Drug policy and Drug-Free Workplace Act

Drug and alcohol policy

Kinetic Data is committed to providing a safe, healthy, and productive work environment for the benefit of our employees, customers and in compliance with the DFWA. Consistent with this commitment, it is the intent of the Company to maintain a drug and alcohol-free workplace. Being under the influence of alcohol, illegal drugs (as classified under federal, state, or local laws), or other impairing substances while on the job may pose a serious health and safety risk to others, and will not be tolerated.

Prohibited conduct

The Company expressly prohibits employees from engaging in the following activities when they are on duty or conducting Company business or on Company premises (whether or not they are working):

• The use, abuse, or being under the influence of alcohol, illegal drugs, or other impairing substances.

• The possession, sale, purchase, transfer, or transit of any illegal or unauthorized drug, including prescription medication that is not prescribed to the individual or drug-related paraphernalia.

• The illegal use or abuse of prescription drugs.

While the use of marijuana has been legalized under some state laws for medicinal and/or recreational uses, it remains an illegal drug under federal law. The Company does not discriminate against employees solely on the basis of their lawful off-duty use of marijuana. You may not consume or be under the influence of marijuana while on duty or at work. If you have a valid prescription for medical marijuana, refer to the Company's Disability Accommodation Policy for additional information. Nothing in this policy is meant to prohibit your appropriate use of over-the-counter medication or other medication that can legally be prescribed under both federal and state law, if it does not impair your job performance or safety or the safety of others. If you take over-the-counter medication or other medication that can legally be prescribed under both federal and state law to treat a disability, inform your Supervisors if you believe the medication may impair your job performance, safety, or the safety of others or if you believe you need a reasonable accommodation before reporting to work while under the influence of that medication.

Employer-sponsored events

From time to time, the Company may sponsor social or business-related events where alcohol may be served. This policy does not prohibit the use or consumption of alcohol at these events. However, if you choose to consume alcohol at such events, you must do so responsibly and maintain your obligation to conduct yourself properly and professionally at all times.

Treatment or rehabilitation

The Company may assist you in seeking treatment or rehabilitation for drug or alcohol dependency through the EAP as further detailed in Section 6.5. In such cases, the Company may consider your continued employment as long as concerns regarding safety, health, production, communication, or other work-related matters are adequately addressed. The Company may also require you to obtain a medical clearance and agree to random testing and a "one-strike" rule as a condition of continued employment.

The Drug-Free Workplace Act of 1998 (“DFWA”)

The Drug-Free Workplace Act of 1998 ("DFWA") applies to all Federal Contractors with contracts greater than $100,000 and makes it illegal for employees to manufacture, distribute, dispense, possess, or use a controlled substance in the workplace, including alcohol. The DFWA was enacted to ensure employers like Kinetic Data provide a safe and productive workplace that yields work products of the highest standard expected by our customers, namely the US Federal Government. Prospective employees may be asked to successfully pass a confidential drug test prior to employment, depending upon the nature of their role at Kinetic. Once employed, should there be reasonable cause to assume the use of illegal drugs, alcohol, or the abuse of prescribed medication, Kinetic Data reserves the right to request an employee to take a drug test. Employees who seek assistance before the necessity of a drug test is determined will be offered access to addiction counseling/treatment as part of its employee benefits program and not be subject to disciplinary action. Employees who are found to be in violation of this policy and directed to take a drug test may be subject to disciplinary action ranging from mandatory counseling to potential termination of employment, depending upon the circumstances. For additional details on available counseling resources, please see Employee Assistance Plan.

The DWFA still regards cannabis as a controlled substance under Federal Law, despite legalization for recreational and/or medical use in multiple states. It is Kinetic Data’s paramount concern that we offer a safe and productive work environment for our employees while meeting commitments to our customers to deliver high-quality results. Regardless of state laws, it is the expectation of Kinetic Data that the use of cannabis will not occur in the workplace or during working hours, no different than alcohol or other controlled substances. Use of medically prescribed cannabis is permitted on the condition that it does not impair the judgment or performance of the employee and must be evidenced by a prescription from a properly licensed doctor.