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Hiring Policies and Procedures

Drug Testing

DeFalco Construction Company, through its Human Resources Department, will maintain pre-employment drug screening practice  designed to prevent hiring individuals who use illegal drugs or  alcohol or whose use of illegal drugs or alcohol indicates a potential for impaired or unsafe job performance.

Procedure:

Pre-employment Consent – Each applicant competing for employment with DeFalco Construction Company and
subsidiaries requiring pre-employment health and substance screening will be required to complete a consent
document before being scheduled.

Procedure:

Results of a pre-employment health and substance screening are confidential and only designated members of the
Human Resources Department are advised of the results. Division officers of the hiring department may be
furnished results upon request with approval of the Human Resources Manager. Under no circumstances will date
obtained from results of a pre-employment health/substance screening be released to any employee, family member,
relative or friend or notarized consent of applicant. Written results of the pre-employment drug screen, if
satisfactory, will be placed in the employee’s personnel file. Unsatisfactory reports will be retained by the Human
Resources Department for a period of one (1) year, unless subjected to litigation, and then destroyed.

Random Testing:

Employees will be subjected to substance screening at any time on a random basis as a term and condition of
holding a position as an employee. Refusal by an employee to submit to random screening or test results indicating
the presence of a controlled substance shall result in immediate termination.

Rejection Criteria:

A. Alcohol

Where medical evidence indicates that at the time of application, the use of alcohol (ethanol) is determined
to be a potential safety risk or at a level to impair job performance, employment will be denied.

B. Legal Drugs

Where use of a legal, mood altering drug is detected, applicants may be required to offer proof that the drug
has been prescribed by a physician. If the applicant is unable to provide such proof, employment may be
denied. Employment may also be denied in accordance with applicable laws concerning handicapped
individuals, where future of continued use of a drug poses a potential safety risk or would impair job
performance.

C. Illegal Drugs

When the presence of an illegal drug is detected in the job applicant, employment may be denied. A
second or confirmation test may be offered within 48 hours if DeFalco Construction Company employment
staff elect. As an employee, involvement in any accident, no matter how minor, is cause for immediate
testing. Positive testing may result in employee termination.

D. Refusal to Submit

Refusal of an applicant to submit to a pre-employment health/substance screening will eliminate the
applicant from consideration.

E. Composition of Health Screen

DeFalco Construction Company will screen through use of a contracted laboratory for presence of the
following chemicals in the urine specimen provided by the applicant: Amphetamines, Cannabinoids, Cocaine (Metab.), Opiates, Phencyclidine

Work Authorization

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