Team Members Human Resources

Policy number: WAG.POL.ERS-***

Policy title: Drug and Alcohol-Free Workplace Policy

Effective date: January 26, 2021

Approval date: September 28, 2020

Version: 2.0

Owner: Sr. Vice President & Walgreens Chief Human Resources Officer Description: This policy describes the expectations for handling Drug and Alcohol testing and use among Walgreens Candidates and Team Members. Table of Contents

1. Purpose 2 2. Scope 2 3. Definitions 2 4. Drug and Alcohol Testing 3 4.1 Pre-Employment Testing 4 4.2 Post-Employment Testing 4 4.3 Drug Testing Remote and Work from Home Team Members 5 4.4 Drug Testing Contract and Temporary Workers 5 5. After the Test (Review of Results) 5 5.1 Test Results 5 5.2 Medical Review Officer 6 5.3 Compliance with the Policy 6 5.4 Back on Track Program 6 6. Marijuana Guidelines 7 6.1 Medical Marijuana Use 7 6.2 Recreational Marijuana Use 8 6.3 Non-Adverse Action States 8 7. Rehire and Reapplication Eligibility after a Positive Test 8 8. Related Policies & Documents 8 9. Policy Revision History 9 10. Contact Information 9 11. Approval Matrix 9 WAG POL DDD-009, Drug Free Workplace

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1. Purpose

Walgreens ("Company") is committed to providing a safe, Drug and Alcohol Free Workplace environment through programs that encourage health, performance, and service to our customers and patients. Team Members are expected to be in a coherent mental and physical condition while at work and able to perform their jobs in a satisfactory manner. In instances where the use of Drugs or Alcohol interferes with these goals, appropriate action, up to and including termination of employment, will be taken. Under no circumstances are Team Members permitted to report to work under the influence of Drugs or Alcohol. The possession of illegal drugs or open Alcohol on Company property is prohibited and may result in termination. Prescription drugs should not be brought on Company property by any person other than the person for whom the drug is prescribed and must only be used as prescribed.

2. Scope

This policy applies to all Walgreens Team Members and candidates in the U.S., Puerto Rico, the Virgin Islands, and all other U.S. territories, as well as all U.S. based WBA Team Members.

3. Definitions

Term Definition

Alcohol Company policy prohibits team members

from consuming alcohol on the company

premises while on duty and/or from

reporting for duty or remaining on duty while

having a blood alcohol concentration of .04

or greater. Company policy also prohibits

team members from reporting to work

smelling of alcohol or having the appearance

of being impaired by alcohol.

Back on Track Program Program designed to assist Team Members who suffer from drug and alcohol

dependency issues with finding the

appropriate resources and getting the help

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they need to address those issues. See

below at Section 5.4 for more information.

Candidate An individual who is seeking employment

with Company.

Illegal Drugs/Controlled Substances For purposes of this policy, an illegal drug is any drug that is not legally obtainable or has

not been legally obtained. The term includes

prescription drugs not legally obtained, and

prescribed drugs not being used for

prescribed purposes or in prescribed

amounts, or by the person for whom they

were prescribed (including family members

or persons in the same household) or not

issued for a legitimate medical purpose by a

physician acting in the usual course of sound

professional practice. A team member using

a legal drug has an obligation to inquire of

his/her healthcare provider and determine

whether the substance will affect their ability

to safely and efficiently perform their job

duties.

Vendor/Administrator Entity contracted by Company to assist in facilitating and managing the drug testing

procedures during the pre-employment

hiring process, as well as during employment.

Walgreens Team Members Any employee and/or officer of Walgreens. 4. Drug and Alcohol Testing

Drug and Alcohol tests ("tests") may be performed using a Candidate or Team Member's saliva, urine, hair, blood or breath. Testing may be conducted at the hiring, work location or in laboratories that are certified for federally mandated drug testing by the U.S. Department WAG POL DDD-009, Drug Free Workplace

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of Health and Human Services. All tests will be performed according to state guidelines; therefore, alternative testing methods may be conducted. 4.1 Pre-Employment Testing

External Candidates

Candidates applying for pre-determined positions such as pharmacy-based, safety- sensitive and various leadership roles will be required to take a drug test post-offer, but pre-employment. Employment will be contingent upon the Company receiving a negative drug test result.

Internal Transfers and Promotions

Team Members who are transferred or are promoted into positions that require drug testing and have not been previously tested in their tenure with the Company, will be required to submit to a drug-test. Team Members who have been previously drug- tested will not need to retake a drug test.

4.2 Post-Employment Testing

Post Injury/Accident

Any Team Member involved in a traffic or on-the-job accident, which requires offsite medical treatment or evaluation, involves lost time from the job, or property damage over $100 while on Company business or driving a Company vehicle, will be required to take a drug test and a breath alcohol test (where permitted by state). Random

Random testing may be required of all or a percentage of all Team Members at a particular location, job classification or department. This will also include district or area personnel on site who are working (including all corporate personnel visiting or supervising in the location). Team Members who are selected to participate in a random test will be required to take the drug test immediately. Walgreens engages a Vendor and/or Administrator to manage the random testing program on the Company’s behalf. This third party Administrator has been appointed by the Company to develop and apply a random selection process, so that all Team Members within the pool subject to testing will have an equal chance to be selected. WAG POL DDD-009, Drug Free Workplace

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Reasonable Suspicion

Any Team Member who displays behaviors that may cause a reasonable suspicion that they are under the influence of Drugs or Alcohol, including the misuse of prescription medication, may be required to take a drug test. Managers can refer to the Reasonable Suspicion Process and the Reasonable Suspicion Checklist for more information.

No such reasonable suspicion test will be allowed, nor results accepted without the prior approval of both management and the Administrator’s Master Level Clinician. 4.3 Drug Testing for Remote and Work-From-Home Team Members

Team Members who work in a remote setting (temporary or permanent) are also subject to post-hire drug testing.

Random – Team Members are required to comply with the instructions of their manager (as directed by the Vendor) to report for a random drug test.

Reasonable Suspicion – direct observations are required to proceed with a reasonable suspicion test. However, Team Members are expected to work in a coherent and professional manner at all times, and all Team Members are subject to an evaluation of coherency and may be subject to disciplinary action for appearing unfit for duty.

4.4 Drug Testing for Contract and Temporary Workers

Contract workers are required to undergo the drug testing requirements of their hiring agency, and those set forth in the contract between Walgreens and said agency pursuant to which they are providing services to Walgreens. However, at no time, are any workers performing work/services for Walgreens to be under the influence of any Controlled Substances or Alcohol.

Temporary workers may be subject to this policy’s drug-testing requirements for pre and post-employment testing, depending on the nature of the role being filled.

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5. After the Test (Review of Results)

5.1 Test Results

Instant oral tests will provide immediate results in most cases. Test results that do not read negative will require completion of a urine-based lab test. No test will be confirmed as positive and reported by the Medical Review Officer (MRO) as such unless it has undergone an initial and confirmation process, which will include verification of valid medications, including medical marijuana. 5.2 Medical Review Officer

The MRO (provided by the Vendor and/or Administrator) will contact the Candidate or Team Member and provide the individual with an opportunity to explain any laboratory- confirmed positive test result. At this time, the MRO will ask whether the Candidate or Team Member is taking a lawful and valid prescription or over-the-counter medication that may have altered test results. If the MRO validates the legitimate medical explanation of the substance, a negative result will be reported to the Company. 5.3 Compliance with this Policy

Attempts to substitute, adulterate, or dilute the test specimen will be considered as a failed test.

Candidates who do not test within the determined guidelines, including assigned time frames, will be considered to have refused the test. Team Members who fail to fully cooperate with any aspect of this policy, including, but not limited to, refusing to take a required test or authorize the release of test results; refusing to cooperate with searches or Company investigations; not seeking professional evaluation for Drug and Alcohol dependency; or failing to comply with rehabilitation conditions imposed by the Company or Substance Abuse Professionals

(SAP) will be subject to employment termination.

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5.4 Back on Track Program

Our Company recognizes the seriousness of chemical dependency. We will assist Team Members with Drug or Alcohol problems to find the appropriate resources they need to get help.

Team Members with more than two years’ service who test positive for any form of Illegal Drug/Controlled Substance or Alcohol (other than marijuana, which is addressed below) will be admitted to the Back on Track Program, where they will be assessed by a qualified Substance Abuse Professional (SAP) who will make recommendations that, if followed, may lead to reinstatement, absent theft or wrongdoing. A subsequent positive test result while in a Back on Track Program will subject the Team Member to employment termination. Final decisions regarding recommendations for return to work will be made by the Company.

Team Members with less than two years’ service who test positive for any form of Illegal Drug/Controlled Substance or Alcohol will be subject to employment termination, unless prohibited by law. See marijuana guidelines below. 6. Marijuana Guidelines

• Medical Marijuana: The valid and lawful use of marijuana for medical purposes, when permitted by state law, regulation or ordinance, and accompanied with a valid and lawful prescription and/or medical marijuana card will be reported as a verified negative drug test for marijuana.

• Recreational Marijuana: Unless prohibited by state or local law, a Candidate’s or Team Member’s use of marijuana for recreational purposes will not be considered an acceptable explanation for a confirmed positive drug test for marijuana on a Company-authorized drug test and will be reported as a verified positive drug test for marijuana.

• Hemp Use: A failed drug test will not be excused merely due to Candidate or Team Member’s claim of hemp ingestion or use.

• CBD Products: Use of CBD products is not expressly prohibited under this policy, but a failed drug test will not be excused merely due to a Team Member’s claim that the result was due to his or her use of CBD products, or due to substances or products, including CBD products, that were purchased or sold at Walgreens. WAG POL DDD-009, Drug Free Workplace

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6.1 Medical Marijuana Use

Regardless of tenure or employment status, Team Members and Candidates who possess a valid and lawful medical marijuana card and/or prescription prior to the date of testing will not be subject to adverse action. Final test results are subject to MRO clearance and review. Team Members who test positive and have a valid and lawful medical marijuana card will be offered a reasonable accommodation (see Reasonable Accommodation Policy on Ask Walgreens). Under no circumstances may a Team Member report to work under the influence of any Controlled Substance, including medical marijuana, making them unfit for duty. Team Members who present to work under the influence of Alcohol or Illegal Drugs/Controlled Substances will be subject to disciplinary action, including and up to termination. Team Members are not permitted to bring marijuana, even when medically prescribed, on Company property, even in states where use or possession of medical and/or recreational marijuana is legal.

6.2 Recreational Marijuana Use

Several states have legalized the use of recreational marijuana. However, that does not permit Team Members to come to work under the influence and unable to perform the functions of their job. Team Members who test positive for marijuana in states that have legalized usage, but do not possess a valid marijuana card, will be placed into the Back on Track Program.

Team Members who test positive in a state that has not legalized marijuana for recreational use will be subject to termination, unless they have a minimum of two years’ service

(without considering a pending bridge of service). 6.3 Non-Adverse Action States

The Company will comply with state and jurisdiction laws that prohibit employers from taking adverse employment action against Candidates and Team Members who use marijuana for recreational or medical purposes and/or possess a valid marijuana card. The Vendor as negative will report such test results.

7. Rehire and Reapplication Eligibility after a Positive Test Candidates and Team Members terminated due to violation of this policy are eligible to reapply after twelve months from being rejected or terminated. Team Members who leave the organization while actively participating in the Back on Track Program are eligible for WAG POL DDD-009, Drug Free Workplace

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rehire, if they were compliant at the time of separation. The Team Member must present proof of completion of a comparable and approved (by Vendor) program or be reinstated into the program (with approval of the next level hiring manager). Eligibility to reapply does not automatically guarantee rehire.

8. Related Policies & Documents

1) Marijuana State Guidelines

2) Random Drug Testing Process

3) Reasonable Suspicion Process

4) Back on Track Program Guidelines

5) Drugs Included in this Test

6) Reasonable Accommodation Policy (Ask Walgreens) 9. Policy Revision History

Version number Issue date Description of changes

Version 1.0 January 2010 Approximate date on initial version Version 2.0 December 2020 Addressees the new testing structure to explain who, when and how tested. Moved all marijuana components to one area. Removed processes and specific procedures, providing high-level overview. Addresses work-from-home and

contractor groups.

10. Contact Information

Name Contact Information

Tabatha French, Specialist, Employee

Relations

*******.******@*********.***

Jon Kelly, Director, Employee Relations ********.*****@*********.*** WAG POL DDD-009, Drug Free Workplace

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11. Approval Matrix

Name Title

David Metz Sr. Counsel, Employment Law

Jon Kelly Director, Employee Relations

Hillary Leisten SVP and Chief Human Resources Officer

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