PANDEMIC PREPAREDNESS AND RESPONSE PLAN

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1 PANDEMIC PREPAREDNESS AND RESPONSE PLAN Sterling Group Our values include a commitment to empowerment with accountability that results in teamwork and efficiency. -Sterling Mission Statement Overview Experts believe that a pandemic will strike in the near future. The World Health Organization states that the risk is serious. Absenteeism, a shortage of supplies and utilities overload, are only a few of the concerns. Therefore, the following information has been compiled to assist employees and residents in pandemic flu preparedness procedures. General Policy Statement Sterling Group is committed to ensuring a safe, healthy environment for all its employees, residents, investors and visitors. In an effort to support public health officials in preventing the spread of contagious disease, Sterling Group has developed policies to help prevent and respond to a pandemic. As a general rule, the prevention policy will be enforced and as a situation warrants, the response policy will go into effect. Sterling Group will work with local public health officials in its various markets in order to stay informed and monitor the need to respond to potential and/or real outbreaks. This Plan will be shared with local public health officials, hospitals and local clinics in each area of operation. A copy will also be sent to the health insurance provider, employee assistance program provider and liability insurance carrier. During the annual meeting to review coverage provided by the various plans, the Pandemic Prevention and Response Plan will also be reviewed in order to ensure appropriate levels of coverage are included in the plan designs. Necessary changes in coverage will be discussed and considered as needed. Stopping the Spread of Germs at Work How Germs Spread Illnesses such as influenza (the flu) and colds are caused by viruses that infect the nose, throat and lungs. The flu and colds usually spread from person to person when an infected person coughs or sneezes. How to Help Stop the Spread of Germs 1. Cover your mouth and nose when you sneeze or cough. Cough or sneeze into a tissue and then throw it away. Cough or sneeze into your sleeve if tissues are unavailable. Wash your hands every time you cough or sneeze. 2. Clean your hands often. 1

2 When available, wash your hands with soap and warm water, then rub your hands vigorously together and scrub all skin surfaces. Wash for 15 to 20 seconds. It is the soap combined with the scrubbing action that helps dislodge and remove germs. When soap and water are not available, alcohol-based disposable hand wipes or gel sanitizers may be used. If using a gel, rub the gel in your hands until they are dry. The gel doesn't need water to work; the alcohol in the gel kills germs that cause colds and the flu. Keep antibacterial gel at your desk and in your purse or briefcase. Antibacterial gel will be provided for employees to use in all conference and break rooms. 3. Clean equipment often. Sanitizing wipes have been provided in several areas throughout the office where common use of equipment occurs; i.e., the conference room, mail room, reception area. Telephones, keyboards and other equipment should be wiped down prior to individual use. 4. Avoid touching your eyes, nose or mouth. Germs are often spread when a person touches something that is contaminated with germs and then touches his or her eyes, nose or mouth. Germs can live for a long time (some can live for two hours or more) on surfaces like doorknobs, desks and tables. 5. Stay home when you are sick and check with a health care provider when needed. When you are sick or have flu symptoms, stay home, get plenty of rest and check with a health care provider as needed. Remember: keeping your distance from others may protect them from getting sick. Common symptoms of the flu include: Fever (usually high) Headache Extreme tiredness Cough Sore throat Runny or stuffy nose Muscle aches Nausea, vomiting and diarrhea 6. Practice other good health habits. Get plenty of sleep, be physically active, manage your stress, drink plenty of fluids and eat nutritious food. Practicing healthy habits will help you stay healthy during the flu season and all year long. 7. Get a flu shot. Employees are reminded that the company sponsors annual influenza vaccinations during the fall. The company also provides paid time off (vacation/sick leave) to cover absences due to influenza. 8. Masks When contact is unavoidable and it becomes necessary to wear a mask, the N-95 masks by 3M are recommended; Model 1870 folds flat and is individually packaged. 2

3 Pandemic Response Plan Communication Each department is responsible to develop a communication plan for the purpose notifying their employees when the office is closed. This communication plan must be reviewed and updated each April and October and a copy submitted to Human Resources. Corporate or property offices will be closed when an order or recommendation by public health officials has been made or the President/CEO has determined it is necessary. At that time, the communication plan will be initiated as outlined as follows: Larry Swank and Lance Swank will call their direct reports as identified on the attached chart. Those colleagues will in turn contact the rest of the staff as outlined in the chart. (See Corporate Staff Phone Tree). Property office closures in affected areas will be determined by Andrea Hurn, Vice President of Management, in conjunction with the appropriate Regional Director. Company Leave Policy As outlined in Policy 400 (Paid Time Off), all full time colleagues are granted paid time off that can be used for any purpose, including vacations, illness or time away from work for personal or family matters. Paid time off must be scheduled in advance and have supervisory approval, except in the case of illness or emergency. All full time colleagues receive paid time off based on the length of continuous service according to the following schedule: Length of Service First Year After 1 Year After 2 Years After 5 Years Paid Time Off (10 hours accrued quarterly) 80 hours 120 hours 160 hours In addition to paid time off, Sterling Group provides medical and personal leaves of absence as outlined in Policies 500 (Leave Policies--General), 505 (Personal Emergency Leave) and 506 (Medical-Disability Leave) and 509 (Family and Medical Leave). In the event of a pandemic, these leaves may or may not apply. Employee absences due to contagious illnesses will be documented by the Human Resources Department. Employees are to follow the Attendance Policy (600) and contact their direct supervisor prior to the beginning of their shift, when possible. If their direct supervisor is unavailable, they will contact their regional director or divisional vice president, as appropriate. If those individuals are unavailable, they should call the Corporate Office ( ) and press Option 5 to leave a message on the general Human Resources voic . All managers are required to Eileen Shue, Vice President of Corporate Resources or leave a message on the HR general voic to report all absences related to the pandemic. 3

4 Contagious Temporary Illnesses Policy Sterling Group realizes that employees with contagious temporary illnesses, such as influenza, colds and other viruses, need to continue with normal life activities, including working. In deciding whether an employee with an apparently short-term contagious illness may continue to work, the company considers several factors. The employee must be able to perform normal job duties and meet regular performance standards and their continued presence must pose no risk to the health of the employee, other employees and customers. If such risks are present, the company will ask the employee to leave work/stay home until the threat of infection is gone. Supervisors are encouraged to remind employees that the company provides paid leave to cover absences due to contagious temporary illnesses. All employees are urged to contact Human Resources regarding any questions about the possible contagious nature of another employee s temporary illness. Disclosure of confidential information by any employee about another employee s protected health information is forbidden. Contingent Leave Policy In the event that an employee has exhausted all available paid time off and has contracted a contagious illness requiring them to remain at home, or they are caring for a dependent that has contracted a contagious illness, they will be granted an additional 5 days of paid time off. Employees will not be required to provide a statement from their health care provider that they or their dependent family member has such an illness. The Centers for Disease Control (CDC) recommends that people NOT go to hospital emergency rooms, walk-in clinics or doctors offices, unless they have high fever, dehydration, difficulty breathing or symptoms that seemed to get better, get worse. Employee Assistance Program Guidelines Sterling Group benefit plan includes access to the employee assistance program (EAP) administered through New Avenues. Any employee who feels the need to contact the EAP may do so confidentially and independently by calling ( ). If a department or property manager feels the need for a critical response team to be available to their staff, they may contact Eileen Shue in Human Resources to arrange for an on-site counselor. Identifying Essential Business Issues during a Pandemic It is expected that approximately 20% to 60% of the workforce can be absent for an extended period of time during a pandemic due to personal illness, family member illness, fear, community containment, quarantines, school and/or business closures and public transportation closures. Therefore, it is important to identify individuals and services essential to maintaining continuing operations. Each Department Head is responsible for identifying those essential individuals and services by location and function that are required to continue business operations during a pandemic. Business operations can include managing internal staff, servicing 4

5 clients, residents and tenants, and managing products and services received from suppliers, vendors and subcontractors. Factors to consider in this planning would be Cross training of employees within a department. Reallocation of staff resources. This can include a temporary transfer from one department/property/jobsite to another. Having secondary and tertiary vendors, suppliers and subcontractors available and set up in the system. Utilization of vendors for services where none had been used before, including temporary staffing. It is the responsibility of every supervisor to ensure coverage for all positions, so that if an employee is absent and unable to telecommute, their responsibilities are covered. Each department head and member of the executive team is also responsible for establishing and maintaining a succession plan, which should be reviewed every 6 months to ensure it is up-to-date in the event of a critical position vacancy. Assistance with cross training and succession planning can be obtained from the Human Resources or Marketing Departments. The IT Department will establish a data base of which employees have a home computer, printer, fax machine and internet access. Each manager is responsible for notifying IT when personnel changes occur or as their employees obtain listed equipment/services. IT will also maintain an inventory of equipment that may be loaned out on a temporary basis in the event that employees are required to work from home and do not have the necessary equipment. It will be IT s responsibility to establish, monitor and correct any firewall issues. In the event that temporary staffing is necessary, department heads should contact the Human Resources Department to arrange for this service. The HR Department maintains a data base of temporary staffing agencies that can provide assistance based on each department s needs. Property managers will be expected to arrange for temporary staff based on their property s needs through their local staffing firms. Medical Assistance Guidelines Employees should be reminded that resources are available for general medical information, outside of their regular family physician and that in most cases, the resources are part of the company s regular benefit plan (i.e., New Avenues website: Work/Life Resource Center [log in: The Sterling Group], Unified Group Services, or ). It is expected that pandemic outbreaks will occur in clusters throughout the country and the severity and intensity within regions may vary. CDC and local public health officials will be the most reliable sources of information, followed by local hospitals and medical clinics. 211 service is being established in many communities to provide answers related to any type of emergency. 5

6 Many hospitals have hotlines where callers can ask a nurse questions related to medical issues. In addition, most health insurance providers have disease state management programs which can offer assistance. Social Distancing Guidelines (for communicable disease outbreaks in the workplace includes apartment communities, i.e., common areas, office, etc.) In the event of a flu pandemic or other communicable disease situation, Sterling Group may implement these social distancing guidelines to minimize the spread of the influenza and other communicable diseases among the staff and/or residents. During the work day, employees are requested to: 1. Avoid meeting people face-to-face. Employees are encouraged to use the telephone, video conferencing and the Internet to conduct business as much as possible, even when participants are in the same building. Residents should also be encouraged to communicate by phone or Internet. 2. If a face-to-face meeting is unavoidable, minimize the meeting time, choose a large meeting room and sit at least one yard from each other if possible; avoid person-toperson contact such as shaking hands. 3. Avoid any unnecessary travel and cancel or postpone nonessential meetings, gatherings, workshops and training sessions. Conduct training via webinar. 4. Do not congregate in break or conference rooms, pantries, copier rooms or other areas where people socialize. 5. Bring lunch and eat at your desk or away from others (avoid lunch rooms and crowded restaurants). 6. Encourage residents and others to request information via phone and in order to minimize person-to-person contact. Have the materials and information ready for fast pick-up or delivery and encourage residents to use the drop box for returning information. Outside activities Employees might be encouraged to the extent possible to: 1. Avoid public transportation (walk, cycle, drive a car) or go early or late to avoid rushhour crowding on public transportation. 2. Avoid recreational or other leisure classes, meetings, activities, etc. where employees might come into contact with contagious people. 6

7 Telecommuting Managers will determine which, if any, employees may work from home and encourage all employees who are able to telecommute to do so. (See Telecommuting Policy below) Conferences, seminars and educational events Managers will determine if and when to cancel or postpone company or resident events or when to cancel an employee s attendance at a conference, seminar or educational event. Travel All non-essential travel will be eliminated and employees will be expected to conduct business by phone or . When travel is required, avoid airline transportation as much as possible and consult the Center for Disease Control (CDC) website at or for outbreak areas and recommendations for wearing masks and gloves to avoid contact with potentially contagious people. Telecommuting Policy As a necessary precaution in controlling the spread of infectious diseases, Sterling Group may consider telecommuting to be a viable alternative work arrangement in cases where the individual, job and supervisor characteristics are best suited to such an arrangement. Telecommuting allows an employee to work at home, on the road, or in a satellite location for all or part of their regular workweek. Telecommuting will be considered a short-term alternative for the period of time required and in no way changes the terms and conditions of employment with Sterling Group. Consistent with the organization's expectations of information asset security for employees working at the office full-time, telecommuting employees will be expected to ensure the protection of proprietary company and customer information accessible from their home office. Steps include, but are not limited to, use of locked file cabinets, desks, regular password maintenance, and any other steps appropriate for the job and the environment. Employees are required to maintain a list of frequently visited websites, logins and passwords and submit the list in a sealed envelope with their name on the outside to the IT Director no less than two times a year or more frequently as passwords change. (See Corporate Passwords Example, attached) Telecommuting employees are responsible for notifying their supervisor of any injuries in accordance with company worker's compensation procedures. The employee is liable for any injuries sustained by visitors to their work site. Positions eligible for telecommuting include: Vice Presidents Executive Administrative Accounting* Compliance IT Construction Project Managers Construction Administrative* Marketing Management Administrative Regional Directors District Managers 7

8 *With limitations based on access to Timberline Requirements for telecommuting: Employee must be in a position that does not involve direct customer contact. Employees whose positions rely on direct customer contact may be allowed to telecommute with written permission from their immediate supervisor, if the property or department is adequately staffed and/or the Pandemic Threat Level is at 6 (as defined by the World Health Organization). Employee must have internet access from home and either a home computer or company laptop. The employee will establish an appropriate work environment within their home for work purposes. Sterling Group will not be responsible for costs associated with initial setup of the employee's home office such as remodeling, furniture or lighting, nor for repairs or modifications to the home office space. Employees will be offered appropriate assistance in setting up a work station designed for safe, comfortable work. Sterling Group will supply the employee with appropriate office supplies (pens, paper, etc.) for successful completion of job responsibilities and will also reimburse the employee for all other business-related expenses such as phone calls, shipping costs, etc. that are reasonably incurred in accordance with job responsibilities. Reimbursement for these expenses will be through the established expense reimbursement procedure. Telecommuting employees who are not exempt from the overtime requirements of the Fair Labor Standards Act will be required to record all hours worked in a manner designated by Sterling Group. Telecommuting employees will be held to a higher standard of compliance than office-based employees due to the nature of the work arrangement. Hours worked in excess of those specified per day and per work week, in accordance with state and federal requirements will require the advance approval of the supervisor. Failure to comply with this requirement can result in the immediate cessation of the telecommuting agreement. When the threat of infection is gone and telecommuting employees return to the workplace, they will return all company property including computers, fax machines, pens, paper and miscellaneous office supplies that were provided to them. Transportation Issues There are a number of different possible scenarios with regards to public transportation and employees commuting to and from work during a pandemic. First, it is very likely that public transportation services may be disrupted during a pandemic due to transit staffing issues. The transit authorities will have the same potential issues with staff shortages as all other employers. In addition, there is the possibility that public transportation may be stopped completely as a community containment measure. At the same time, it is predicted that transit use will drop significantly due to commuters unwillingness to use public transportation as a result of a public health advisory to limit person-to-person contact. Regardless of the reason employees who use public transportation will need to consider developing contingency plans to deal with these situations. 8

9 If you rely on public transportation but have the ability to telecommute, we recommend that option first. However, telecommuting is not always possible. Should you choose to continue to use public transportation, we recommend that employees wear gloves and masks during their commute. Sterling Group will provide these items to any employee requesting them. In order to assist in decreasing the amount of person-to-person contact during your commute, we will work with employees to establish staggered working hours or flexible hours so employees are not using public transportation during high volume times. Although this will not always be feasible, we will do our best to accommodate as many employees as possible. If disruptions in public transportation occur and/or employees are hesitant to use public transportation, we recommend driving yourself to work or carpooling with other employees under these circumstances. We will provide a means by which employees can connect with others employees in the same situation. A Sign-Up Sheet will be located at each location designating employees who are willing to drive and others who are in need of transportation. We will identify vacant apartments and models for use by employees who are having transportation issues and are critical to our operations. The use of these vacant apartments and models will be evaluated on a case by case basis. 9

10 Management Preparedness Checklist 1. Verify the Property Emergency Phone Listing is current with cellular numbers and home numbers of all employees, including the regional director s numbers. Include a contact person for staff and a central number for all employees to contact. Upon completion, distribute to all employees and forward a copy to the regional director and corporate office. The corporate office will compile an Emergency Reaction Team to assist properties in need after the company is affected by the pandemic. 2. Verify that the properties and the corporate office emergency equipment are in good working order and supplies are adequate to last several days if necessary. Office emergency equipment is to include batteries, flashlights, and batterypowered radios. 3. Ensure emergency relief supplies are available and easily assessable. Supplies are to include first aid kits, blankets, can openers, batteries, canned food, bandages, plastic bags, unscented bleach, drinking cups, bottled water and other supplies as recommended by local public health officials or the CDC. 4. Request replenishment of any outstanding petty cash. 5. Should the office be required to close, call all move-ins and move-outs to make the necessary arrangements. 6. Contact the local Red Cross Chapter to verify the phone numbers and inquire as to where the closest hospitals are located. Distribute maps of the locations to residents. For residents who are frail, elderly or handicapped and without transportation, recommend they call the local Red Cross Chapter for assistance. Advise them to register early before any threat of an outbreak in the area. 7. Send notification to the residents. A sample Pandemic Flu Preparedness Letter is attached. 8. Open and remove any gate arms in anticipation of power outage. 9. Know where the authorities will allow waste disposal until pick up is available. Separate types of waste. Food products must be bagged and separate from all waste materials. 10. Give answering services the manager s and maintenance supervisor s home and cell phone numbers. 11. Locate a local radio station with the appropriate news network system on a battery-powered radio. Stay informed of where outbreaks are occurring and listen for instructions for your area. 10

11 12. In the event the property model units are required for habitation, stock the units with the following: bedroom and bathroom linens, toilet paper and tissues, blankets, bottled water, unscented bleach, can opener, canned food, bandages, first aid kit, plastic bags, drinking cups, paper napkins and plates, plastic utensils and batteries. 13. Ensure emergency relief supplies are available and easily assessable. Supplies are to include first aid kits, antibacterial hand gel, blankets, can openers, batteries, canned food, bandages, plastic bags, unscented bleach, drinking cups, and bottled water. Management Responsibilities after the Pandemic 1. Contact the regional director and Corporate management resource specialist with the status of the property s employees and residents. 2. Assist government health agencies with records and information on residents. 3. Make the property office as easily accessible as possible for residents requesting assistance. 4. If possible, have a unit available for employees or government health agencies. 11

12 Pandemic Flu Preparedness Dear Residents: In an effort to assist you in preparing for the expected pandemic flu in our region, we ask that all residents please read the following information thoroughly and be properly prepared in the event of an outbreak. You are encouraged to contact the local Emergency Preparedness Division or local Red Cross Chapter to verify the needs of your household. Please be advised that Sterling Group staff may not be remaining on the property once an outbreak in the area has been reported. We encourage all residents to take responsibility for themselves and their families just as we have advised our employees. In the event of an emergency, please call local law enforcement or fire officials. When an outbreak is announced: Listen to the County Warning System or Public Health Officials on the radio or television. Do exactly as advised, including staying home if you are ill, keeping children home, etc. Follow these precautions: o Wash your hands frequently for at least 20 seconds, especially after sneezing or coughing. Alcohol-based hand cleaners are also effective. o Avoid close contact with those who appear unwell and have a fever and cough. o Cover your mouth and nose with disposable tissues when coughing or sneezing. Cough or sneeze into your sleeve if a tissue is not available. o Avoid touching your eyes, nose, or mouth. o Get enough sleep, eat nutritious foods, and keep physically active. o If you feel unwell, stay home from work or school, and avoid crowds as much as possible. o Rest, drink plenty of fluids and seek help for chores that require contact with other people. The Centers for Disease Control (CDC) recommends that people NOT go to hospital emergency rooms, walk-in clinics or doctors offices, unless they have high fever, dehydration, difficulty breathing or symptoms that seemed to get better, got worse. Keep plenty of bottled water on hand (save empty bottles to refill from the tap, if necessary). 12

13 Stock up on daily necessities. Items such as the following are recommended: non-perishable food, bottled water, first aid kits, blankets, manual can opener, batteries, battery powered radio, prescriptions, diapers, baby food, extra eye glasses, hearing aids, and battery powered lanterns. Back up batteries for each item requiring a battery are also recommended. Fill all vehicles with gas. In the event of loss of power, the gas pumps will not operate. During the outbreak: Continue to listen to the County Warning System or Public Health Officials on the radio or television. Do exactly as advised by the announcer. Stay indoors. Contact with others is to be avoided. Do not run generators or propane tanks inside the apartment. Carbon monoxide fumes will spread throughout the apartment and will cause serious health issues and/or death. Additionally, generators require a well-ventilated area. Avoid public contact until the official all clear is given from the County Warning System or Public Health Officials on the radio or television. After the outbreak: Report any emergencies. All emergency numbers are in the front of the white pages telephone book. Should maintenance repairs be required, please contact the office. A schedule will then be prepared to complete the necessary repairs. All life-safety issues will be responded to accordingly. We hope these steps will assist you in preparing for any such occurrences. Please contact our office should you have any questions. Sincerely, Property Manager 13

14 Emergency Contact List Communication Chart and Routing of Emergency Calls Property: Police or 911 Ambulance or 911 Fire or 911 Poison Control or 911 Property Manager Maintenance Supervisor Regional Director Vice President Assistant Mgr Insurance Admin Owner HR Name Home Phone # Cell Phone/Pager # Apt # Regional Director Property Manager Assistant Manager Leasing Leasing Maintenance Supvsr Maintenance Tech Maintenance Tech Housekeeper Groundskeeper Utility or Vendor Contacts Telephone # Temporary Staffing Temporary Staffing Electricity Gas Water/Sewer Snow/Ice Removal Pest Control Trash Collection Landscaping 14

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