Staffmark Group, in compliance with the Drug-Free Workplace Act of 1988, has a longstanding commitment to providing a safe, quality-oriented, and productive work environment consistent with the standards of the community in which we operate. Alcohol and drug use pose a threat to the health and safety of our employees and our clients as well as to the security of our client’s equipment and facilities. For these reasons, Staffmark Group is committed to the elimination of drug and/or alcohol use in the workplace.

This policy is necessary for the safety, security and well-being of all employees and customers. This policy applies to all temporary and leased employees/applicants of Staffmark Group. The Staffmark Group Human Resources department is responsible for the administration of this policy.

The policy will help ensure the safety of the public as well as a safe working environment at the customer site. The policy will help ensure that employment related decisions utilizing drug and/or alcohol screenings are made in accordance with applicable law. Staffmark Group is committed to honoring and enforcing our customer’s Drug-Free Workplace policies as well as our own.

It is not the purpose of this policy to provide detailed information or descriptions of each individual drug and/or alcohol screen that can be performed. It is not the purpose of this policy to provide detailed information of all applicable law. Questions about these subjects should be directed to Staffmark Group’s Human Resources.

CIRCUMSTANCES THAT REQUIRE SCREENING

Applicants and employees of Staffmark Group may be required to submit to a drug and/or alcohol screening under the following circumstances:

Pre-employment drug screening after a conditional offer of employment has been made.

For cause or reasonable suspicion drug screening may be requested at any time if there is reason to believe that the employee may be under the influence of drugs and/or alcohol, including, but not limited to the following circumstances: a workplace accident, evidence of drugs and/or alcohol on or about the employee’s person or in the employee’s vicinity, unusual conduct on the employee’s part that suggests impairment or influence of drugs and/or alcohol, negative performance patterns, or excessive and unexplained absenteeism or tardiness in accordance with applicable law, random testing: employees may be selected at random for drug screening at any interval determined by Staffmark Group or its client company.

The Company may conduct random drug screens on employees where permitted by applicable law. In California, Massachusetts, Minnesota, Montana, New Jersey and West Virginia, random screening will be limited to employees in safety-sensitive positions, i.e., positions in which impairment due to drugs and/or alcohol would threaten the health or safety of any person (or as otherwise defined by applicable law). In Connecticut, Rhode Island, Vermont, Boulder, CO., and San Francisco, CA., no random screening will be conducted. The screenings conducted will be unannounced ahead of time and the dates of such screens will be spread out reasonably throughout the calendar year. As permitted by law, employees who will be subject to random screening will be put into one or more random selection pools and will be selected for screening by the Company using a valid random selection process that ensures that each employee in the selection pool has an equal chance of being selected each time a selection is conducted. Appropriate safeguards will be used to ensure that the identity of

Employees involved in an on-the-job incident may be required to drug screen, depending upon the circumstances, within 24- hours of notification at Staffmark Group’s sole discretion.

TERMINATION AND REHIRE POLICY

Applicants who refuse to cooperate in a drug screening or who test positive will not be hired and will not be allowed to re-apply/re-test for 60 days. Employees who have tested positive, or otherwise violated this policy, are subject to discipline, up to and including termination, subject to applicable law. The employee may be considered for re-employment by Staffmark Group after 60 days.

Employees who refuse to cooperate in required screens or who use, possess, buy, sell, manufacture, or dispense an illegal drug in the workplace are in violation of this policy and will be terminated.

Prescription drugs may be permitted if the product is kept in the original bottle with the original label and both the employee’s name and the prescribing doctor’s name are on the bottle. The prescription must be less than twelve months old, and written permission must be submitted from the prescribing doctor which permits the employee to work while taking the drug. This permission must be submitted to the Human Resources Department. In certain situations, the Company retains the right to obtain a second physician opinion to determine whether the drug might affect the employee’s ability to perform his/her job.

The illegal or improper use, sale or possession of narcotics, drugs, alcohol or controlled substances (including recreational or medicinal marijuana) while on the job or on Customer or Company property is prohibited and could result in disciplinary action up to and including termination, subject to applicable law. Any illegal substance will be turned over to the appropriate law enforcement agency and may result in criminal prosecution.

If an employee tests positive and is determined to be in violation of this policy, the employee will be terminated. However, an employee may request that the termination be changed to an unpaid leave by admitting to drug use and requesting rehabilitation assistance.

Employees who voluntarily enter a drug and/or alcohol rehabilitation program may be required to provide medical validation of satisfactory completion of the program. An employee who requests a leave of absence to enter a drug and/or alcohol rehabilitation program will be reasonably accommodated with an unpaid leave of absence, as required by law, to enroll in such a program if such an accommodation is not an undue hardship on Staffmark Group. Employees voluntarily entering a drug and/or alcohol rehabilitation program may be required to provide medical validation of satisfactory completion of the program. Employees returning to work following satisfactory completion of a rehabilitation program may be subject to drug and/or alcohol screens without prior notice of up to one (1) year following the return date. A recurrence of a positive drug and/or alcohol screens following return to work may lead to disciplinary action up to and including termination, subject to applicable law.