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Table of Contents

WELCOME TO BRANDYWINE LIVING pg 5

Welcome Letter From Brenda

Our Beliefs and Commitments as an Organization

Our Mission

Concepts of Assisted Living

Core Values

Customer Service

Compliance Program

Alert Line

Standards of Conduct

TRUST Program

Confidentiality

Brandywine University

Handbook Purpose

SECTION 1 EMPLOYMENT POLICIES pg 13

Employment-At-Will

Pandemic Precautions

Licensure, Registration & Certification

Medical Exams

Equal Employment Opportunity / ADA

Open Door Policy

Complaint Procedure

Job Postings and Transfers

Reference and Criminal Background Checks

Employment of Relatives

Orientation Program

Introductory Period

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Performance Evaluations

Personnel Files

Change in Status

SECTION II COMPENSATION POLICIES pg 20

Classifications of Employment

Work Hours

Work Breaks

Meal Break Rules

Rest Breaks

Recording Work Time

Regular Pay Procedures

Overtime Pay Procedures

Paycheck Deductions

SECTION III TEAM MEMBER BENEFITS pg 25

Introduction

401(k) Plan

Medical / Prescription, Vision & Dental Plans

COBRA – Converting Group Health Insurance Coverage Life and Supplemental Insurance Programs

Workers’ Compensation Insurance

Paid Time Off

Holidays

Bereavement Leave

Jury Leave

Unpaid Leave of Absence

Family & Medical Leaves of Absence

Personal Leave

Military Leave

SECTION IV TEAM MEMBER CONDUCT pg 32

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Personal Conduct Guidelines

Disciplinary Procedures

Attendance & Lateness Guidelines

Termination / Resignation of Employment

Exit Interviews

Team Member Behavior & Respect

Workplace Violence Prevention

Sexual and Other Harassment

Drug / Alcohol Use & Drug Testing

Reasonable Cause

SECTION V HOUSE RULES/MISCELLANEOUS pg 39

Break in Service

Final Paycheck

Conflicts of Interest

Proprietary Information

Gifts & Gratuities

Parking

Team Member Lounge

Smoking

Cell Phone Usage, Personal Visitors, Telephone Calls Name Badges

Business Travel Expenses

Computer, Email & Internet Usage

Internet Usage

Social Networking

Mandatory Meetings and In-Service Training

Dressing & Grooming

Theft, Inspection of Packages & Right to Search

Solicitations & Distribution

Severe Weather

Team Worker Communication Meetings

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Improvement & Suggestions

BrandySTAR Program

Safety Rules

Reporting an Accident

Communicable Disease Control

Fire, Disaster & On-The-Job Safety

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Welcome Team Member

I want to welcome you to Brandywine Living and wish you every success here. Thank you for joining our team. I am confident our association will be mutually beneficial. As a leading provider of quality care and services for seniors, Brandywine Living is meeting the challenges of establishing itself as the premier senior network. We believe that each team member contributes directly to Brandywine Living’s growth and success. We carefully select our team members requiring that they must share our commitment to quality care and respect for our residents and fellow team members. Each team member has an obligation to ensure that our residents enjoy life to its fullest. Our team members, residents and their families are part of the “Brandywine family”. We want them to enjoy the peace of mind that comes with knowing we will always be there to listen and address their concerns.

This Handbook was developed to describe what we expect from our team members and to outline the policies, programs, and benefits. Our unwavering commitment to provide our team members, residents and all residents’ families with the support and encouragement needed to function at their optimum potential will remain constant.

We hope that your experience here will be challenging, enjoyable and rewarding. This Handbook provides answers to most of the questions you may have, our responsibilities to you and your responsibilities to us. If you have any questions about this Handbook or need further clarification, please discuss the matter with your human resource representative or supervisor. Again, welcome and best wishes for a great career with Brandywine! Sincerely,

Brenda J. Bacon

President and Chief Executive Officer

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Our Beliefs and Commitments as an Organization

Our first responsibility is to our residents and their families. We are committed to providing the highest quality of life and advanced medical programs to maximize the independence of each person.

Our second responsibility is to the team members of Brandywine Living. The goal of Brandywine Living is to create an atmosphere where team members want to contribute to the company.

Brandywine’s commitment to recognition, appreciation and personal development facilitates a good working environment. Listening to ideas, soliciting feedback and putting those ideas to use make Brandywine a great place to work. Our third responsibility is to the communities in which we work and live. At Brandywine, we are committed to establishing partnerships that begin and end with our communities. The foundations for building bridges between the community and the company begin and end with our residents.

Our fourth responsibility is to develop a strong management team that will effectively build a culture that facilitates respect and collaboration. Brandywine is committed to building a team that focuses on team development, goal setting, problem-solving and facilitating open communication across all levels. Brandywine Living Mission Statement

Brandywine Living will use its Interactive Care Network to provide our residents with the highest quality care in the most appropriate setting based on an individual’s needs and respecting their individuality, independence and dignity. The Concepts of Assisted Living

Assisted Living promotes the idea of “aging in place” in a residential environment for the frail elderly and for disabled adults. Aging in Place is a term that describes a Page 7

resident’s freedom to age in their own home through the provisions of additional support as needed.

Interaction and care are supportive of a resident’s ability to remain as independent as possible in both physical functioning and decision-making. Residents receive supportive health and social services as needed to maintain their individuality, independence, privacy and dignity.

The facility offers living arrangements to accommodate individuals with a varying range of abilities, limitations, needs and strengths. Assisted Living Residences

• Provide personalized services and care to meet each resident’s needs.

• Foster the independence and individuality of each resident.

• Treat each resident with respect, courtesy, kindness and dignity.

• Assure each resident the right to make choices regarding services and life- style.

• Treat each resident with respect, courtesy, kindness and dignity.

• Assure each resident the right to make choices regarding services and life- style.

• Encourage socialization and foster relationships with family and friends.

• Assure the right to privacy and confidentiality.

• Nurture the spirit and uniqueness of each resident.

• Encourage participation of families and friends in service planning and implementation.

• Provide the facility the opportunity to become a community resource. Core Values

1. We believe that every resident has the right to be treated with dignity and respect and has the right of self-determination.

2. We believe in delivering the best quality services possible to those who have put their trust in us.

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3. We believe that honesty, integrity, caring and thoughtfulness are as important as the healthcare we provide.

4. We believe that our residents are active, joyful and fascinating individuals who will continue to learn and grow each day and will contribute to our learning and growing as well.

5. Each team member shall:

• Treat each resident with respect

• Become an active listener

• Communicate clearly with residents

• Respond positively to each resident

• Take action and follow through

• Ensure each resident is satisfied

• Interact with residents, families, team members and referral sources Customer Service

Brandywine Living is committed to providing the finest customer service in the senior living industry. Our exceptional customer service is our attitude and action to deliver above and beyond what is expected. Our attitude towards customer service honors requests and delights our customers with the unexpected. Team members are expected to anticipate the wants and needs of our residents and deliver that service without hesitation as part of their commitment to Go the Distance every day.

A Commitment to Do Things Right the Brandywine Compliance Program

The successful business operation and reputation of Brandywine Living is built upon the principles of fair dealing and ethical conduct of our team members. Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations. Brandywine has scrupulous regard for the highest standards of conduct and personal integrity. In general, the use of good judgment, based on high ethical principles, will guide team members with respect to acceptable conduct.

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Brandywine Living will therefore comply with all applicable laws and regulations. Brandywine expects directors, officers and team members to conduct business in accordance with the letter, spirit, and intent of all relevant laws and to refrain from any illegal, dishonest or unethical conduct.

Team members are expected to inform their supervisor and/or department head should they have knowledge of any illegal or dishonest activities or violations of any federal, state or local laws; any billing for services not performed or for goods not delivered; the filing of any false, fraudulent or improper record with any federal, state or local governmental agency; and/or any other fraudulent or improper financial, accounting or auditing matter.

If a situation arises in which a team member raises a concern with their supervisor and/or department head but continues to have reasonable grounds to believe that the supervisor and/or department head has not properly addressed the concern, the team member should next report the concern to the Executive Director and/or their human resources representative. Alternatively, if the team member is uncomfortable speaking to their supervisor and/or department head, or if their supervisor and/or department head is the subject of the concern, then the team member should report the concern directly to the Executive Director and/or their human resources representative. If after discussing a concern with the Executive Director and/or their human resources representative and a team member continues to have reasonable grounds to believe that the concern has not been properly addressed, or if any reason the team member is not comfortable discussing the concern with their supervisor, Executive Director and/or human resources representative, then the team member should contact the Brandywine Alert Line at 1-888-***-**** where the call will remain anonymous if desired. Team members reporting any alleged illegal and/or fraudulent activity will be protected against any form of retaliation and the confidentiality of the team member will be maintained as allowed in compliance with the law.

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Compliance with this policy of business ethics and conduct is the responsibility of every Brandywine team member. Disregarding or failing to comply with this standard of business ethics and conduct could lead to disciplinary action, up to and including possible termination of employment.

The Brandywine Alert Line 1-888-***-****

Although all levels of management are available to discuss any questions or concerns, the Brandywine Alert Line is available 24 hours a day, seven days a week. It is the team member’s responsibility to report any violations, suspected violations or questionable practices. All concerns may be reported to the Alert Line anonymously or by self- identification. All questions will be forwarded to the corporate compliance officer for review and follow up. Brandywine forbids any retaliation against any team member reporting a concern.

The Brandywine Standards of Conduct

Brandywine Living provides the highest level of care and services to our residents and their families with ethics and integrity in everyday decisions. Compliance with the following Standards of Conduct is essential for the accomplishment of our mission, and as a reminder that we are all responsible for our actions. We are committed to doing the right thing for our residents at all times.

Brandywine Living and its team members are committed to the following Standards of Conduct:

• Treating each resident, each resident’s family and fellow team member with dignity and respect.

• Treating each Resident with Understanding, Sincerity and Tenderness

(T.R.U.S.T.).

• Doing the best job possible in a manner that complies with all laws and regulations.

• Conducting business in an ethical manner at all times.

• Promoting a positive and non-discriminatory work environment. Page 11

• Working safely to protect our residents and fellow team members.

• Keeping accurate and complete records.

• Assuring the confidentiality of client and team member information.

• Promoting the highest standards of personal integrity.

• Using good judgment in daily decision making and asking for assistance if a proper course of action is not clear.

• Presenting only truthful and accurate information regarding Brandywine Living and its entities.

• Reporting anything that team members see that violates these Standards of Conduct, Brandywine Living policies or the law.

• Maintaining an alcohol, drug and theft free workplace. T.R.U.S.T. – A Zero Tolerance for Abuse Program

Brandywine Living has made a commitment to an environment of care that does not tolerate abuse of our residents. Individuals

entrusted into our care are deserving of the highest quality of care, and that quality begins with T.R.U.S.T. We are committed to a progressive program of T.R.U.S.T: Treating Residents with Understanding Sincerity & Tenderness Confidentiality/HIPPA

All information given about our residents and team workers is confidential. The law protects our residents’ right to privacy and protects patient data from inappropriate disclosure or use as well as providing safeguards in unauthorized access to patient information systems. It is essential that team members direct any questions concerning a resident or his or her condition to the nurse in charge. Any unauthorized team member sharing information about a resident, team member or record without permission will be subject to disciplinary action up to and including termination. Brandywine University:

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Our Commitment to Team Members’ Development

Everyone at Brandywine is committed to ensuring that our residents enjoy life to its fullest. Our success goes beyond delivery of quality care and services. One key to our success is Brandywine University, where we focus on motivating, inspiring and enabling team members through orientation, training and resident satisfaction programs. All Brandywine team members are required to attend certain courses offered through Brandywine University. A variety of other voluntary courses are also available. For more information, team members should contact their human resource representative.

Handbook Purpose

This Handbook has been prepared to acquaint team members with our employment practices, policies and codes of conduct. We realize that this Handbook can never anticipate every circumstance or question about a policy. Should team members have questions or need clarification, please speak to the facility human resource representative or supervisor. It is through a person-to-person conversation that views are expressed and harmonious relationships develop. Page 13

SECTION I EMPLOYMENT POLICIES

Employment-At-Will

Employment with Brandywine Living is voluntarily entered into and continues at the will of both parties. Similarly, Brandywine Living may terminate the employment relationship at will, at any time, with or without notice or cause, so long as there is no violation of applicable federal or state law.

Policies set forth in this Handbook are not intended to create a contract, nor are they to be construed to constitute contractual obligations of any kind or a contract of employment between Brandywine Living and any of its team members. Brandywine Living reserves the right to revise, supplement, rescind or cancel any policies or portions of the Handbook as necessary and appropriate, at its sole and absolute discretion, except for the policy of employment-at-will. Any oral modifications of team members’ employment are not company policy and are not binding. No modification of the employment-at-will relationship between Brandywine Living and any team member will be binding unless in writing, signed by both the team member and the President/Chief Executive Officer or her authorized designee. Pandemic Precautions

During a global pandemic, applicable law requires Brandywine Living to take certain precautionary health measures. In order to maintain the highest quality care for our residents and safety for all those who are part of the “Brandywine family,” Brandywine will go above and beyond minimum legal requirements. Therefore, Brandywine reserves the right to require residents, team members and others seeking access to our communities to undergo regular COVID-19 testing and obtain annual flu shots. Licensure, Registration and Certification

Certain positions at Brandywine require team members to have a license, registration or certification. In order to comply with the law, team members must furnish proof that Page 14

the license, registration or certification is current before starting employment. It is the team member’s responsibility to renew their license as required by law, provide verification to their supervisor and to notify all appropriate agencies of name or address changes. If team members do not renew their license, registration or certification on a timely basis, team members may not be able to continue employment with Brandywine Living.

Medical Exams

As part of Brandywine Living’s employment procedures, an applicant may be required, post offer, to have a physical examination by a physician designated by Brandywine. Where federal law, state law or Brandywine policy dictates, team members may be required to have other tests like tuberculosis, drug screening or hepatitis vaccines. As a condition of continued employment, team members may also be required to undergo periodic medical examinations to the full extent permitted under the law, and/or alcohol and drug screenings.

Equal Employment Opportunity/Disability Accommodation (ADA) In order to provide equal employment and advancement opportunities to all individuals, employment decisions at Brandywine will be based on merit, qualifications and abilities. Brandywine does not discriminate in employment opportunities or practices on the basis of race, creed, religion, color, national origin, ancestry, age, sex, gender identity, affection or sexual orientation, marital status, familial status, atypical heredity, cellular or blood trait, genetic information, disability and liability for service in the United States armed forces or any other legally protected status. Brandywine will make reasonable accommodations for qualified applicants or team members with known physical or mental dis- abilities unless the accommodations would impose undue hardship to the operation of its business. This policy governs all aspects of employment, including selection, job assignment, compensation, discipline, termination, access to benefits and training.

If a team member has a question or concern about any type Page 15

of discrimination in the workplace they are encouraged to bring these issues to the attention of their supervisor or the human resources representative. Team members can raise concerns and make reports without fear of reprisal. Anyone found to be engaging in any type of unlawful discrimination will be subject to disciplinary action, up to and including termination of employment. If for any reason team members are not comfortable discussing any matter with their supervisor or other management personnel, contact should be made with the Brandywine Alert Line at 1-888-***-**** where the call will remain anonymous if desired. Open Door Policy

We encourage team members to bring their questions, suggestions and concerns to our attention. If team members feel they have a problem, they should first present the situation to their supervisor or the department head so the problem can be settled by examination and discussion of the facts. We hope they will be able to satisfactorily resolve most matters. If, however, the team member finds they still have questions after meeting with the supervisor and/or the department head or if the team member would like further clarification on the matter, they may request a meeting with the facility human resource representative, Executive Director or call the Brandywine Alert Line at 1-888-***-**** where their call will remain anonymous if desired. Complaint Procedure

Each member of management is responsible for creating an atmosphere free of discrimination and harassment. Further, team members are responsible for respecting the rights of others.

If any team member experiences any job-related harassment based on sex, race, national origin, religion, age, disability, or other legally protected status, or believes they have been treated in an unlawful, discriminatory manner, the incident should be promptly reported to their supervisor and/or department head, who will investigate the matter and take appropriate action, including reporting it to the Executive Director. If a team member believes it would be inappropriate to discuss the matter with the supervisor and/or department head, the team member may bypass the supervisor and/or Page 16

department head, and report it directly to the Executive Director and/or human resources representative, who will conduct an investigation. Complaints will be kept confidential to the maximum extent possible. If Brandywine Living determines that a team member violated this policy, appropriate disciplinary action will be taken against the offending team member, up to and including termination of employment. Brandywine Living prohibits any form of retaliation against any team member for filing a bona fide complaint under this policy or for assisting in a complaint investigation. However, if, after investigating any complaint of harassment or unlawful discrimination, Brandywine Living determines that the complaint has knowingly provided false information regarding the complaint, disciplinary action may be taken against the individual who filed the complaint or who intentionally and/or maliciously gave the false information. If for any reason team members are not comfortable discussing any matter with their supervisor or other management personnel, contact should be made with the Brandywine Alert Line at 1-888-***-**** where the call will remain anonymous if desired.

Job Postings and Transfers

Brandywine supports the advancement of team members from within the organization and has established a job-posting program to give all team members an opportunity to apply for positions in which they are interested and for which they are qualified. To be eligible to apply for a position, the applicant must meet the minimum hiring specification for the position, be capable of performing the essential functions of the job, with or without a reasonable accommodation, be a team member in good standing in terms of overall work record and generally have been in their current position for a minimum of six months. To be considered for another position, team members must complete and forward a Transfer Request Form acknowledged by team member’s current supervisor’s signature to the human resource representative. In selecting the best candidate for the job, Brandywine reserves the right to advertise or seek team members from other sources while simultaneously posting the position within the facilities.

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Reference and Criminal Background Checks

In evaluating and verifying an individual’s qualifications for employment, Brandywine conducts reference checks on applicants. In addition, a criminal history record check will be conducted per state requirements for work in all Brandywine locations. Employment of Relatives

Brandywine Living permits the employment of qualified relatives of team members as long as such employment does not, in the opinion of Brandywine, create actual or perceived conflicts of interest. For purposes of this policy, “relative” is a spouse, significant other in the same household, child, parent, sibling, grandparent, grandchild, aunt, uncle, first cousin, or corresponding in-law or “step” relation. Brandywine will exercise sound business judgment in the placement of related team members in accordance with the following guidelines:

Relatives are permitted to work in the same facility, provided no direct reporting or supervisory and/or management relationship exists. That is, no team member is permitted to work within the “chain of command” of a relative such that the supervisor could influence the responsibilities, salary, or the career progress of the other relative. No relatives are permitted to work in the same department or in any other positions in which Brandywine believes an inherent conflict of interest may exist. Orientation Program

During the first days of employment, no later than the first 30 days, each team member will participate in a general orientation pro- gram conducted by the human resource representative including the Executive Director and various members of the facility management team. The program will provide important information regarding the performance requirements of the team member’s position, basic Brandywine Living policies, compensation and benefit programs as well as information necessary to acquaint the team member with their job.

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All necessary paperwork will be completed on or before the first day of employment including federal, state, and local tax forms.

At this time, team members will be required to present Brandywine with information establishing their identity and eligibility to work in the United States in accordance with applicable federal law.

Introductory Period

Team members’ first ninety (90) days of employment are considered to be their training period. During this introductory period, team members will have the opportunity to receive guidance and training to develop the skills necessary for successful accomplishment of their job routine. The supervisor will instruct and counsel the team member regarding performance requirements and expected standards of their position. If performance is satisfactory, team members will be considered to have completed their introductory period. In some cases, if performance requires further evaluation, the introductory period may be extended.

In cases of promotions or transfers within Brandywine, a team member will begin a new introductory period. If the team member is not successful in the new position, at the sole judgment of management, the team member can be removed from that position at any time. If this occurs, the team member may be allowed to return to the former or comparable position, if qualified, depending on the availability of such positions and facility needs.

Performance Evaluations

Written evaluation of a team member’s job performance may be completed by the supervisor or department head after approximately 90 days of work or at any other time as deemed necessary. Team members and supervisors are strongly encouraged to discuss job performance and goals on an informal, frequent basis. Performance evaluations are conducted at the end of the introductory period, annually and when needed. After the review, the team member will be asked to sign the evaluation. The team member’s signature verifies that the evaluation has been reviewed with them. It does not signify that the team member agrees or disagrees with the evaluation. The Page 19

original date of hire will be maintained for benefits and calculating compensated time off.

Personnel Files

Brandywine Living maintains personnel files on each team member. These files contain documentation regarding all aspects of the team member’s tenure with Brandywine such as performance appraisals, beneficiary designation forms, disciplinary warning notices and letters of commendation. A team member may arrange time to review their personnel file by contacting the human resource representative. All personnel files are to remain confidential, unless there is a valid and appropriate business reason for access. Personnel files become exclusive property of the Company and access to the file is denied once the employment relationship is severed. Change in Status

In order to maintain up-to-date records, it is the responsibility of each team member to promptly notify their supervisor and the human resource representative of any changes to the following:

• Name

• Address

• Telephone number

• Number and names of dependents

• Individuals to contact in the event of an emergency

• Educational accomplishments including seminar work

• Beneficiaries

• Marital Status

• Renewed licenses, registrations or certifications

• Life changing events like marriage, divorce, birth (benefits only) Page 20

SECTION II COMPENSATION POLICIES

Classifications of Employment

For the purposes of salary administration and eligibility for overtime payments and benefits, Brandywine Living classifies its team members as follows: Exempt: Team members who are not paid overtime, in accordance with applicable federal

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