has an uncompromising commitment to fully serve our Customers’ every need. Through this service commitment, we feel we can build a large, profitable business enterprise, which in turn will provide outstanding opportunities for our employees to successfully achieve their own personal and professional developmental goals.

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STATEMENT OF EQUAL EMPLOYMENT OPPORTUNITY Guardian Pharmacy will not discriminate against any employee or applicant for employment because of race; religion or religious creed (including religious dress and grooming practices); color; national origin (including language use restrictions); ancestry; citizenship status; age; disability (physical and mental), including HIV and AIDS; medical condition, including genetic characteristics; genetic information; marital status; status with regard to public assistance; sex; pregnancy, childbirth, breastfeeding and medical conditions related to pregnancy, childbirth or breastfeeding; perceived pregnancy; actual or perceived gender, gender identity or expression; sexual orientation; service in the military forces of the United States; military and veteran status, or any other protected class under federal, state, or local law. Guardian Pharmacy will make every effort to provide applicants and employees with reasonable accommodations necessary for the performance of the essential functions of a job. Disabled employees who can no longer perform essential job functions are encouraged to advise management of the nature of their disability and which functions they can no longer perform and to suggest accommodations that they believe would enable them to perform those functions. It is our philosophy and policy that all people are treated fairly and their dignity as individuals be respected at all times. In accordance with the Genetic Information Nondiscrimination Act of 2007 (“GINA”), Guardian Pharmacy prohibits discrimination on the basis of “genetic information” pertaining to not only employees, but also applicants and anyone in their respective families. “Genetic information” includes information regarding an individual’s family medical history, genetic tests, the manifestation of diseases and disorders, and any request for or receipt of genetic counseling or education. Guardian Pharmacy has a strong commitment to equal employment opportunity. Our policy further requires that promotions and job progress will be made on the basis of merit, ability and skills required of the job. Any employee who believes that he or she has been discriminated against based on any of the above-mentioned items is encouraged to discuss the situation with his or her Manager or Pharmacy President, the Vice President of Human Resources or the President/CEO in Atlanta. The Company takes all such complaints seriously. All complaints of discrimination will be promptly investigated. If a violation of this policy is found to have occurred, appropriate disciplinary action, up to and including termination, will be taken and appropriate action will be taken to remedy the injury, if any, to the affected employee(s). Additionally, measures will be undertaken to protect those who use the complaint procedure from retaliation due to reporting a good faith complaint of discrimination or participating in an investigation or proceeding concerning the alleged discrimination.

Fred Burke, CEO

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AT-WILL EMPLOYMENT It is not the policy of Guardian Pharmacy to enter into employment contracts with its employees. We believe that only when both parties, the Company and the employee, are satisfied should the employment relationship continue. Either party is free to terminate the relationship at will. Further, no representative of the Company, other than the President, has any authority to enter into an employment contract or to change the at-will employment relationship or to make any agreement contrary to that relationship. The Company retains the sole right to exercise all managerial functions including but not limited to, the rights: 1.

To dismiss, assign, supervise, promote, and discipline employees;

2.

To determine and change starting times, quitting times, and shifts;

3.

To transfer employees within departments or classifications or into other locations;

4.

To determine and change the size and qualifications of the work force;

5.

To establish, change, and abolish policies, practices, rules, and procedures at will and as it deems necessary;

6.

To determine and change methods by which its operations are to be carried out;

7.

To determine and change the nature, locations, services rendered, quantity, and continued operation of the business; and

8.

To assign duties to employees in accordance with the Company’s needs and requirements, and carry out all ordinary administrative and managerial functions.

STATEMENT OF EMPLOYER/EMPLOYEE RELATIONS It is the policy of Guardian Pharmacy to implement fair and effective operating policies and practices. To this end, the Company's goals are: 1. To provide Equal Employment Opportunity and treatment regardless of race, religion, color, sex, age, marital status, national origin, physical or mental disability, genetic make-up, Vietnam Era veteran status, or other legally protected classification; 2. To provide competitive wages and employee benefits; 3. To establish reasonable hours of work based on the Company's service requirements; 4.

To monitor and comply with applicable Federal, State and Local laws and regulations concerning employee safety;

5. To provide training consistent with the Company's requirements for those whose needs, capabilities, and desires warrant such training;

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6. To accept constructive suggestions which relate to methods, procedures, working conditions, and the nature of the work performed; and 7. To establish appropriate procedures for employees to discuss matters of interest or concern with their immediate supervisors or department managers. Together with the Company's goals, the Company expects all employees: 1. To give a productive day's work; 2. To arrive at the work site and begin work on time; 3. To demonstrate a considerate, friendly and constructive attitude toward customers and fellow employees; 4. To promote a civil work environment and work in a cooperative manner with management/supervision, coworkers, customers, and vendors; 5. To conduct business with the highest ethical standards, to obey the law, and to treat with fairness, integrity and honesty all fellow employees, customers and suppliers; and 6. To adhere to the operating policies and procedures adopted by the Company.

ATTENDANCE AND PUNCTUALITY Regular and predictable attendance and reporting to work on time are extremely important to the efficient and smooth operation of the Company. It is one of the most important contributions that you can make to Guardian Pharmacy. Being on time means being at your work location at the starting time for your schedule, working the schedule established by your Manager (including applicable breaks), and remaining there until your workday is complete. Entering or leaving Company property without permission may result in termination. An employee is expected to call his/her Manager directly before the start of the shift if circumstances arise which may cause tardiness or an absence. Employees should speak directly to their Manager. Poor attendance and excessive tardiness are disruptive and may lead to disciplinary action, up to and including termination of employment. Any employee who misses 3 or more consecutive days of work due to illness/injury is required to bring a doctor’s note releasing him/her to work. Any employee who misses work for three consecutive workdays without contacting his/her Manager will be considered to have resigned. Non-exempt employees are required to clock in and out each day, including for any breaks and meal periods. Failure to clock in and out can lead to paycheck errors, and continued failure can lead to disciplinary action.

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BENEFITS SERVICES Listed below are some of the standard benefits currently offered by Guardian Pharmacy. The Company reserves the right to modify, alter, or terminate any of these benefits, with or without prior notice. For information on the complete benefit offerings, please refer to the current year’s employee benefit guide, or to the Guardian Pharmacy Benefits Portal at www.mybensite.com/guardianpharmacy (username: guardianpharmacy / password: benefits). In addition, some of these benefits are governed by ERISA and/or may be further explained in the Summary Plan Description and/or plan document, which controls in case of a conflict. You are Automatically Enrolled In… A. Long Term Disability Insurance Employees regularly scheduled to work 30 hours or more per week are eligible for LTD coverage after satisfying the waiting period. This coverage provides 60% of the pre-disability salary after 90 days of disability (maximum monthly benefit is $8,500). This benefit is reduced by Social Security benefits if applicable. The Company pays for this benefit in full. B. Basic Life and AD&D Insurance Employees regularly scheduled to work 30 hours or more per week are eligible for coverage equal to one times their annualized salary (up to $50,000) after satisfying the waiting period. The Company pays for this benefit in full. C. Employee Retirement Savings Plan – 401(k) After six (6) months of service all employees who are at least 21 years of age are eligible to participate in Guardian Pharmacy’s 401(k) Plan. The plan allows employees to save for long-term retirement goals, and allows contributions on either a pre-tax or post-tax (Roth) basis. Participation is automatic, which means unless you actively “decline,” you will be enrolled at a 3% (pre-tax) contribution rate upon meeting the eligibility requirements. You may contribute between 1% and 85% of your salary, up to a yearly maximum, or you may decline participation, but you must actively indicate your desired participation rate if different than 3%. The plan has several investment options, but if no active investment election is made, your funds will automatically be placed in a target-date mutual fund based on your age. The Company will make a Matching Contribution to the Elective Deferral of up to 3.5%. The company matches 100% of the first 1% of deferred compensation and 50% on the next 2% to 6%. So, it’s a 3.5% match, but employees must contribute at least 6% to get the full matching amount. This match is subject to “vesting.” Full details are provided in the 401(k) Summary Plan Description. Employees should contact their Manager or go to www.mykplan.com for more information. You Enroll In… D. Group Medical, Dental and Vision Insurance Employees regularly scheduled to work 30 hours or more per week are eligible for Medical, Dental, and Vision insurance after satisfying the waiting period. The cost of coverage is shared between the Company and the employee. These deductions are also made PRE-TAX, which means that the employee does not pay tax on any of the insurance premiums. Information on Medical, Dental, and Vision insurance will be given to the employee when he or she starts work at Guardian Pharmacy. Employees should contact their Manager or go to the Guardian Pharmacy Benefits Portal for more information. 7

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E. Health Savings Account (HSA) Employees enrolled in the Guardian Pharmacy High Deductible Medical Plan are eligible to open an HSA. An HSA is a bank account which is used to plan, save and pay for qualified medical, dental and vision expenses. HSAs offer employees a before-tax method of paying for these expenses. Employees may contribute to their HSA via pre-taxed payroll contributions, and the money spent from an HSA on qualified medical, dental and vision expenses is tax advantaged. The money in an employee’s HSA belongs to the employee and can be used for current and future qualified expenses; there is no use-it-orlose-it rule. Information on HSAs and how to open an account will be given to the employee when he or she starts work at Guardian Pharmacy. Employees should contact their Manager or go to the Guardian Pharmacy Benefits Portal for more information. F. Short Term Disability Insurance Employees regularly scheduled to work 30 hours or more per week are eligible for Short Term Disability Insurance after satisfying the waiting period. The coverage is paid for by the employee through AFTER-TAX payroll deductions. This coverage provides 60% of the pre-disability salary after seven (7) calendar days of disability (maximum weekly benefit is $1,000). Information on Short Term Disability Insurance will be given to the employee when he or she starts work at Guardian Pharmacy. Employees should contact their Manager or go to the Guardian Pharmacy Benefits Portal for more information. G. Voluntary Life Insurance Employees regularly scheduled to work 30 hours or more per week are eligible for Voluntary Life Insurance after satisfying the waiting period. Employees can elect additional life insurance, spouse life insurance, and child(ren) life insurance. The coverage is paid for by the employee through AFTER-TAX payroll deductions, and the cost is based on the employee’s age. Information on Voluntary Life Insurance will be given to the employee when he or she starts work at Guardian Pharmacy. Employees should contact their Manager or go to the Guardian Pharmacy Benefits Portal for more information. H. Flexible Spending Accounts (FSA) Healthcare FSA – Employees enrolled in the Guardian Pharmacy PPO Medical Plan are eligible to participate in the Healthcare FSA. This plan provides tax savings for costs of eligible out-of-pocket medical, dental, and vision expenses. Dependent Care Reimbursement Account – Employees regularly scheduled to work 30 hours or more per week are eligible to participate in the Dependent Care Reimbursement Account. This plan provides tax savings for costs of daycare, eldercare and other care expenses if necessary for the employee or spouse to work. Eligible employees may participate after satisfying the waiting period. The plan year for this account is based on the fiscal year October 1 – September 30. Full details of this plan will be given to each employee when he or she starts work at Guardian Pharmacy. Additional information can also be found on the Guardian Pharmacy Benefits Portal. I. Accident Insurance and Critical Illness Insurance Employees regularly scheduled to work 30 hours or more per week are eligible for Accident Insurance and Critical Illness Insurance after satisfying the waiting period. Accident Insurance helps offset the costs associated with both minor and major on and off-the-job accidents. Critical Illness Insurance can help with expenses associated with a serious illness like cancer or a heart attack. These coverages are paid for by the employee through AFTER-TAX payroll deductions. Information on Accident Insurance and Critical Illness Insurance will be given to the employee when he or she starts work at Guardian Pharmacy. Employees should contact their Manager or go to the Guardian Pharmacy Benefits Portal for more information.

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OTHER BENEFITS I. Social Security Employees and their survivors are provided with certain benefits under the Federal Social Security laws. To provide these benefits, the law requires a deduction from the employee’s pay. In addition to the deduction, the Company is required to pay an amount equal to the deduction on the employee’s behalf. J. Unemployment Compensation Should you become unemployed through no fault of your own, you may be eligible for Unemployment Compensation insurance payments under state law. These payments are made possible by contributions paid entirely by the Company. K. Worker's Compensation In the event of an injury/illness arising out of your employment, you may become eligible for Worker's Compensation payments. While state law determines the amount of your benefit, the Company pays for this benefit with no contribution from you or any other source.

CELL PHONE USAGE Employees are expected to exercise discretion in using personal cell phones1 during working hours. Cellular phones shall be turned off or set to silent or vibrate mode at work or during meetings, conferences, and in other locations where incoming calls may disrupt normal workflow. Personal calls shall be restricted to nonwork time, such as breaks or lunch, whenever possible. If an employee’s use of his or her personal cell phone causes disruptions or loss in productivity, the employee may become subject to disciplinary action. Employees are strictly prohibited from using a cell phone to take photographs while at work. Regardless of your physical location in the building, a seemingly innocent photograph could capture protected health information and result in a HIPAA data breach event for the Company. Failure to follow this policy may result in disciplinary action, including and up to termination. CODE OF ETHICS We expect all employees to conduct themselves in an honorable fashion. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations. Here are the behaviors that we expect employees to exhibit in general practice: 1. Build Trust and Credibility. The success of our business is dependent on the trust and confidence we earn from our customers and stakeholders. We gain credibility by adhering to our commitments, displaying honesty and integrity, and reaching company goals through honorable conduct. 2. Respect for the Individual. Everyone deserves to work in an environment where they are treated with dignity and respect. Guardian Pharmacy is committed to creating such an environment because it brings out the full potential in each employee, which in turn, contributes directly to our business success. 3. Be A Role Model. Employees must be aware that their behavior in the work place must model the For the purposes of this policy, the term “cell phone” is defined as any handheld electronic device with the ability to receive and/or transmit voice, text, or data messages without cable connection (including, but not limited to, cellular phone, telephone, digital wireless phones, radio phones/walkie-talkies, telephone pagers, PDA’s (personal digital assistants with wireless communications capabilities), or RIM (“research in motion”) wireless devices). 1

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Guardian Pharmacy values. Each employee should always strive to set a good example. 4. Conflicts of Interest. Employees must avoid any relationship or activity that might impair, or appear to impair, the ability to make objective and fair decisions when performing their duties. 5. Personal Accountability. All employees are responsible for knowing and adhering to the core values and ethical standards of Guardian Pharmacy, as well as for understanding and meeting the requirements and expectations of their job responsibilities. 6. Open and Honest Communication. At Guardian Pharmacy, every employee should feel comfortable to speak his or her mind on business issues, and particularly with respect to ethics concerns. It is imperative that each employee communicates with his or her Supervisor, or other member of the management team, when he or she feels there is problem. Honesty and ethical behavior are core standards for our company and all employees. Therefore, any misrepresentation of facts or falsification of records, including personnel records, time sheets, medical records, leaves of absence documentation or the like, will not be tolerated. Each employee is expected to abide by Company policies and to cooperate fully and honestly in any investigation that the Company may undertake. Any violations will result in corrective action, up to and including termination of employment. Any employee aware of dishonest behavior or any other code of ethics violations should contact his/her Manager or Pharmacy President, Human Resources Support Services representative, or the Guardian Pharmacy Help Line at (866) 827-5477.

CONFLICT OF INTEREST To safeguard the activities and assets of Guardian Pharmacy, employees should not have personal interests, financial or otherwise, in outside businesses which conflict or appear to conflict with their ability to act and make independent decisions in the best interest of Guardian Pharmacy. All employees are expected to exercise good judgment and discretion in evaluating a particular activity so as to avoid an actual, or apparent, conflict of interest. Employees who are aware of a potential or actual conflict of interest must complete a General Conflict of Interest Disclosure Form and deliver it to the Pharmacy President. CONTINUING EDUCATION Guardian Pharmacy Pharmacists are eligible for reimbursement of reasonable continuing education expenses. The continuing education should be for maintaining a current pharmacist license. Pharmacists should obtain approval from their Manager prior to taking any continuing education course. Pharmacists should use good judgment when selecting live CE programs. Guardian Pharmacy Certified Pharmacy Technicians are only eligible for reimbursement of reasonable continuing education expenses when no-cost options are unavailable.

COMPENSATION STRATEGY It is the goal of Guardian Pharmacy to offer market and industry competitive salaries. To that end we research salary ranges adjusted for geographic market variables for each job title. These ranges are generally reviewed on an annual basis to verify that they are consistent with the local job market. An 10

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employee's continued years of service will not, therefore, necessarily result in a salary increase. Currently, compensation is based on merit, experience, the prevailing market, and other legitimate, nondiscriminatory business reasons. It is also the goal of Guardian Pharmacy to reward those employees who consistently contribute to the positive results of our company, work to make others successful, and show progress in the achievement of their personal goals. We strive to be a team that works smarter. Therefore, this reward will come in the form of a merit-based pay adjustment. Generally, if an increase in base pay is warranted, it will be effective during the first pay period of the month: Date Department January 1: Atlanta Support Services April 1:

Data Entry

Fulfillment Cycle Fill Medical Records HME Other Production July 1:

Inventory & Purchasing Billing & Admin Marketing Delivery

October 1:

Management Pharmacists COUNSELING AND CORRECTIVE ACTION

Employees have responsibilities and duties associated with their jobs. All employees are expected to consistently perform their job at a competent level. In addition, Guardian Pharmacy expects employees to maintain a professional working relationship with their coworkers, customers, and visitors. If a problem does arise, Guardian Pharmacy has designed counseling and corrective action guidelines to provide a constructive method of dealing with performance problems, while maintaining an at-will employment relationship. In general, the purpose is to make employees aware of the problem and to provide them with the opportunity to improve. Guardian Pharmacy has the sole discretion to determine whether any particular disciplinary steps are utilized prior to termination. In addition, at Guardian Pharmacy’s sole discretion, forms of corrective action may include one or more of the following, and any and all forms may be repeated or skipped: • Verbal Counseling • Written Counseling • Final Written Warning • Suspension • Involuntary Demotion • Termination 11

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Although one or more of these steps may be taken in connection with corrective action of a particular employee, no formal order or system is required. Guardian Pharmacy may terminate the employment relationship without following any particular procedure whenever it determines that such an action is necessary. Factors that may be considered in ascertaining the appropriate steps include: seriousness of conduct, employment record, the employee’s ability to correct the problem, action taken with respect to similar conduct by other employees, effect on customer business operations, and/or surrounding circumstances. DEFINITIONS Exempt

Exempt employees are those exempt from the Federal Wage & Hour Law. An exempt employee is not eligible to receive overtime pay. Most professional, sales, and management positions are included in the "exempt" designation. These employees are paid a bi-weekly salary.

Non-Exempt

Non-exempt employees are not exempt from the Federal Wage & Hour Law. Nonexempt employees receive time and one-half for hours worked in excess of forty (40) per week. Most positions other than those listed above are considered nonexempt, unless you are informed otherwise. These employees are paid at an hourly rate.

Full-Time

Full-time employees are regularly scheduled to work at least 30 hours per work week. A full-time employee is eligible for all Company benefits, provided the specific requirements of the individual benefit plans are met.

Part-Time >20

Part-time >20 employees are regularly scheduled to work at least twenty (20) hours per week, but less than thirty (30). These employees are eligible for sick, vacation, and holiday at one half the regular rate. If they work on a holiday, they receive regular hours worked plus holiday pay equal to the number of hours worked (or 4 hours holiday pay, whichever is greater), up to a maximum of eight (8) hours per holiday. They are also eligible to participate in the 401(k) Plan.

Part-Time