DocumentCloud_Epstein_Docs_p00422.png

Case 18-2868, Document 278, 08/09/2019, 2628230, Page289 of 648 DRUG/ALCOHOL USE AND TESTING The Mar-a-Lago Club recognizes that employee drug abuse interferes with the Club’s level of production, as well as its competitive position in the marketplace, and can result in costs, delays, and tragedies associated with work-related accidents. As a condition to employment or continued employment, you must refrain from reporting to work or working with the presence of drugs or alcohol in your body. To address the problem of drug/alcohol abuse and to comply with Florida’s Workers’ Compensation Drug-Free Workplace Act (the Act) The Mar-a-Lago Club adopts the policies and procedures detailed below. This policy will be administered in accordance with all relevant laws (state and local), including the ADA, the Florida Civil Rights Act, the Workers’ Compensation Act, and in a non- discriminatory fashion. To protect the health, safety, and welfare of all Mar-a-Lago Club employees, it is the Club’s policy that the unlawful manufacture, distribution, dispensation, possession, or use of controlled substance on any Club property is absolutely prohibited. Controlled substances include, but are not limited to, amphetamines, barbiturates, cocaine, heroin, morphine, PCP, marijuana, hashish, and any other controlled substance listed in Schedules I through V of Section 202 of the Controlled Substance Act, 21 U.S.C. & 812 or in the Florida Statute on controlled substances, except for medication prescribed by the employee’s physician. You are also prohibited from drinking alcohol during the business day. You are also prohibited from bringing alcoholic beverages onto the Club premises. Special care shall be taken during Company-sponsored social events for employees. In these cases, employees and guests below the legal age will not be allowed to drink alcoholic beverages. The amount of time alcohol is served will be limited as well as the quantity of the alcohol. If necessary, transportation will be arranged for someone if his or her driving ability seems to be impaired. The Mar-a-Lago Club will test for the presence of drugs under the following circumstances: 1) pre-employment testing, 2) reasonable suspicion testing (including post-accident incidents), and 3) follow-up testing. Such testing will be done in accordance with the Worker’s Compensation Drug Testing Program, which policy had been given to all employees or can be obtained from the Human Resources Manager. Refusal to submit to the test or having a confirmed, positive test result will result in immediate discipline, including termination. Any questions about this policy should be referred to the Human Resources Manager. MAR-A-LAGO 0235