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I-11

incident and facts to the Executive Director. If an employee cannot go to his/her

Executive Director, or prefers not to, he/she can report any complaint or incident

to the Regional or Area Director, Sr. Vice President of Senior Living, Human

Resources or any officer of the Company without fear of reprisal. Management

has the responsibility of thoroughly and objectively investigating and resolving

complaints of discrimination and sexual or other harassment. Confidentiality will

be maintained, with information disclosed only to others on a need-to-know basis.

HHHunt will take prompt and appropriate action against anyone in the Company

who discriminates against or harasses another employee, which may include the

suspension or discharge of the offender.

Retaliation against an employee by any person under the CompanyÊs control for

opposing such harassment, for filing a bona fide complaint of discriminatory

harassment, or for providing information in good faith regarding another

employeeÊs complaint will not be tolerated. However, an allegation or allegations

that are fraudulent or made in bad faith will also be treated as a violation of this

policy.

COMPUTER SYSTEMS AND ELECTRONIC COMMUNICATIONS

Access to computers and electronic communications systems, e.g., e-mail and

voice mail, is provided so that employees may perform their work effectively

and efficiently. However, employees who use such equipment and systems

should be aware that in addition to the right which the Company retains to

randomly inspect company property, including such equipment and the

information/data contained therein, electronic communication systems may be

accessed and monitored by personnel who are responsible for administering

and maintaining the system. This right of access is necessary for system

management and maintenance.

Management reserves the unqualified right to access all computers, e-mail, and

other electronic files at any time, with or without notice to the employee. There

should be no expectation of privacy in the CompanyÊs property. Internal and

external electronic communications are considered business records and may be

subject to discovery in the event of litigation. Be aware of this possibility when

sending electronic communications within and outside the Company.

Appropriate Communications: In general, employees should exercise the same

restraint and caution in drafting and transmitting messages via electronic

communications as they would when writing a memorandum or letter and

should assume that someone other than the intended recipient may review their

message.

Employees are expected to exercise the same restraint and caution when

transmitting messages via cellular phones.

Communication with Residents and their Family: Whenever possible,

communication to a resident or their family by the community should occur in

person or through a telephone call. Email communication is permitted only by a

Spring Arbor Department Manager. Texting by any employee to a resident or