Key Point Health Services Inc. Internal Communication Policy General: Accurate, timely and open communications within Key Point is a major objective of the organization. To that end, four separate methods of fostering such communications have been established, each with its own objective and procedure. This policy sets forth each of the four methods and every employee is encouraged to make use of these programs as the subject may apply. Grievance Procedure: A grievance is any significant employee concern that arises in the application of personnel breaches or in violation of personnel practices, either between employees and their coworkers or between employer and employees. COMPLAINTS INVOLVING ANOTHER EMPLOYEE: Employees are encouraged to take the complaints involving a coworker directly to that person for discussion and resolution. If the two employees are unable to resolve their differences, they may at any time request a mediation meeting with their immediate supervisor where both employees are present. If the complaint is unresolved at that level, a second mediation meeting can be arranged with the program director. The resolution of the program director, in consultation with the CEO, shall be considered final. It is the policy of Key Point Health Services to discourage gossip among or about staff people. COMPLAINTS AGAINST KEY POINT HEALTH SERVICES The procedure set forth is intended to serve as a means for peaceful settlement of disputes that arise between employees and KEY POINT HEALTH SERVICES. Extension of times beyond those indicated in the formal steps of the procedure outlined below may be secured through mutual (written) agreement of the parties involved. Failure by the employee to comply with any limitations shall constitute withdrawal of the grievance. Failure of management to comply with the time limitations shall constitute the right of the employee to proceed to the next step of the grievance procedure. 1. STEP ONE: IMMEDIATE SUPERVISOR a. Every effort shall be made by both employee and supervisor to resolve the problem through discussions. b. If discussions fail to resolve the issue, the employee shall submit the substance of his or her grievance in writing to the immediate supervisor. c. The immediate supervisor shall convey his or her decision in writing to the employee within five working days or receipt of the grievance d. If the aggrieved employee is not satisfied by this decision, he or she may submit in writing his or her grievance to the program director within five working day of the receipt of the immediate supervisor’s decision. 2. STEP TWO: PROGRAM DIRECTOR a. The program director shall within five working days of notification, arrange a meeting with the employee to discuss the grievance. b. A decision regarding the disposition if the grievance shall be conveyed in writing to the employee within five working days following the meeting. c. If the matter is resolved at this level, it shall be mutually acknowledged in writing, and no further action is required d. If the discussion has failed to resolve the issue, the employee has five working days to submit a written notice outlining the grievance to the CEO. 3. STEP THREE: CHIEF EXECUTIVE OFFICER a. Upon receiving the written request, the CEO shall request copies of all written communications from steps one and two. b. The CEO will issue a decision in writing to the employee within a reasonable amount if time, to be determined by the CEO. c. The decisions of the CEO are final Corrective Measures: The Corrective Measures program has been developed in an effort to create a uniform and documented process by which the entire agency can address issues or concerns related to job performance. This system must be used any time a corrective action (i.e., counseling meeting, verbal warning, written warning, and suspension) is taken on an employee of Key Point. . An employee may also use and document a counseling meeting to address concerns he/she is having with a supervisor. 1. When a corrective action is needed, both the supervisor and the employee will have a meeting to discuss the issue of concern and develop a plan to address the issue. 2. After this meeting, the Corrective Measures form is filled out and signed by the supervisor and the employee. Signatures are needed for all levels of corrective action. 3. Within 3 business days of the meeting the original form is sent to the Human Resources Manager and copies are kept for the supervisor and the employee 4. The Human Resources Manager will provide confirmation that the forms were received and/or will also request any further documentation. 5. Within 2 weeks after all documentation is received, the Human Resources Manager will review the action take and will then contact the director, supervisor, and employee (via phone, face-to-face, or e-mail) to communicate any procedural issues and to provide any recommendations.. 6. When indicated, the Corrective Measures form will be filed in the appropriate employee file (i.e. supervision file, personnel file). Whistleblower Policy: The whistleblower policy at Key Point Health Services is to comply with the Public Company Accounting Reform and Investor Protection Act of 2002 (Sarbanes-Oxley). At Key Point Health Service any staff member or volunteer who reports waste, fraud, or misuse of company resources will not be terminated or otherwise retaliated against for making the report. The report will be investigated and even if determined not to be waste, fraud, or misuse of company resources, the individual will not be retaliated against. There will be no punishment for reporting problems-including termination, demotion, suspension, harassment, failure to consider the employee for promotion, or any other kind of discrimination. There are several ways to make an anonymous or confidential report of suspected waste, fraud, or misuse of company resources: Call or email the CEO Submit a report in writing to the CEO Contact the president of the Board of Directors. The President’s email address is on the KeyPoint.org web site The CEO or Board of Directors will investigate the report as follows: Ask the corporation’s independent counsel to review the report, or Assign the CEO or his/her designee with the investigation The CEO or Board of Directors will follow up to report on their findings as follows: Provide the person filing the report a summary of the findings Take steps to deal with the issue addressed If warranted contact law enforcement to deal with any criminal activities Confidential Input: Notwithstanding the methods of employee communications noted above, it is possible there may be a situation for which the employee is uncomfortable to discuss or question in any of these forums. To that end arrangements have been made for any employee to contact our Human Resource Manager via email. Contact may be made via the Key Point website using the Confidential Input Form in the “members only” section. 12/2011