MCKESSON MEDICAL-SURGICAL IMPORTANT HUMAN RESOURCES POLICIES

Page created by Wesley Simpson
 
CONTINUE READING
MCKESSON MEDICAL-SURGICAL IMPORTANT HUMAN RESOURCES POLICIES
McKesson Medical-Surgical
   Important Human
   Resources Policies
MCKESSON MEDICAL-SURGICAL IMPORTANT HUMAN RESOURCES POLICIES
Introduction to McKesson Medical-Surgical
Important Policies
The purpose of this document is to present core policies and practices for McKesson Medical-Surgical in one reference source. In
addition to the policies in this document, other Enterprise HR and McKesson Medical-Surgical policies and procedures are also posted
on McKNet. The information provided here applies only to McKesson Medical-Surgical locations in the United States.

It is your responsibility to read this information carefully as it is a valuable reference for understanding your job and the Company’s
expectations of you. The core policies included in this Summary, which include both Enterprise HR Policies and McKesson Medical-
Surgical policies, along with policies posted on McKNet, supersede all previously issued Policy Manuals and employee Handbooks on
the subjects discussed in those materials. They also supersede all inconsistent verbal or written policy statements. Except for the policy
of At-Will Employment, which can only be changed in writing by the Company’s Executive Vice President, Human Resources, the
Company reserves the right to revise, supplement, amend, or supersede policies at any time. We will try to inform you of any changes
to policies and procedures as they occur. Revised policies and procedures will modify, supersede or eliminate existing policies. No
oral statements or promises can change or modify Company policies. Nothing in any Company policy is intended or should be
construed to violate any local, state or federal law or regulation or constitute a contract (either express or implied) between the Company
and its employees.

Other Company Policies
As noted above, not all Company policies and procedures are included in this document. Although this document includes a number of
important Company policies, there are other Enterprise HR policies and practices and McKesson Medical-Surgical policies and practices
that are posted on McKNet, you are required to abide by, including the policies and practices at the business unit where you work if a
collective bargaining agreement applies to you, you should refer to that agreement to understand the extent to which that agreement
supersedes any company policies. Disregarding or failing to comply with any applicable policy or procedure could lead to disciplinary
action, up to and including termination of employment.

Information and Policies Included in This Summary
 A.   Introduction to our Team                                        I.   Solicitation and Distribution of Written Materials *
 B.    Our Shared Principles - ICARE                                  J.   Standards of Workplace Behavior *
 C.    Anti-Harassment *                                              K.   Substance Abuse Prevention & Testing Policy *
 D.    At-Will Employment *                                           L.   Nonexempt Attendance Policy *
 E.    Equal Employment Opportunity *                                 M.   Medical-Surgical: Searches and Inspections +
 F.    Open Door Policy *                                             N.   Medical-Surgical: Personal Appearance +
 G.    Performance and Behavior that Violates our Standards *         O.   Policy Against Work Related Violence *
 H.   Smoking Policy for the Workplace *
*McKesson Enterprise Policy
+Medical-Surgical Policy

Contact
For further guidance, contact the HR Support Center at 1-855-GoMcKHR (1-855-466-2547).
A. Introduction to our Team
We are very glad to have you as a member of the McKesson Medical-Surgical (“the Company”) team. We believe that you have a great
contribution to make to the Company, and that you will find your employment at the Company a rewarding experience. We look
forward to the opportunity to work together to create a more successful Company. We also want you to feel that your employment
with the Company will be mutually beneficial and gratifying.

You have joined an organization that has established an outstanding reputation for quality. Credit for this goes to everyone in the
organization. We hope you find satisfaction and take pride in your work here. As a member of the Company’s team, you are expected
to contribute your talents and energies to further improve the environment and quality of the Company. In turn, the Company
intends to provide you with all of the support and the resources you will need to perform your job effectively. If, at any time, you need
assistance or guidance, please do not hesitate to ask any of the members of your management team. They are here to help you
perform to the best of your abilities.

B. Our Shared Principles – ICARE
ICARE is a set of shared principles that helps align us on how to perform our mission-critical work. It's more than a set of words and
phrases. ICARE is a way of life at McKesson and is part of everything we do. Because every one of us shares a commitment to ICARE,
McKesson stands out as a healthcare company that's a cut above the rest—and as an exceptional place to work.

Know the Five Principles

Integrity
The "I" in ICARE represents the first letter in ICARE and gives all of us at McKesson a marker we can use to choose the right path to
take in tough situations. McKesson stands out as a company that does what it promises and doesn’t take shortcuts. As individuals we
can take pride in our contribution.

Customer-First
Our customers, internal and external, are at the center of everything we do. The customer-first principal fosters our devotion to
making customers happy.

Accountability
Our willingness to step up and take responsibility sets us apart. McKesson employees are known for their personal commitments to
their customers, their vendors, their colleagues and their jobs. For McKesson, there's nothing more important than trust in the type of
work we do.

Respect
Respect sets the tone for a workplace where employees treat each other, our customers and our vendors with dignity, consideration
and open-mindedness.

Excellence
Our excellence is how we define our difference to our customers, and the journey to excellence never ends. In each project, each
interaction, each product we release, each tote we deliver, we tirelessly work to deliver more than just "good" solutions.
C. Anti-Harassment, Non-Discrimination and Non-
Retaliation
Overview:
The Company is committed to providing a professional work environment that is free of unlawful harassment, discrimination and
retaliation.

Applies To:
This policy protects all applicants and employees (including, without limitation, unpaid interns) from unlawful harassment,
discrimination and retaliation caused by any employee of the Company, including supervisors and managers, as well as vendors,
customers, Outside Services Workers and other third parties not employed by the Company who come into contact with Company
employees because of Company business. This policy also protects Outside Services Workers from harassment. If harassment,
discrimination or retaliation occurs on the job by someone not employed by the Company, the procedures in this policy should be
followed.

Policy Details:
The Company is committed to providing a professional work environment that is free of unlawful harassment, discrimination and
retaliation. The Company strictly prohibits harassment and discrimination based on an individual’s race, religion creed, color, national
origin, ancestry, citizenship, sex (including pregnancy, childbirth breastfeeding and medical conditions related to pregnancy, childbirth
or breastfeeding), age, marital or registered domestic partnership status, military or veteran status, mental or physical disability,
medical condition (including cancer and genetic characteristics), genetic information, sexual orientation, gender, gender identity or
expression, political affiliation, or other legally protected characteristic (“Protected Characteristics”). The Company also strictly
prohibits retaliation against any employee for exercising their rights under this policy.

What Harassment Is
Harassment includes verbal, visual or physical conduct that denigrates or shows hostility toward an individual or creates a hostile,
offensive or intimidating work environment because of a Protected Characteristic. Conduct perceived to be harassing and unwelcome
may be considered harassment, even if it was not intended to be offensive.
Some examples of prohibited conduct may include the following when such conduct is based on a Protected Characteristic:
•   verbal conduct such as making derogatory, demeaning, or threatening epithets, jokes, comments or slurs
•   visual conduct such as displaying, distributing, or sending derogatory, demeaning, or threatening posters, Internet websites,
    photographs, cartoons, drawings, gestures, emails, texts, instant messages, voicemails or other electronic information
•   physical conduct such as assault; unwanted touching; accessing, storing, or sharing electronic information using company
    information systems; possessing materials on company property or while on company business; and other actions that may offend
    or create fear or intimidation due to an individual’s Protected Characteristic

What Sexual Harassment Is
Sexual harassment is a type of harassment prohibited by the Company. It may occur when submission to or rejection of unwelcome
sexual conduct is used as a basis for employment decisions, or when submission to sexual harassment is a condition for receiving
employment benefits, promotions, raises, etc. Sexual harassment also may occur when unwelcome sexual conduct unreasonably
interferes with job performance or creates an intimidating, hostile, or offensive working environment, even if it does not lead to tangible
or economic job consequences.
Some examples of prohibited conduct may include:
•   basing an employment decision or purporting to place an employment decision, like hiring, promotion, retention or compensation
    on whether an employee or candidate accepts sexual advances
•   making statements or threats that imply a link between an employee's sexual conduct and his or her employment status,
    advancement potential or compensation
•   displaying, distributing, downloading, accessing, storing, sharing, possessing on company property or while on company
    business, or otherwise using company information systems to view, sexually explicit, suggestive or demeaning objects or pictures,
    including graphic cartoons, photographs, drawings, Internet websites, calendars, or magazines of a sexually explicit, suggestive or
    demeaning nature
•   making demeaning, lewd or suggestive comments about someone's personal life, dress, body or appearance
•   sending e-mail, text, instant messaging, voicemail or other electronic information of a sexually explicit, suggestive or demeaning
    nature
•   persistently asking employees for dates despite indications that the invitations are unwanted making sexually explicit, suggestive
    or offensive remarks, innuendoes and jokes
•   engaging in unwanted physical contact, such as patting, pinching, brushing up against, hugging, cornering, kissing, or fondling
Hostile treatment of a sexual nature can amount to unlawful sexual harassment whether or not motivated by sexual desire. Sexual
harassment includes harassment of women by men, of men by women, and same-sex harassment.

What Discrimination Is
Discrimination is making an employment decision, denying someone an employment benefit or otherwise treating someone less
favorably, based on a Protected Characteristic. As discussed in our Equal Employment Opportunity Policy, the Company prohibits
discrimination with respect to all terms and conditions of employment, including (without limitation) recruitment, selection, hiring,
training, promotion, compensation, benefits, transfer, performance management, discipline, termination, and participation in company
events and programs.

What Retaliation Is
Retaliation is an adverse action taken against someone because he or she filed a charge of discrimination, harassment or retaliation,
complained to his or her employer or other covered entity about discrimination, harassment or retaliation on the job, participated in an
employment discrimination, harassment or retaliation proceeding (such an investigation or lawsuit) or otherwise exercised rights under
this policy. Examples of adverse actions include, but are not limited to: (1) employment actions such as termination, refusal to hire,
and denial of promotion, (2) other actions affecting employment such as threats, unjustified negative evaluations, unjustified negative
references, or increased surveillance, and (3) any other action that is likely to deter reasonable people from pursuing their rights.

Preventing Harassment, Discrimination and Retaliation
McKesson Corporation takes the following steps to help prevent harassment, discrimination and retaliation:
•   each complaint is timely, thoroughly, fairly and impartially investigated, and if harassment, discrimination or retaliation has
    occurred, corrective action will be taken (which may include discipline, up to and including termination);
•   managers are held accountable for providing an environment free of harassment, discrimination and retaliation; and
•   open lines of communication encourage employees to talk to managers so problems can be investigated and resolved.
Filing a Complaint Internally
If you believe that you have been unlawfully harassed or subject to discrimination or retaliation, or that you have witnessed or
otherwise become aware of unlawful harassment, discrimination or retaliation or conduct that violates this policy,, immediately report
your concerns to your supervisor, any member of management, or to Human Resources through the Human Resources Support
Center at 1-855-Go-McKHR. Complaints should be as detailed as possible, including the names of individuals involved, the names of
any witnesses, direct quotations when language is relevant, and any documentary evidence (notes, pictures, cartoons, etc.).
Supervisors who become aware of complaints of harassment, discrimination or retaliation must promptly report such complaints to
Human Resources or any member of management.
After you file a complaint, the Company will conduct a timely, thorough, fair and impartial investigation of the incident or incidents,
either by qualified employees of the Company, or by an outside investigator. The investigation will be documented, and the Company
will track the investigation to make sure it is progressing on a reasonable timeframe. The investigation will provide all parties
appropriate due process. It will be completed and a determination will be made as soon as practical. The Company will reach
reasonable conclusions based on the evidence collected in the investigation, and the results of the investigation will be communicated
to the complaining party as soon as practical.
Complaints and investigations will be handled discretely. The confidentiality of complaints and investigations will be maintained to the
extent possible, and will be shared only on a need-to-know basis.
During an investigation, you may be asked questions like:
•    Who discriminated against, retaliated against or harassed you?
•    What did the individual do? (Specifics are important.)
•    What did you do in response?
•    When did the activity take place?
•    If relevant, where did the activity take place?
•    Were there any witnesses?
•    Who did you tell?
All managers and employees have a duty to cooperate in the Company's investigation of alleged harassment, discrimination and/or
retaliation. Failing to cooperate, providing false information or making a false complaint or false charges during an investigation (in
contrast to a complaint or charges which are erroneous but made in good faith) shall be grounds for disciplinary action, up to and
including termination.
Information gathered from the investigation will be reviewed, and the Company will decide if any corrective action should be taken,
based on the individual circumstances. If it is determined that a violation of this policy has occurred, appropriate remedial measures
will be taken consistent with the severity of the conduct.
The Company will also take steps as necessary to prevent further harassment, discrimination or retaliation. Because a workplace free
of harassment, discrimination and retaliation is so important, the Company may take disciplinary action against an employee who
exhibits poor judgment or engages in inappropriate conduct, even if the conduct falls short of constituting unlawful harassment,
discrimination or retaliation.
In all cases, the Company will take steps to ensure a safe work environment for you and your fellow employees.
If you have concerns about how an investigation has been handled, contact the Human Resources Support Center or the McKesson
Integrity Line.

Filing A Complaint With An Agency
The Company encourages all employees to report any incidents of harassment, discrimination or retaliation immediately to their
supervisor, any member of management, or to Human Resources so that complaints can be quickly and fairly resolved. Employees
also should be aware that the Federal Equal Employment Opportunity Commission (“EEOC”) and the California Department of Fair
Employment and Housing (“DFEH”) and other state agencies investigate and prosecute complaints of prohibited harassment,
discrimination and retaliation in employment. If an employee thinks they have been harassed, discriminated against or retaliated
against, they may file a complaint with the appropriate agency.

The Company’s Policy Against Retaliation
The Company will not retaliate against an employee who in good faith:
•   files a complaint of harassment, discrimination or retaliation;
•   files, testifies, participates, or assists in an authorized harassment, discrimination or retaliation investigation;
•   opposes harassment, discrimination or retaliation in the workplace;
•   or otherwise exercises rights under this policy.
The Company will not tolerate retaliation by management, employees, or co-workers.
Any report of retaliation will be investigated in a timely, thorough, fair and impartial manner in accordance with the procedures outlined
above, and appropriate remedial action will be taken.

    Policy            Discrimination is making an employment decision, denying someone an employment benefit or
                      otherwise treating someone less favorably, based on a Protected Characteristic.
    Definitions:
Harassment includes verbal, visual or physical conduct that denigrates or shows hostility toward an
              individual or creates a hostile, offensive or intimidating work environment because of a Protected
              Characteristic. Conduct perceived to be harassing and unwelcome may be considered harassment, even
              if it was not intended to be offensive.
              Outside Services Worker is defined in McKesson’s Outside Services Policy.
              Retaliation is an adverse action taken against someone because he or she filed a charge of
              discrimination, harassment or retaliation, complained to his or her employer or other covered entity about
              discrimination, harassment or retaliation on the job, participated in an employment discrimination,
              harassment or retaliation proceeding (such an investigation or lawsuit) or otherwise exercised rights under
              this policy.
              Sexual Harassment is a type of harassment that may occur when submission to or rejection of
              unwelcome sexual conduct is used as a basis for employment decisions, or when submission to sexual
              harassment is a condition for receiving employment benefits, promotions, raises, etc. Sexual harassment
              also may occur when unwelcome sexual conduct unreasonably interferes with job performance or creates
              an intimidating, hostile, or offensive working environment, even if it does not lead to tangible or economic
              job consequences.
Related Policies
                      •   Code of Conduct
                      •   Equal Employment Opportunity
                      •   Gender Transition Policy
                      •   Performance and Behavior that Violates our Standards
                      •   Religious Accommodation
                      •   Standards of Workplace Behavior

Contacts:             •   Director, Workforce Compliance. Current: Susan Nachazel susan.nachazel@mckesson.com

                      If you have any questions about this Policy please contact the Human Resources Support Center
                      at 1-855-Go-McKHR.
D. At-Will Employment
Overview
This document describes the Company's at-will employment policy.

Applies To
All U.S. regular employees (full-time, part-time or McKesson temporary employees), except those employees who work pursuant to a
collective bargaining agreement (CBA) where the CBA provides otherwise.

Our Company Policy
Employment at the Company is at-will except for those employees who work pursuant to a CBA where the CBA provides otherwise.
This means that unless you are employed pursuant to such a CBA:
    •   Neither you nor the Company have entered into a contract regarding the duration of your employment.
    •   The Company has the right to terminate your employment, or otherwise discipline, transfer, or demote you, or change your
        job duties or responsibilities at any time, with or without cause, at the discretion of the Company.

Regardless of whether you work pursuant to such a CBA, you are always free to terminate your employment with the Company at any
time, with or without cause.

The Company does and will continue to comply with all applicable laws regarding employment. No representative of the Company can
enter into an agreement contrary to this policy without written approval from the Company's Executive Vice President, Human
Resources.

Questions
Call the HR Support Center at 1.855.Go.McKHR (1.855.466.2547).
E. Equal Employment Opportunity
Overview
This document describes the Company's equal employment opportunity policy, which sets forth our commitment to providing equal
opportunity for all applicants, employees and contingent workers, and our prohibition against unlawful discrimination and retaliation.

Applies To
This commitment applies to applicants, employees, Outside Services Worker and all persons involved in Company operations and
prohibits unlawful discrimination by any employee of the Company. All share in the responsibility for ensuring that these values are
upheld. This policy applies to all terms and conditions of employment, including (without limitation) recruitment, selection, hiring,
training, promotion, compensation, benefits, transfer, performance management, discipline, termination, and participation in
company events and programs.

Our Company Policy
As part of our commitment to our values of integrity, respect and excellence, the Company is an equal opportunity employer and is
committed to providing an environment free from unlawful discrimination, harassment and retaliation. The Company is committed to
compliance with all applicable laws providing equal employment opportunities.

We do not make employment decisions because of race, religious creed, color, national origin, ancestry, citizenship, sex (including
pregnancy, childbirth, breastfeeding and medical conditions related to pregnancy, childbirth or breastfeeding), age, marital or
registered domestic partnership status, military or veteran status, mental or physical disability, medical condition (including cancer
and genetic characteristics), genetic information, sexual orientation, gender, gender identity or expression, political affiliation, or other
legally protected characteristic. McKesson provides reasonable accommodations for otherwise qualified disabled applicants and
employees. (Please see McKesson’s Reasonable Accommodation Policy for further detail). McKesson also provides reasonable
accommodations to employees whose religious beliefs, practices or observances conflict with their employment. (Please see
McKesson’s Religious Accommodation Policy for further detail).

Discrimination and Retaliation

If you believe you have been subjected to or witnessed any form of unlawful discrimination, you should immediately inform your
recruiter (if you are an applicant), your supervisor, any member of management, or to Human Resources through the Human
Resources Support Center at 1-855-Go-McKHR (1-855-466-2547).

The Company strictly prohibits retaliation against any employee, applicant or Outside Services Worker who in good faith uses this
reporting procedure, files, testifies, assists or participates in an authorized investigation, proceeding or hearing, or opposes
discrimination against others, as described further in the Company’s Anti-Harassment, Non-Discrimination and Non-Retaliation
Policy. Any employee, applicant or contingent worker who believes that they have experienced or witnessed retaliation must
immediately report such conduct to his or her recruiter (if an applicant), supervisor, any member of management, or to Human
Resources through the Human Resources Support Center.

The Company will investigate any report of discrimination or retaliation and will take effective corrective action as appropriate, as
described further in the Company’s Anti-Harassment, Non-Discrimination and Non-Retaliation Policy.
Our Affirmative Action Plans
As a federal contractor, the Company has adopted affirmative action plans, which mean the Company will not make any decisions
based on any of the above categories and will take affirmative action to ensure the availability of employment opportunities without
regard to such factors. Kristi Williamson, Director of AAP/EEO, is responsible for leading McKesson’s affirmative action efforts.

Contacts
Affirmative Action Plans may be reviewed by employees and applicants by contacting Kristi Williamson during business hours at
kristi.williamson@mckesson.com or 972.446.5724.

Questions
Call the HR Support Center at 1.855.Go.McKHR (1.855.466.2547).

Related Policies
Hammergren Reaffirmation Letter – May 2011
F. Open Door Policy
Open Door Policy
Open communication is essential to a successful, productive workplace. McKesson wants all employees to have the opportunity to raise
concerns safely, and without fear of reprisal. We have developed our Open Door Policy for all employees, to encourage and facilitate
active dialogue about issues. While our Open Door Policy may not satisfactorily resolve every situation, we know that active, open
communication leads to the resolution of the vast majority of workplace issues.

Why This Policy is Important
Our ICARE shared principles of Integrity, Customer-first, Accountability, Respect, and Excellence serve to unite and guide us in how
we treat our customers and treat each other. We believe that open communication about issues and concerns is a reflection of these
values and helps foster a work environment of mutual trust and respect.

While we strive to conduct ourselves with the best of intentions, we know that workplace concerns, disagreements, and disputes
sometimes arise – whether between coworkers, employees and managers, or third parties.

McKesson’s Open Door Policy is designed to encourage McKesson employees to engage in dialogue and feedback, address concerns
and resolve problems in a thoughtful manner.

How the Open Door Policy Works
McKesson’s Open Door Policy applies to all employees and consists of a three-tiered review process, outlined below. The process
provides you with several opportunities to present issues or disputes to progressively higher levels of management for consideration
and action. Please be sure to review the list of issues covered by the Open Door Policy below to ensure that this is the appropriate
process for raising your issue.

Any employee wishing to raise or escalate a concern should begin with Step One and may advance to higher steps if appropriate. In
order to maintain the integrity of this process, employees should not skip steps, unless there is a compelling reason to do so. The
objective of this process is to get parties talking openly and as quickly as possible so that they can reach a resolution in a fair and
objective manner. Rest assured that McKesson will not retaliate against an employee who exercises his or her rights under the Open
Door Policy in good faith.
STEP           WHEN                     WHOM YOU TALK TO               WHAT HAPPENS
One –          When you first have a    Your supervisor, any           Meet one-on-one with your manager.
Open Door      concern that you want    member of management
               to raise.                with whom you are              You or your manager may also request that
                                        comfortable, or to Employee    Employee Relations facilitate the discussion.
                                        Relations through the
                                        Human Resources Support
                                        Center.

Two –          When Step One does       A manager at least one level   Open Door Second Level Review form should
Escalation     not resolve the issue,   of management above the        be completed and forwarded to the Employee
               you may escalate to      manager you spoke with in      Relations Representative you spoke with in
               Step Two.                Step One                       Step One.

                                        and
                                                                       Employee Relations will conduct a review of
                                        An Employee Relations          Step One and may request additional
                                        Manager or Senior Director.    information that will be used to conduct
                                                                       further investigation.

Three –        When Step Two does       A senior business leader at    Written notification requesting further review
Final Review   not resolve the issue,   least one level above the      should be forwarded to the Employee
               you may escalate to      senior leader you spoke with   Relations Representative you spoke with in
               Step Three.              in Step Two (no higher than    Step Two.
                                        the Business Unit President
                                        or Corporate Function          Decisions reached in Step Three are made
                                        Executive Vice President)      with the utmost care and are considered final
                                                                       and therefore not subject to additional
                                        and                            review.

                                        An Employee Relations
                                        Senior Director or Vice
                                        President.
Issues covered by the Open Door Policy

McKesson’s Open Door Policy is generallyi intended to address many workplace issues, including those relating to:

    •    Work assignments
    •    Overtime assignments
    •    Transfer or promotion decisions
    •    Written warnings or other disciplinary actionsii
    •    Compensation
    •    Treatment perceived as unfair or discriminatory
    •    Any form of perceived harassment (e.g., sexual, racial, ethnic, religious, sexual orientation)
    •    Request for reasonable accommodation
    •    Involuntary termination
    •    Application of workplace policy

Issues excluded from the Open Door Policy
McKesson’s Open Door Policy may not be used where prohibited by local law, where the subject is the matter of a collective bargaining
agreement (see footnote 1), or to resolve issues involving the following, as they are addressed by other McKesson policies and
procedures:
             •   Workers’ compensation or unemployment insurance claims
             •   Benefits claims, including claims covered by the United States Employee Retirement Income Security Act of 1974
                 (ERISA)
             •   An alleged breach of an Employee’s non-competition, non-solicitation, fiduciary, or confidentiality obligations
             •   A determination that an Employee has violated the Company’s Code of Business Conduct and Ethics
             •   Home appraisals under the Company’s Relocation Program
             •   Intellectual property concerns, claims or disputes
             •   Attempts to challenge, establish, modify or object to the Company’s policies and procedures, except for claims that
                 allege discriminatory or inequitable application of the Company’s policies and procedures

When you want to raise issues under the Open Door policy (such as those described above in the section “Issues covered by the Open
Door Policy”), ask an HR question, need HR assistance or have a work-related concern, you can contact an HR expert in the HR
Support Center at 1-855-GO-MCKHR (1-855-466-2547).

You may also communicate concerns regarding security, safety or business practices you think may be unethical or unsafe to
McKesson’s Integrity Line via telephone at 1-877-MCK-4MCK (1-877-625-4625) or online at http://integrity.mckesson.com/. In
addition, you can ask questions regarding McKesson’s Code of Business Conduct and Ethics. If you choose, you may remain
anonymous when contacting the Integrity Line.

1Employees covered by a collective bargaining agreement will need to follow locally applicable grievance procedures to address
concerns relating to work assignments, overtime assignments, transfer or promotion decisions, written warnings or other disciplinary
actions, compensation, involuntary terminations, and other topics covered by the collective bargaining agreement.
2  The use of the Open Door Policy to resolve an issue concerning a written warning or other disciplinary action generally will not
suspend the written warning or other disciplinary action while the dispute is being resolved. Discipline for Code of Conduct violations
is not subject to review through the Open Door Policy, but may be reviewed subject to procedures described in The Code of Conduct
Procedural Guidelines. Similarly, discipline pursuant to a local collective bargaining agreement is not subject to review through the
Open Door Policy, but may be reviewed subject to grievance procedures described in the agreement.
G. Performance and Behavior That Violates Our
Standards
Overview
This document describes the Company’s policy on Performance and Behavior that Vi0lates our Standards.

Applies To
All U.S. regular employees (full-time, part-time or McKesson temporary employees), except those employees to whom a collective
bargaining agreement applies and that agreement contains superseding provisions.

Our Company Policy
When an employee's actions are inappropriate for our work environment, interfere with performance, or violate Company policy, or
job performance is below standards, the Company maintains an approach of progressive discipline designed to improve the employee's
job performance or ensure full and immediate correction of inappropriate behavior. The actions we take will depend on the severity
and nature of the employee's behavior. They may include none, some, or all of the following actions, as well as additional actions
initiated by the business unit:

    •    Documented verbal warning
    •    Written warning
    •    Final written warning in lieu of suspension
    •    Performance improvement plan with specific deadlines for improvement
    •    Suspension, with or without pay
    •    Termination

The circumstances in each situation play a key role in how the Company will handle the progression, and we may choose to carry out
none or any of the steps, in any order we choose, including immediate termination of employment. This policy does not alter the at-will
employment relationship.

Contact
For further guidance, contact the HR Support Center at 1-855-Go-McKHR (1-855-466-2547).
H. Smoking Policy for the Workplace
Overview
This document describes the Company’s Smoking Policy for the Workplace.

Our Company Policy
To provide the healthiest work environment, McKesson does not allow smoking in or near Company facilities, at any time. Specifically,
smoking and the use of e-cigarettes is prohibited in general working areas, customer areas, company vehicles, restrooms, and within
50 feet of any building entrance, operable window, or air intake.

Applies To
All U.S. employees (regular and temporary), customers, vendors, guests, contractors and consultants.

Contact
For further guidance, contact the HR Support Center at 1-855-Go-McKHR (1-855-466-2547).
I. Solicitation and Distribution of Written Materials
Overview
We know that many Company employees have important commitments to organizations and causes outside of work. But we are
relying on everyone to keep our work environment customer-centered and focused on our work objectives. That means keeping
“working time” separate from other commitments, as described below:

Employees shall not solicit or promote support for any cause or organization during his or her working time or during the working
time of the employee or employees at whom such activity is directed;
Employees shall not distribute or circulate any written or printed material in work areas at any time, or during his or her working time
or during the working time of the employee or employees at whom such activity is directed.
Under no circumstances will non-employees be permitted to solicit or to distribute written material for any purpose on Company
property.
Solicitation and/or distribution for any non-Company business or activities using the Company’s resources (including computers,
electronic mail, fax machines, photocopiers, telephones, cell phones, personal communication devices and voicemail) is prohibited.

Nothing in this policy is applicable to lawful communication by employees to other employees or to third parties concerning employee
wages, hours, working conditions or other subject matters protected by any law, including Section 7 of the National Labor Relations
Act.

Working Time vs. Non-Working Time
As used in this policy, “working time” includes all time for which an employee is paid and/or is scheduled to be performing services or
work for the Company; it does not include break periods, meal periods, or periods in which an employee is not, and is not scheduled to
be, performing services or work for the Company. This policy does not preclude employees from participating in activities sponsored or
sanctioned by Corporate Citizenship or Public Affairs.

Work Areas vs. Non-Work Areas
As used in this policy, “work areas” are all areas on Company property where employees are required to perform their job duties but do
not include break rooms, rest rooms, locker rooms, lobbies and parking areas.

Company Bulletin Board
The main purpose of our bulletin boards is to provide a highly visible location for work-related notices, along with notices that the
Company must post, as required by local, state and federal law.

Special Information for Employees
Occasionally, special notices and information for employees will be displayed on bulletin boards, so please check them regularly.

Questions
Call the HR Support Center at 1.855.Go.McKHR (1.855.466.2547).
J. Standards of Workplace Behavior
Overview
Whenever people gather together to achieve goals, some rules of conduct are needed to help everyone work together efficiently,
effectively, and harmoniously. By accepting employment with us, you have a responsibility to the Company and to your fellow
employees to adhere to certain rules of behavior and conduct. The purpose of these rules is not to restrict your rights, but rather to be
certain that you understand what conduct is expected and necessary.

Applies To
All U.S. regular employees (full-time, part-time or McKesson temporary employees), except those employees to whom a collective
bargaining agreement applies and that agreement contains superseding provisions.

Unacceptable Activities
Generally, we expect each person to act in a professional and responsible way at all times. The following list describes examples of
impermissible conduct that violate McKesson's standards of conduct. These are only examples, and business units and locations may
employ additional policies regarding workplace behavior to meet their unique needs. Violation of the standards of conduct — or any
form of disruptive or inappropriate behavior, even if not specifically listed here — may result in disciplinary action, up to and including
immediate termination of employment. The nature and severity of the discipline will be determined by the Company, subject to any
legal prohibitions or applicable collective bargaining agreement, and typically will reflect the severity of the violation, the employee's
past record, and other individual circumstances. Further, nothing in this policy is intended to interfere with any employee’s right to
engage in lawful activities or speech protected by Section 7 of the National Labor Relations Act (NLRA) including, but not limited to,
the examples provided in subsections c, m, and n below designed to promote positive workplace interactions. Also, this policy,
including subsection j, does not prevent an employee from removing or retaining information about his or her own pay or benefits or
terms or conditions of employment, such as the Employee Handbook or any agreements signed by the employees, or any other
information which the employee is legally entitled to use.

a)       Violation of any Company rule, guideline, policy or practice;

b)       Intentional, negligent or careless action that endangers the life or safety of another person;

c)       Engaging in harassing or abusive behavior toward a customer, co-worker, supplier, partner, contractor, or business associate
         where the harassment or abusive behavior is based on a characteristic protected by law or occurs in situations that would not
         be protected concerted activity under the NLRA. Some types of harassing behavior include, stalking or harassing a co-worker
         at work for personal reasons, or using abusive language to a customer or business partner because of his or her political or
         religious beliefs.

d)       Being intoxicated or under the influence of illegal drugs or drugs that are legally obtainable but used for illegal or
         unauthorized purposes while on Company premises or when representing the Company; using, possessing, distributing,
         transferring or selling illegal drugs or drugs that are legally obtainable but used for illegal or unauthorized purposes while on
         Company premises or when representing the Company;

e)       Possession of firearms, weapons, hazardous materials, or explosives on Company property or while on duty, except to the
         extent such a prohibition is unlawful under applicable law;
f)   Engaging in criminal conduct or acts of violence; making threats of violence toward, or fighting or provoking a fight with,
     employees, customers, clients, suppliers, visitors to Company property, or other persons with whom the Company has a
     business relationship;

g)   Threatening, physically intimidating, or unlawfully coercing fellow employees on or off Company premises;

h)   Engaging in an act of sabotage; negligently causing the destruction or damage, in any manner, of Company property, or the
     property of fellow employees, customers, clients, suppliers, visitors to Company property, or other persons with whom the
     Company has a business relationship;

i)   Failing or refusing to cooperate in or interfering with a Company investigation;

j)   Theft or unauthorized possession of Company property or the property of fellow employees, customers, clients, suppliers,
     visitors to Company property, or other persons with whom the Company has a business relationship; unauthorized
     possession or removal of any Company property, including confidential Company documents, from the premises without
     prior permission from management, unauthorized use of Company equipment or property for personal reasons; using
     Company equipment for personal profit, gain or business;

k)   Dishonesty, falsification, or misrepresentation on work records, including but not limited to, applications, expense reports,
     personnel records, and time cards; lying about sick or personal leave; falsifying a reason for a leave of absence or other data
     requested by the Company; alteration of Company records or other Company documents; recording the work time of another
     employee or allowing another employee to record your work time;

l)   Violating one's Employee Agreement; providing confidential or proprietary Company information to competitors; working for
     a competing business while a Company employee;

m)   Unlawfully defaming a co-worker or customer; fighting with employees, customers, or other third parties in the workplace or
     on work duties; using obscene or vulgar profanity or abusive language (in a manner not protected by law) in the performance
     of your duties; engaging in unlawful hate speech;

n)   Interfering with another employee’s ability to do his or her job or to follow Company policy (in a manner not protected by
     law). For example, continually interrupting a co-worker’s work to discuss personal matters, or preventing an employee from
     reporting behavior that violates a policy, such as sexual harassment.

o)   Excessive absenteeism, tardiness, leaving early, or leaving work without management permission;

p)   Unauthorized or inappropriate use or disclosure of Protected Health Information;

q)   Conducting Company business at a location that could embarrass the Company if disclosed to the public or make other
     individuals feel uncomfortable, including but not limited to “adult entertainment” establishments and other venues with
     sexual undertones;

r)   Willful or negligent non-performance of assigned duties; or
s)       Refusing to perform duties as instructed by a supervisor or manager; deliberately engaging in unprotected conduct related to
         performance of your duties contrary to Company instructions.

Nothing in this policy alters the at-will nature of your employment (unless an employee has a written contract or is covered by a
collective bargaining agreement that expressly provides that he or she is not an at will employee); either the employee or the Company
may terminate the employment relationship at any time and for any reason, even in the absence of a violation of these rules.

Contact
For further guidance, contact the HR Support Center at 1-855-Go-McKHR.

Related Policies
At-Will Employment Policy
K. Substance Abuse Prevention & Testing Policy
Overview
McKesson, including its subsidiaries and affiliates, (“McKesson”) is committed to promoting the safety, health, and well-being of its
employees, its customers, and all of those who use its products and services. Drug and alcohol abuse impair judgment, performance
and health. As a leading provider of services dedicated to improving health care, McKesson’s goal is to promote and maintain a work
environment that is free from the effects of substance abuse.

Applies To
• This policy applies to all U.S. employees.

• Job applicants in violation of this policy will not be hired.

• Outside Services Workers and vendors must not engage in prohibited activity while at McKesson work sites or while performing
services for McKesson business units or functions.

• Some vendors may be required to take and pass a drug test as a condition of assignment and/or subject to testing while performing
services for McKesson. If you are a vendor, your employer can advise you of any such requirements.

• Employees or applicants for positions that are subject to U.S. Department of Transportation (“DOT”) regulations on substance abuse
and testing must comply with this policy and with those rules.

• If an employee is subject to a collective bargaining agreement that contains a substance abuse policy, that policy will take precedence
over this policy where the policies differ.

• Business units may adopt supplemental policies addressing drug and alcohol use and testing with the approval of the Vice President
of Employee Relations or designee as may be appropriate for the business unit given business unit needs or customer requirements.

• If any provision of this policy differs from any requirement imposed by state or local law, the policy will be implemented at that
location in accordance with those requirements.

Policy Details

Drug and Alcohol Rules

Illegal Drugs
• McKesson strictly prohibits the illegal use, sale, attempted sale, conveyance, distribution, manufacture, purchase, attempted
purchase, possession, cultivation, and/or transfer of drugs and intoxicants.

• This prohibition on illegal drug activity applies not only during working hours, while conducting McKesson business, and while on
McKesson-owned or occupied premises, but extends to all illegal activities involving drugs or intoxicants.

• Employees are further prohibited from working with illegal drugs or intoxicants in their systems.
• “Illegal drugs and intoxicants” means drugs or intoxicants the use or possession of which is prohibited as a matter of federal, state or
local law, and includes the use of prescription medications other than as prescribed. Marijuana remains illegal as a matter of federal
law, and therefore, its use or possession, even as permitted by a state’s medical marijuana or recreational marijuana law, violates this
policy. McKesson will accommodate medical marijuana users where required by law and to the extent not inconsistent with
McKesson’s obligations under federal law, but will not accommodate medical marijuana use.

• This policy does not prohibit employees from the lawful use and possession of prescribed or over-the-counter medications. See the
section on Prescription Medications, below.

• The misuse of drugs can have effects that persist long after the individual has taken the drug. Information about the effects of specific
drugs is available to employees through our Employee Assistance Program.

Alcohol
• McKesson prohibits the use or possession of alcohol while working, while on-call, while operating a vehicle for McKesson, or when on
McKesson premises.

• The use or abuse of alcohol off the job that impairs performance on the job may subject the employee to disciplinary action.

• Employees are prohibited from working with alcohol in their systems.

• On occasion, McKesson will authorize the use of alcohol at Company-sponsored or approved functions. Employees who choose to
drink alcohol at such an event are expected to exercise good judgment and to refrain from becoming intoxicated or impaired.

• Employees in safety-sensitive jobs may not use alcohol within four hours of reporting for work and may not return to work within
four hours if they consume alcohol (including following a McKesson-approved function or event).

• “Safety-sensitive” jobs include those in which the individual must drive or operate machinery other than standard office machines,
provide security services, or work in patient care roles or with hazardous materials or controlled substances. This list is illustrative, not
exhaustive; ask your ER Consultant if you are unsure whether your position qualifies you as safety-sensitive.

Prescription Medications
• When a physician prescribes the use of prescription or over-the-counter drugs, or when over-the-counter drugs bear warnings about
side effects that may affect job performance, each employee should ask his or her health care provider whether such drugs may
adversely affect the ability to safely perform assigned duties.

• An employee must advise his or her immediate supervisor if he or she is taking a medication that may adversely affect the employee’s
ability to perform assigned duties safely. The supervisor will engage Employee Relations to discuss whether an interactive dialogue
should take place to assess whether reasonable accommodation may be required. In the interim, if there is any question concerning the
employee’s ability to perform safely, the employee will be assigned other work, if, in the sole discretion of management, such duties are
appropriate and available, or the employee will be sent home.

• Marijuana remains illegal as a matter of federal law and therefore its use or possession violates this policy. McKesson will endeavor to
accommodate individuals with disabilities but will not excuse positive drug tests or other policy violations related to medical marijuana
use beyond what is consistent with both its federal and state legal obligations. If you have questions about medical marijuana in your
state, please consult Employee Relations for details.
Discipline
Employees in violation of this policy will be subject to discipline, up to and including termination, even for a first offense.

At its option, McKesson may require an employee who has violated this policy to enter into a Return-to- Work Agreement that includes
an employee commitment to participate in and complete successfully a prescribed and approved drug or alcohol abuse assistance
program as a condition of continued employment. Additional requirements may be imposed in the Return-to-Work Agreement as
appropriate for each individual’s situation.

Vendors and Outside Services workers who violate this policy will be barred from McKesson facilities. Job applicants (including
temporary labor Outside Services workers staff seeking placement with McKesson) will not be hired or placed with McKesson. Job
applicants who test positive are ineligible to reapply for six months and, if they do reapply, they must have ceased using illegal drugs.

McKesson may involve law enforcement as it deems appropriate, and will cooperate in any resulting investigation.

Employee Assistance Resources
McKesson encourages employees to seek assistance with drug and/or alcohol concerns and will assist and support employees in
locating services and rehabilitation programs that emphasize education, prevention, counseling, and treatment.

• McKesson encourages employees who may have concerns about substance abuse to seek assistance promptly. An employee’s decision
to seek help voluntarily (before the individual is asked to submit to a drug test and/or before the individual is discovered otherwise to
have violated this policy) will not be used as a basis for disciplinary action, although the individual may be transferred, given work
restrictions, or placed on leave, as appropriate. Please be aware, however, that a decision to seek treatment can neither absolve nor
protect individuals from the consequences of failing to meet performance expectations or for engaging in policy violations.

• A person’s decision to seek help will be treated as confidential, and communicated only to those McKesson employees and agents
with a need-to-know, or except as may be required by law.

• McKesson offers employees (and their dependents) access to an Employee Assistance Program (“EAP”). The EAP can provide
confidential assistance to employees with alcohol or drug concerns, including an evaluation for substance abuse dependence and
referral to education and/or rehabilitative services, when appropriate. The HR Support Center can help you locate the EAP contact
information for your business unit or location.

• Employees’ health insurance may cover the costs of treatment. Moreover, employees may be eligible for a leave of absence to
participate in such a program. See your location’s leave policies or speak with the HR Support Center for details.

• After an employee who has sought treatment is released by the treating medical professional to return to work, the employee must
take and pass a return-to-work drug and/or alcohol test before resuming work. In addition, the employee may be required to submit to
unannounced follow-up drug and/or alcohol tests. Additional fitness-for- duty assurances may be required, depending upon the
employee’s position and job duties.

Federal Drug-Free Workplace Act Compliance
As part of McKesson’s program to comply with the federal Drug-Free Workplace Act of 1988 and similar state laws, McKesson has
implemented the following policies:
Criminal Convictions
• All employees are required to notify McKesson within five (5) days if they are convicted of a crime involving drugs or alcohol. A
conviction means a finding of guilt, including a plea of guilty or no contest, or imposition of sentence, by any judicial body.

• If the employee is convicted of a crime involving illegal drugs while performing services funded by or for the government, McKesson
will in turn inform the relevant contracting officer of the conviction and take appropriate disciplinary action within 30 days.

• Although convictions will not automatically lead to discipline, off-duty conduct that violates this policy may have a bearing on an
employee’s continued suitability for the job.

Drug Education & Awareness Program
• McKesson will periodically provide information to employees on the effects and dangers of drug and alcohol abuse, the resources
available to employees through McKesson and in the community to address substance abuse and dependence, and information about
the provisions of, and consequences of, violating this policy.

• The Employee Assistance Program can also provide educational information on substance abuse upon request.

Acknowledgment of Receipt
• Employees will be required to sign a receipt acknowledging that they have received this policy.

Drug Testing
McKesson may test job applicants, employees for illegal drugs and/or alcohol as described below. Tests may seek the presence of one
or all of the following substances: alcohol (ethyl alcohol), amphetamines (including methamphetamine, MDMA (“ecstasy”), MDA, and
MDEA), barbiturates, benzodiazepines (Valium, Xanax), cocaine, marijuana (THC and synthetic THC (“spice” or “K2”)), opiates and
opioids (including codeine, heroin, and morphine, fentanyl, methadone, mepiradine, oxycodone (OxyContin), Suboxone),
phencyclidine (PCP), Methaqulone and designer drugs such as methedrone, MDPV, and methylone (“plant food,” “bath salts”).

Outside Services Workers may be tested for illegal drugs and/or alcohol as described above following their agencies/employers
process.

Pre-Employment Testing
• Job offers may be contingent upon taking and passing a drug test before commencing work.

• Employment offers (or assignment offers, in the case of Outside Services workers) will be withdrawn whenever an applicant receives
a verified positive test result or refuses to participate in the testing process.

• Behaviors designed to frustrate the testing process, such as attempting to adulterate, dilute, substitute or damage the test sample, or
refusing to participate in the testing process when requested, also are considered refusals to test.

• Applicants who violate this Policy will not be hired and will not be eligible to reapply for a position with McKesson for six months,
and provided they no longer illegally use drugs.

Reasonable Suspicion Testing
When McKesson management has reason to believe that an employee has violated this policy, the employee may be asked to submit to
a for-cause or reasonable suspicion drug and/or alcohol test. McKesson may also impose discipline, up to and including termination of
employment, without a test, based upon the facts and circumstances giving rise to a reasonable belief that the policy has been violated.
You can also read