Pandemic Flu Policy

Model POLICY:
Pandemic Flu Policy

Purpose

As part of EMPLOYER's comprehensive emergency preparedness and business continuity plan, this document establishes the broad parameters of our corporate-wide response to influenza. It outlines specific steps EMPLOYER takes to safeguard employees' health and
well-being during a flu while ensuring EMPLOYER's ability to maintain essential operations and continue providing essential services to our customers. In addition, it provides guidance on how EMPLOYER intends to respond to specific operational and Human Resources issues in the event of a pandemic

Identification of Essential Personnel

EMPLOYER has identified and designated as essential personnel certain employees whose jobs are vitally important to EMPLOYER's continued operation in emergencies. EMPLOYER expects only designated essential personnel to be available for work during an influenza pandemic. EMPLOYER acknowledges, however, that even essential personnel might become ill and unavailable to work or not be able to reach our worksite because of conditions beyond their own or EMPLOYER's control. Consequently, EMPLOYER and its subsidiaries, affiliates, and industry partners have devised and agreed on back-up arrangements under which designated personnel in locations outside our respective areas are trained and equipped to fulfill the duties of unavailable essential employees. In addition, EMPLOYER has equipped our most essential personnel with all the resources, including computers, cell phones, and back-up generators, that essential employees will need to work remotely during emergencies.

EMPLOYER provides a list of essential personnel to all managers and employees as well as outside parties with a need to know.

Remote Work Locations

EMPLOYER acknowledges that during an influenza pandemic local, state, or federal authorities might prohibit or severely curtail individuals' access to and use of public services and public transportation; close or prevent access to buildings or public highways; isolate or quarantine buildings' occupants; and prevent inter- or intrastate delivery of goods and services. EMPLOYER cannot predict and has no control over such authorities' actions and acknowledges its legal duty to comply with outside authorities' directives. EMPLOYER, however, is prepared to continue key “bare bones” operations from a number of remote work locations, including essential employees' home offices. EMPLOYER has installed at all remote work locations all the equipment necessary for off-site telecommuting operations. In addition, EMPLOYER has designated a secure website through which essential personnel can communicate with each other and outside authorities.

Infection-Control Measures

EMPLOYER takes a number of steps to minimize to the extent practicable exposure to and spread of infection in the workplace, which is an ideal site for contagion because of workers' close proximity to one another. As appropriate, EMPLOYER recommends measures that employees can take to protect themselves outside the workplace and encourages all workers to discuss their specific needs with a family physician or other appropriate health or wellness professional.

Ill employees: EMPLOYER expects employees who contract the flu or have been exposed to infected family members or others with whom employees have been in contact to stay home and seek medical attention as necessary and appropriate. EMPLOYER expects such workers to notify EMPLOYER as soon as possible of exposure or illness, using EMPLOYER's secure telephone hotline, which channels calls to our emergency response call center.

At EMPLOYER's discretion or the direction of outside authorities, EMPLOYER can require the isolation and quarantine in EMPLOYER's on-site clinic of any infected employees who come to work despite exposure or need for medical attention.

Vaccinations: EMPLOYER requires all essential personnel to maintain up-to-date vaccinations and to obtain annual EMPLOYER-paid flu shots, if available and not medically contraindicated. EMPLOYER requires essential personnel to certify that they have obtained the necessary inoculations and to maintain a copy of that certification, which must be provided at EMPLOYER's request.

EMPLOYER is entitled under our state's Pandemic and Emergency Health Preparedness Act to receive from healthcare providers medical information created as a result of employment-related healthcare services, such as inoculations, provided to employees at EMPLOYER's specific request and expense when such information is needed to process insurance claims. EMPLOYER maintains the confidentiality of all such employee medical information.

Mandatory employee training: All employees are at risk of exposure to flu, viruses, both in and outside the workplace; therefore, EMPLOYER requires all employees to attend initial or annual refresher training annually to become informed about what to do when a flu outbreak occurs.

Training, which is customized for our business and conducted by a panel of outside experts and representatives from our Training, Risk Management, and Plant and Facilities sections, addresses information summarized in this document and, more specifically, such issues as availability of flu shots; symptoms and health effects of influenza, treatment, and sources to contact for appropriate medical care; steps to take if exposure is suspected; company representatives to whom to report known or suspected exposures, and procedures for reporting exposure to co-workers, family members, friends, or others who are ill with flu; proper use of EMPLOYER-provided personal protection equipment; proper hygiene in the workplace and at home; and communications. Training includes role plays based on scenarios developed to test employees' understanding of EMPLOYER's planned emergency response.

Supervisors and Human Resources are responsible for recording and maintaining documentation on every employee's participation in required training.

Personal protection equipment: EMPLOYER maintains on site adequate supplies of recommended personal protection equipment, such as face masks, eye protection, rubber gloves, and anti-bacterial hand gels and wipes, which EMPLOYER can require workers to use.

EMPLOYER urges all employees to speak with their personal physician about types and proper use of personal protection equipment in the home.

On-site clinic: EMPLOYER's fully equipped on-site health clinic is staffed at all times by full-time, EMPLOYER-paid medical professionals who are trained to respond to workplace medical emergencies and are familiar with all protocols to be followed during an influenza pandemic.

On-site cafeteria: EMPLOYER has no control over the independently owned and operated cafeteria in our building; however, EMPLOYER strongly advises employees who are working on site during an influenza pandemic to avoid purchases of foods whose sanitary preparation cannot be verified and certified.

Facilities maintenance: EMPLOYER's Plant and Facilities manager regularly inspects the workplace for signs of heating, air conditioning, or other equipment in need of replacement or repair. EMPLOYER's Plant and Facilities staff coordinate closely with EMPLOYER's cleaning and waste removal contractors to maintain our physical plant in top condition.

EMPLOYER approves the installation or use wherever possible of improved equipment or cleaning methods to guard against the spread of infection in the workplace.

Employee Leave and Pay

In the event of pandemic influenza, EMPLOYER grants all nonessential personnel immediate administrative leave. EMPLOYER pays workers on administrative leave a reduced salary, and continues such reduced salary for one-week periods up to a maximum of six weeks. EMPLOYER monitors emergency conditions daily to determine how long administrative leave must continue and, following consultation with outside authorities, advises employees when to expect to return to work.

EMPLOYER's established emergency response fund to which EMPLOYER allocates a portion of annual revenues is one source on which EMPLOYER draws to pay employees on administrative leave. Each year, EMPLOYER's board of directors sets the portion of revenues
to be allocated to the emergency response fund.

Family and medical leave: EMPLOYER places on family and medical leave any workers who
fall ill with flu or must be absent from work to care for an infected family member. EMPLOYER requires such employees to notify EMPLOYER as soon as possible of need for family and medical leave.

EMPLOYER allows employees to use accrued paid annual and sick leave in lieu of unpaid family and medical leave. EMPLOYER requires employees to take unpaid family and medical leave once all accrued paid leave is used.

EMPLOYER requires all employees to certify that they have received, read, and fully understand EMPLOYER's family and medical leave policy and its use in a flu outbreak.
(See EMPLOYER's related Family and Medical Leave Policy.)

Business Travel

EMPLOYER makes all reasonable efforts to obviate the need for travel by taking advantage of technology that allows us to communicate or otherwise operate electronically.

Generally, in the event of an influenza pandemic, travel on EMPLOYER's behalf is immediately suspended and limited to a select group of essential personnel who have obtained required travel authorizations from EMPLOYER and, if necessary, outside authorities.

Essential personnel or other employees traveling anywhere on EMPLOYER's behalf and exposed to avian flu or pandemic influenza are eligible for workers' compensation benefits.
(See description of EMPLOYER's workers' compensation benefits.)

Emergency Contact Information

Workers are required to notify their immediate supervisor and Human Resources of any change in emergency contact information; they must do so within two weeks of a change. When providing such information, employees, especially those who have children or care for elderly relatives, should identify individuals on whom they can depend if the employees themselves become sick at work and must be isolated and quarantined in EMPLOYER's on-site clinic.

Human Resources is directed to verify employees' emergency contact information twice a year, in January and July. Human Resources conducts this verification process electronically.

Supervisors are required to maintain in the workplace and at home an up-to-date emergency contact list for their unit or department.

Special needs and accommodations: EMPLOYER is required by law to notify first-responders about employees with medical conditions that could be compromised because of an influenza pandemic. EMPLOYER urges such employees to confidentially self-identify to Human Resources so that we are aware of and can prepare for you to receive any special medical expertise you might require if you become severely ill on the job. Human Resources maintains the confidentiality of any information you provide, making it available solely on a need-to-know basis and only when needed by emergency responders.

Communications

Outside authorities: EMPLOYER and its Emergency Operations Team partner with local, state, and federal emergency response and health agencies to ensure legal compliance with emergency response protocols to which EMPLOYER is subject and to coordinate efforts to maintain safety and security in and outside the workplace.

In the event of a conflict between directives issued by EMPLOYER and directives issued by local, state, or federal authorities, such as the federal Department of Homeland Security, EMPLOYER directs all employees to obey all orders issued under local, state, or federal law.

Action escalation: EMPLOYER's Emergency Operations Team, which is responsible for ensuring our company's ability to continue operating in emergencies, has devised a system under which essential personnel can be directed to take specific actions at a specific time based on a series of alerts (“Warning,” for example, or “Full Shutdown”) that take into account the seriousness of conditions at hand. EMPLOYER trains all essential personnel in the use and understanding of this communications system.

Call center: EMPLOYER's remote emergency response call center is activated in the earliest stages of a serious flu outbreak. Employees are instructed to call this center, using EMPLOYER's secure hotline number, for pre-recorded messages and assistance from live operators.

EMPLOYER provides separate secure hotlines for communications with customers, suppliers, vendors, and government officials. EMPLOYER communicates information about these hotlines via its dedicated website.

Dedicated website: EMPLOYER maintains a secure (password-protected) website, [provide url], that is devoted to pandemic flu issues generally and to EMPLOYER's responses specifically. You will find on this easily navigable site a copy of this document; easy-to-understand descriptions of influenza viruses and their health effects; hygiene factsheets; recommended infection-control protocols for home, workplace, and travel; copies of EMPLOYER's core travel, leave, pay, benefits continuation, health and safety, and workers' compensation insurance policies; our roster of essential personnel; contact information for EMPLOYER's Emergency Operations Team, as well as key company officials available to you in an emergency; and numerous links to local hospitals, first-responders, government emergency response agencies (for example, Centers for Disease Control and Prevention), and local, state, and federal public health and safety organizations offering information that you and your family can use to protect yourselves. Along with EMPLOYER's secure emergency information hotline, this site is your one-stop source of information on what to do, when, and how in the event of an influenza pandemic in our area.

If you have a question to which you cannot find an answer on this website, please use the
“Ask Us” facility on the site or submit your question by email. Your question will be directed to the appropriate person, who is required to reply, in a non-crisis situation, within three days. If appropriate, your question and the answer, if not confidential and likely to be helpful to other employees, will be posted to the FAQ section of our website one day after your receipt of the response. EMPLOYER has designated a specific company representative to staff “Ask Us” in a crisis; however, you should be aware that EMPLOYER's ability to maintain this service could be compromised during a crisis.

With assistance from Human Resources and designated representatives from our Risk Management/Safety and Security, and Plant Facilities departments, EMPLOYER's Webmaster and selected IT staff maintain and update this site regularly. EMPLOYER expects all employees to know how to access this site and to become familiar with the site's wide range of information, some of which is downloaded and distributed periodically in emergency information packets mailed to every employee's home.

In addition to being listed above, the url for our website is printed on all EMPLOYER communications related to pandemic flu informational posters found throughout the workplace, and a laminated Pandemic Flu Resources list that your supervisor is required to distribute to you. Printed in the form of a bookmark, the Resources list is intended to be posted at your workstation near your telephone. Feel free to ask your supervisor for additional copies to keep at home.

Other media channels: In an emergency, EMPLOYER consults with outside authorities to coordinate dissemination of instructions or other important information as quickly as possible to all employees. EMPLOYER communicates with employees via EMPLOYER's secure emergency information hotline and dedicated website, local radio and television stations, and secure websites of industry partners and affiliates. (See the section below titled Pandemic Flu Resources List for information on these media and how to reach them.)

Pandemic Flu Resources List

EMPLOYER maintains a list of the names, telephone numbers, and web addresses of key EMPLOYER representatives and designated essential personnel who are available to answer your questions about Pandemic Flu Employer Guidance and Actions. Your immediate supervisor, who is required to attend regular information and training sessions on EMPLOYER's emergency response and business-continuity planning and preparedness initiatives, as well as designated representatives of our subsidiaries, affiliates, suppliers, and industry partners, are directed to distribute up-to-date copies of this list, as well as any additional related information or guidance employees, suppliers, vendors, or customers might need.

The categorized list of key internal and external contacts and all appropriate media through which EMPLOYER communicates with employees also is available on our dedicated website. When updated, a new copy of the list is mailed to each employee's home.

Employee Assistance Program Services

EMPLOYER's employee assistance program (EAP) services remain available to you to the extent practicable and reasonable during an influenza outbreak. EMPLOYER has contracted with our EAP provider to make available to you a team of crisis-management specialists with medical backgrounds. Our provider partners with EMPLOYER and local authorities as appropriate to ensure the reasonable availability and continued provision of critical information (such as where to go to obtain medical assistance for yourself or ill family members), respite care, use of personal protection equipment, psychological and emotional support during a pandemic, including assistance and support following the death of an infected family member.

Contact information for our EAP is maintained on our dedicated website, published on posters throughout the workplace, and included in information packets mailed to every employee's home.

Availability of Business Continuity Plan

EMPLOYER's Emergency Preparedness and Business Continuity Plan is the result of many hours of discussion and planning with industry partners, public health experts, and other appropriate parties. EMPLOYER regularly reviews and shares this plan (and any updates to the plan) with EMPLOYER's affiliates and industry partners, insurers, designated first-responders, local healthcare facilities, and local, state, and federal government authorities, all of whom play a role in ensuring your safety and well-being in an emergency. In addition, EMPLOYER regularly tests implementation of the plan.

EMPLOYER makes available on written request printed copies of EMPLOYER's complete Emergency Preparedness and Business Continuity Plan, which includes the foregoing summary of EMPLOYER's response to an influenza pandemic.