Company Social Media Policy No. 6.

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Guidelines

Social Media Policy

Communications Department
Date of Latest Revision: June 8, 2020
Effective Date: January 1, 2014
Date of Last Version: June 8, 2020
Approval: Chief Human Resources Officer
Revision: Final

1.0 Introduction

Guidelines for functioning in an electronic world are the same as the values, ethics and confidentiality policies
employees are expected to live by every day, whether one is tweeting, talking with co-workers or customers,
or in casual conversations outside work hours. Our responsibility as representatives of the Company extends
beyond normal working hours.

The Company recognizes that many of its employees, contractors, partners/vendors, consultants,
temporary employees, etc. use social media sites. “Social media” includes all means of communicating or
posting information or content of any sort on the internet or any site thereon. This includes one’s own
or someone else’s web log or blog, journal or diary, personal web site, social networking or affinity web
site, web bulletin board or a chat room, whether or not associated or affiliated with the Company, as well
as any other form of electronic communication.

Social Media is a communication tool that can have a significant impact on the Company and its
professional image/reputation. The use of social media can obscure the difference between a personal
voice and an organizational voice. Before one posts anything online, she/he should understand that what
they post may be seen by co-workers, supervisors, customers, patients, funders, and consumers, among
others. Every post may be viewed as a reflection of one’s values and character, and by an extension, the
values and character of the Company. What is posted may have consequences and may cause irreparable
harm to the teammate’s reputation or to the reputation of the Company. The way others view the
Company is vital to our mission and to our growth as an organization.

2.0 Scope

This policy applies to all Company operations, employees and vendors/contractors/consultants. Violation
of this policy will lead to corrective action, up to and including termination.

3.0 Policy on Personal Use of Social Media

In line with the purpose of this policy, teammates / vendors / contractors/ consultants are subject to the
following:
3.1 Do not disclose any confidential, proprietary or trade secret information about the Company, its
subsidiaries, affiliates, vendors, or suppliers on any social media. Confidential, proprietary and trade
secret information includes information in any form or media that is created by or on behalf of the
Company in the course and scope of its business, regardless of whether that information is maintained
or stored by the Company or others on the behalf of the Company.

Examples of proprietary, confidential or trade secret information include, but are not limited to,
records of individuals receiving services, personnel records, corporate financial information,
company competitive information, Company-developed intellectual property, and business email
messages.

It is illegal to communicate inside information to others so that they can buy or sell stocks or
securities and such conduct may violate the Company’s Securities Trades and Insider Information
Policy.

3.2 Refrain from posting any comments, photographs, audio or other references to individuals receiving
services from the Company without proper authorization.

3.3 Do not post any individually identifiable information regarding a person receiving services from the
Company, including information collected, received, created, transmitted, or maintained in
connection with his/her status as a client, such as Protected Health Information (PHI), without proper
authorization. Even if an individual is not identified by name, if there is a reasonable basis to believe
that the person could still be identified from that information, then its use or disclosure could
constitute a violation of the Health Insurance Portability and Accountability Act of 1993 (HIPAA), the
Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH Act) and
Company policy.

This restriction includes posting photographs, video, audio or any comments or references
regarding people receiving care or services provided the Company to a personal social media site.

3.4 Do not say, suggest or in any way imply that the views and opinions one expresses related to the
Company is the official view of the Company. Where a connection with the Company is apparent,
one should clearly state that the opinion presented is stated individually, not that of the Company
and that the opinion is not expressed on behalf of the Company, its employees, clients, vendors or
any entity or agent working on behalf of the Company.

In such circumstances, one should use the following disclaimer “The views expressed on this
_________(blog, Web site, page, etc.) are my own and do not reflect the views of my
employer.”

3.5 Under any circumstances, do not infringe on the Company logo, trademarks, slogans, or other legally
protected images. Any use of the Company logo, trademarks, slogans, or other legally protected
images for business/commercial ventures, or for purposes inconsistent with intellectual property
laws, are prohibited on personal social media sites.
3.6 Respect our organization’s values and recognize our diversity. The Company is an equal opportunity
employer, with a diverse workforce, and prides itself in serving a diverse client / patient population.
Comments or materials posted that would otherwise violate applicable Company policies, such as,
but not limited to, policies prohibiting violence in the workplace and policies prohibiting harassment
and discrimination are strictly unacceptable and prohibited. Specifically, one should avoid posting
anything that may include discriminatory remarks, harassment, and threats of violence, or similar
inappropriate or unlawful conduct. Using statements, photographs, video or audio that could
reasonably be viewed as false, malicious, obscene, threatening or intimidating, disparaging, or that
might constitute harassment or bullying are also unacceptable and will violate this policy

Examples of such conduct include offensive posts meant to intentionally harm someone’s
reputation, posts that could contribute to a hostile work environment on the basis of race, sex,
disability, religion or any other status protected by law or company policy, and posts that
impair the Company’s ability to grow and carry out its mission of protecting and caring for a
vulnerable population.

3.7 Accessing social media while on work time or on equipment that the Company provides, unless it is
work-related or as authorized by the appropriate supervisor, is not allowed. All computer and internet
use by teammates must comply with the Company’s Systems Security Policies, internet access
policies, and any/all of the Company’s Policies regarding Technology Solution Services Best Practices.

Only personal e-mail address (e.g., hotmail.com, yahoo.com, gmail.com, etc.) are to be used on
social media sites.

3.8 The Company practices safe reporting and non- retaliation for reporting a violation of the Company’s
Social Media Policy or for cooperating in an investigation regarding this policy. Any teammate who
retaliates against another employee for reporting a possible violation of this policy or for cooperating
in an investigation shall be subject to disciplinary action, up to and including termination from
employment.

3.9 Best practices to avoid violating the Company’s Social Media Policy when posting on one’s personal
social media site or personal page would include, but not be limited to the following:
I. Exhibit professionalism when identifying as an employee of the Company.
II. Do not participate in any online conversation with clients, clients’ families, or others
regarding the specific care of a client.
III. Do not take or post pictures of a client or clients without proper authorization.
IV. Do not discuss or share confidential or proprietary business information, e.g.,
research protocols, contractual terms, financial information, quality data and
protected employee information.
V. Avoid posting anything that may include discriminatory remarks, harassment, threats
of violence, or similar inappropriate and unlawful conduct. Such comments will lead
to corrective action, up to and including termination.
4.0 Policy on Professional Use of Social Media

4.1 Individual operations are prohibited from setting up their own social networking sites. In order to fully
protect the Company brand, any social networking site that carries the Company name in any way
must be approved by the Executive Leadership Team. From time to time customers may need a social
media site for various reasons. The content and information contained on those sites should be
specific to that customer and any mention of Company should be cleared through the Executive
Leadership Team.

4.2 One may not divulge confidential, proprietary or trade secret information of or about the Company,
its subsidiaries, affiliates, clients, vendors, or suppliers on any social media.

4.3 One must acknowledge who you are when representing the Company on a social media platform.
Identify yourself by name and job title. You should not create links from a personal blog, website, or
other social media networking site to a Company site without identifying yourself as an employee of
the Company.

4.4 To protect the Company and employees, teammates must be mindful of copyright and intellectual
property rights of others and of Company. All posted material must conform to any and all applicable
state, provincial (for Canadian operations) and federal laws.

4.5 As a general rule, when representing the Company on social media, one must be honest, accurate,
and reflect the Company’s values when posting information. One should be mindful that the internet
archives almost everything and that deleted posts may still be available and searched by others. Do
not post information, rumors or gossip that is known to be false about the Company, co-workers,
clients, vendors, entities that work on behalf of or with the Company or the Company’s competitors.

4.6 Media contacts regarding the Company or our services, employees, partners, customers, and
competitors should be referred to the Company’s Communication Services team.