EMPLOYMENT

ALCOHOL AND SUBSTANCE ABUSE POLICY Oxentenko, Inc. is committed to the health and safety of its employees. As part of this commitment, it is necessary to provide a work environment free of alcohol and controlled substances. The following policy is a summary of our Anti-Drug Plan and Alcohol Misuse Prevention Plan. Any of these plans may be reviewed by any employee at any time at his/her request. Types of Tests Pre-Employment Testing – A pre-employment test will be administered prior to a person being hired or contracted. After an offer of employment has been made to an individual, the offer is conditional upon the result of the test. A negative result is required prior to the start of work. Any individual who tests positive will be ineligible for employment consideration for a period of one year from the original test date. Post Accident Testing – If an employee is involved in an accident and it can be shown that his/her performance contributed to the cause of the accident or cannot be discounted as a contributing factor, the employee shall submit to a post-accident drug/alcohol test. Each employee involved shall be tested as soon as possible after the accident, but any injury will be treated first. Random Testing – Occasionally Oxentenko, Inc. clients require random drug/alcohol testing. If random testing is required, the employees’ names will be submitted to a consortium. Names will be drawn at random throughout the year by computer. When an employee’s name is drawn, the Drug Program Manager is notified. He will then notify the employee and follow the procedure as outlined in the Anti-Drug Plan. Random tests are meant to be unannounced to ensure the integrity of a drug/alcohol-free job site. Reasonable Cause Testing – Reasonable cause testing is designed to provide management with a tool to identify drug/alcohol-affected employees who may pose a danger to themselves or others in their job performance. Employees may be at work in a condition that raises a concern regarding their safety or productivity. Supervisors must then make a decision as to whether there is a reasonable cause to believe an employee is using or has used a prohibited drug or alcohol. Return-To-Duty Testing – An employee who refuses to take or fails a drug or alcohol test may not return to duty until the employee passes a drug/alcohol test and the Medical Review Officer and the company have determined that the employee may return to duty. Any employee who returns to duty shall be subject to a reasonable program of follow-up drug testing without prior notice for up to 60 months after his/her return to duty. Being under the influence of a controlled substance or illegal drug is defined as testing positive at the following levels using the Gas Chromatography-Mass Spectrometry (GC/MS) at a National Institute on Drug Abuse (NIDA) certified laboratory. Any reading above these levels is considered positive. Oxentenko, Inc. tests for the following drugs: Marijuana Metabolite 15 ng/ml Cocaine Metabolite 150 ng/ml Opiates: Morphine 300 ng/ml Codeine 300 ng/ml Phencyclidine 25 ng/ml Amphetamines: Amphetamine 500 ng/ml Methamphetamine 500 ng/ml Alcohol: DOT Drivers and Operators .02 Non-DOT Drivers .04 Whenever possible, alcohol levels shall be determined by a breath alcohol test. If breath alcohol testing is not available, the employee shall submit to a blood alcohol test. The use, possession, storage, distribution, or sale of alcohol, illegal drugs, or controlled substances on company property, or any location of company business, in company equipment or vehicles, or any time during working hours is prohibited. Being under the influence of alcohol, illegal drugs or a controlled substance on company property, or any other location on company business, in company equipment or company vehicles or any time during working hours is prohibited. Any use of alcohol outside of working hours, off company premises that negatively affects work performance, safety at work, or the company’s reputation is prohibited. Any use or any involvement with controlled substances or illegal drugs that negatively affects work performance, safety at work, or the company’s reputation is prohibited. Switching or adulterating any urine sample submitted for testing is a company violation. Refusing to consent to testing or to submit a urine sample or blood sample for testing when requested by management is a policy violation. Refusing to submit to a search when requested by management, failing to adhere to the requirements of any drug or alcohol treatment or counseling program in which the employee is enrolled is a policy violation. Refusing to sign a statement agreeing to abide by the company’s Alcohol and Substance Abuse policy is a policy violation. An employee undergoing prescribed medical treatment with any drug which may alter his/her physical or mental ability must report this treatment to the company office which will determine whether the company should temporarily change the employee’s job assignment during the period of treatment. Job applicants and employees must sign a form granting consent to the drug and/or alcohol testing and consenting to the release of the results to the company. Chain of custody protection will be provided to all specimens collected from current and prospective employees. Violation of the company’s Alcohol and Substance Abuse policy may result in severe disciplinary action, including discharge at the company’s sole discretion. In addition to any disciplinary action, the company may, at its sole discretion, refer the employee to a treatment and counseling program for alcohol or substance abuse evaluation. The company shall determine whether the employee it has referred for drug and substance abuse evaluation and counseling should be temporarily reassigned to another position. Oxentenko, Inc. will communicate test results to employees in writing no later than 5 days after receipt of results from the drug testing agency.

Oxentenko, Inc, reserves the right to withhold from employee’s pay, the cost of a drug test $114.00 (or current cost, whichever is greater), a paperwork processing fee of $30.00 (or current cost, whichever is greater), and the cost of a background check (if one is done) $52.00 (or current cost, whichever is greater) if the employee terminates employment of his/her choosing or is terminated by Oxentenko, Inc. This rule shall apply during the first six months of employment. If an employee takes the drug test and/or completes orientation paperwork and/or has a background check completed and does not show up for work, the employee agrees to pay the above fees directly to Oxentenko, Inc. If an employee takes a drug test and has a positive result, in addition to the Drug and Alcohol Policy rules, the employee shall reimburse the company for the cost of the drug test, even though the employee is not eligible to begin employment with Oxentenko, Inc.

ALCOHOL AND SUBSTANCE ABUSE POLICY Oxentenko, Inc. is committed to the health and safety of its employees. As part of this commitment, it is necessary to provide a work environment free of alcohol and controlled substances. The following policy is a summary of our Anti-Drug Plan and Alcohol Misuse Prevention Plan. Any of these plans may be reviewed by any employee at any time at his/her request. Types of Tests Pre-Employment Testing – A pre-employment test will be administered prior to a person being hired or contracted. After an offer of employment has been made to an individual, the offer is conditional upon the result of the test. A negative result is required prior to the start of work. Any individual who tests positive will be ineligible for employment consideration for a period of one year from the original test date. Post Accident Testing – If an employee is involved in an accident and it can be shown that his/her performance contributed to the cause of the accident or cannot be discounted as a contributing factor, the employee shall submit to a post-accident drug/alcohol test. Each employee involved shall be tested as soon as possible after the accident, but any injury will be treated first. Random Testing – Occasionally Oxentenko, Inc. clients require random drug/alcohol testing. If random testing is required, the employees’ names will be submitted to a consortium. Names will be drawn at random throughout the year by computer. When an employee’s name is drawn, the Drug Program Manager is notified. He will then notify the employee and follow the procedure as outlined in the Anti-Drug Plan. Random tests are meant to be unannounced to ensure the integrity of a drug/alcohol-free job site. Reasonable Cause Testing – Reasonable cause testing is designed to provide management with a tool to identify drug/alcohol-affected employees who may pose a danger to themselves or others in their job performance. Employees may be at work in a condition that raises a concern regarding their safety or productivity. Supervisors must then make a decision as to whether there is a reasonable cause to believe an employee is using or has used a prohibited drug or alcohol. Return-To-Duty Testing – An employee who refuses to take or fails a drug or alcohol test may not return to duty until the employee passes a drug/alcohol test and the Medical Review Officer and the company have determined that the employee may return to duty. Any employee who returns to duty shall be subject to a reasonable program of follow-up drug testing without prior notice for up to 60 months after his/her return to duty. Being under the influence of a controlled substance or illegal drug is defined as testing positive at the following levels using the Gas Chromatography-Mass Spectrometry (GC/MS) at a National Institute on Drug Abuse (NIDA) certified laboratory. Any reading above these levels is considered positive. Oxentenko, Inc. tests for the following drugs: Marijuana Metabolite 15 ng/ml Cocaine Metabolite 150 ng/ml Opiates: Morphine 300 ng/ml Codeine 300 ng/ml Phencyclidine 25 ng/ml Amphetamines: Amphetamine 500 ng/ml Methamphetamine 500 ng/ml Alcohol: DOT Drivers and Operators .02 Non-DOT Drivers .04 Whenever possible, alcohol levels shall be determined by a breath alcohol test. If breath alcohol testing is not available, the employee shall submit to a blood alcohol test. The use, possession, storage, distribution, or sale of alcohol, illegal drugs, or controlled substances on company property, or any location of company business, in company equipment or vehicles, or any time during working hours is prohibited. Being under the influence of alcohol, illegal drugs or a controlled substance on company property, or any other location on company business, in company equipment or company vehicles or any time during working hours is prohibited. Any use of alcohol outside of working hours, off company premises that negatively affects work performance, safety at work, or the company’s reputation is prohibited. Any use or any involvement with controlled substances or illegal drugs that negatively affects work performance, safety at work, or the company’s reputation is prohibited. Switching or adulterating any urine sample submitted for testing is a company violation. Refusing to consent to testing or to submit a urine sample or blood sample for testing when requested by management is a policy violation. Refusing to submit to a search when requested by management, failing to adhere to the requirements of any drug or alcohol treatment or counseling program in which the employee is enrolled is a policy violation. Refusing to sign a statement agreeing to abide by the company’s Alcohol and Substance Abuse policy is a policy violation. An employee undergoing prescribed medical treatment with any drug which may alter his/her physical or mental ability must report this treatment to the company office which will determine whether the company should temporarily change the employee’s job assignment during the period of treatment. Job applicants and employees must sign a form granting consent to the drug and/or alcohol testing and consenting to the release of the results to the company. Chain of custody protection will be provided to all specimens collected from current and prospective employees. Violation of the company’s Alcohol and Substance Abuse policy may result in severe disciplinary action, including discharge at the company’s sole discretion. In addition to any disciplinary action, the company may, at its sole discretion, refer the employee to a treatment and counseling program for alcohol or substance abuse evaluation. The company shall determine whether the employee it has referred for drug and substance abuse evaluation and counseling should be temporarily reassigned to another position. Oxentenko, Inc. will communicate test results to employees in writing no later than 5 days after receipt of results from the drug testing agency.

Oxentenko, Inc, reserves the right to withhold from employee’s pay, the cost of a drug test $114.00 (or current cost, whichever is greater), a paperwork processing fee of $30.00 (or current cost, whichever is greater), and the cost of a background check (if one is done) $52.00 (or current cost, whichever is greater) if the employee terminates employment of his/her choosing or is terminated by Oxentenko, Inc. This rule shall apply during the first six months of employment. If an employee takes the drug test and/or completes orientation paperwork and/or has a background check completed and does not show up for work, the employee agrees to pay the above fees directly to Oxentenko, Inc. If an employee takes a drug test and has a positive result, in addition to the Drug and Alcohol Policy rules, the employee shall reimburse the company for the cost of the drug test, even though the employee is not eligible to begin employment with Oxentenko, Inc.