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ALCOHOL AND DRUG POLICY

I. PURPOSE OF THE POLICY........................................................................................................- 3 -


II. SCOPE AND APPLICATION........................................................................................................- 3 -
Contractors ...................................................................................................................... - 3 -
Definitions........................................................................................................................ - 4 -
III. PRINCIPLES ...................................................................................................................................- 6 -
1. ALCOHOL AND DRUG WORK RULE ........................................................................................- 6 -
1.1 Work Rule .................................................................................................................. - 6 -
1.2 Prescription Drugs and Non-Prescription Drugs ......................................................... - 6 -
1.3 Social Situations ......................................................................................................... - 7 -
1.4 On-Call and Emergency Call-In .................................................................................. - 8 -
1.5 Site Specific Standards .............................................................................................. - 8 -
1.6 Vehicles and Licenses ................................................................................................ - 8 -
2. PREVENTION, ASSISTANCE AND VOLUNTARY TREATMENT .........................................- 9 -
2.1 Prevention .................................................................................................................. - 9 -
2.2 Assistance .................................................................................................................. - 9 -
2.3 Responsibilities .......................................................................................................... - 9 -
2.4 Aftercare..................................................................................................................... - 9 -
2.5 Confidentiality ............................................................................................................. - 9 -
3. ALCOHOL AND DRUG TESTING .............................................................................................- 10 -
3.1 Standards for Alcohol and Drug Testing ................................................................... - 10 -
3.2 Types of Alcohol and Drug Testing ........................................................................... - 10 -
3.3 Testing Procedures .................................................................................................. - 12 -
3.4 Alcohol and Drug Testing Results............................................................................. - 12 -
4. SEARCHES OF PEMBINA WORKSITES ................................................................................- 12 -
4.1 Reasonable Cause Searches ................................................................................... - 13 -
4.2 Random Searches .................................................................................................... - 13 -
IV. COMPLIANCE ..............................................................................................................................- 13 -

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CONSEQUENCES OF A VIOLATION ..............................................................................................- 13 -


Discipline .......................................................................................................................... - 13 -
Referral to Substance Abuse Expert ................................................................................. - 14 -
Duty to Accommodate ...................................................................................................... - 14 -
Conditions of Return to Work ............................................................................................ - 14 -
Failure to Follow Recommendations ................................................................................. - 14 -
V. ADMINISTRATION ......................................................................................................................- 14 -
VI. REVIEWED AND APPROVED ..................................................................................................- 15 -
VII. RELATED POLICIES...................................................................................................................- 15 -
VIII. SUPPORTING DOCUMENTS ...................................................................................................- 15 -
APPENDIX A .................................................................................................... - 16 -
ACKNOWLEDGEMENT OF ALCOHOL AND DRUG POLICY AGREEMENT .................. - 16 -
APPENDIX B .................................................................................................... - 17 -
REASONABLE CAUSE CHECKLIST ............................................................................... - 17 -
APPENDIX C.................................................................................................... - 18 -
DRUG CATEGORIES ...................................................................................................... - 18 -
APPENDIX D.................................................................................................... - 19 -
ALCOHOL AND DRUG TESTING PROCESS .................................................................. - 19 -

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I. PURPOSE OF THE POLICY


Pembina is committed to the health, safety and wellness of its Personnel, Contractors and the public. The
use of Alcohol and Drugs can have serious adverse impacts on the workplace and Pembina is committed
to ensuring that such adverse impacts do not arise. This Policy supports Pembina’s Health, Safety and
Environment Policy and is part of Pembina's overall approach to risk mitigation and safety.

To this end, this Policy is designed to: (i) ensure that all Personnel are physically and mentally fit to safely
perform their assigned duties; (ii) ensure that all supervisors and managers have clear direction on how to
assess the need for testing, initiate testing protocols and address Alcohol and Drug related issues; and (iii)
deter the use of Alcohol, Drugs and other substances which may impair judgment, work performance or
safety.

In this context, Pembina shall be responsible for:

• ongoing leadership and supervision to ensure safe operations and effectiveness of its safety
program;

• determining and providing appropriate levels of training for Personnel;

• guiding Personnel who voluntarily seek assistance for personal problems related to Alcohol
and/or Drugs to appropriate resources while maintaining confidentiality in accordance with all
applicable privacy laws and Pembina's Privacy Policy;

• making arrangements for an assessment through human resources if, in the course of any
performance-related or other type of discussion, any Personnel states that he or she has a
problem with Alcohol or Drugs;

• taking appropriate steps to investigate any possible known or reported violation of the
requirements set out in this Policy; and

• implementing the requirements of this Policy.

II. SCOPE AND APPLICATION


This Policy applies to all Employees, Executives, and directors of Pembina (“Personnel”). However, the
Alcohol and Drug testing procedures set out in Section 3 of this Policy only apply to Personnel working in
Safety Sensitive Positions and prospective Employees applying for Safety Sensitive Positions. For greater
certainty, this Policy applies at any time when Personnel are: (i) engaged in Pembina business whether on
or off a Pembina Worksite; (ii) on a Pembina Worksite; (iii) operating Pembina Vehicles and equipment;
and (iv) scheduled On-Call. Contractors must comply with this Policy in accordance with Part II of this Policy
under the heading “Contractors”.

Contractors
Pembina extends its concern for the safety of its workforce to all Contractors. All Contractors are required
to either: (i) abide by this Policy; or (ii) have a substantially similar policy that adheres to or exceeds the
principles and standards set out under this Policy. Pembina reserves the right to review any Contractor
policies to ensure compliance with Part II of this Policy.

Contractors that do not have a substantially similar policy that adheres to or exceeds the principles and
standards set out under this Policy must: (i) acknowledge and agree in writing that they will strictly abide

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(and cause all of their employees and contractors to abide) by the principles and standards set out under
this Policy when providing services to Pembina; (ii) provide a copy of this Policy (including all amendments
thereto) to all individuals and entities employed or engaged to perform services for Pembina.

Pembina expects Contractors to remain free from any adverse performance effects of Alcohol and Drugs
and conduct themselves in an appropriate manner while performing services for Pembina or on Pembina
Worksites. All Contractors must be Fit for Work and remain Fit for Work while performing services for
Pembina.

Notwithstanding the above, Pembina reserves the right to:

• test Contractors engaged in Safety-Sensitive Positions in accordance with Section 3 of this


Policy as required to ensure the safety and protection of persons, property and the
environment;

• require Contractors to certify that all individuals employed or engaged to perform services for
Pembina in Safety-Sensitive Positions have been tested for Alcohol or Drugs prior to
performing services for Pembina or their first entry to a Pembina Worksite;

• require Contractors to maintain statistics of testing dates and results (without identifying the
individuals tested), which may be reviewed by Pembina at any time; and

• refuse access by Contractors to a Pembina Worksite in connection with ensuring the safety or
protection of persons, property and the environment.

Failure to comply with the requirements set out in Part II of this Policy under the heading “Contractors” may
be cause for immediate termination of the Contractor's engagement by Pembina.

Definitions

In this Policy:
"Alcohol" means any substance that may be consumed and that has an alcoholic content in excess
of 0.5 per cent by volume;

"Applicant" means any Employee or prospective Employees, including summer students and co-
op students (collectively, "Applicants");

"Camp Rules" means Pembina's Construction Camp Rules, as such document may be amended
from time to time;

"Contractor" means any individual or entity that is not a Pembina employee and that is engaged
by Pembina to perform services for Pembina and includes all employees and contractors of
individuals or entities engaged by a Contractor to perform services for Pembina;

"Drug" means any substance, chemical or agent, the use or possession of which is unlawful in
Canada or requires a personal prescription or authorization from a licensed treating physician, or
the use of which is regulated by legislation such as marijuana/cannabis, or any other psychoactive
substance, and any non-prescription medication lawfully sold in Canada, and drug paraphernalia;

"EFAP" means Pembina's Employee and Family Assistance Program;

"Employee" means any regular full-time, part-time, contract, temporary, casual, co-op, summer
and seasonal employee of Pembina;

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"Executive" means any of the President and/or Chief Executive Officer, the Chief Financial Officer,
the Senior Vice Presidents, and the Vice Presidents of Pembina Pipeline Corporation;

"Fitness for Work" or "Fit for Work" in the context of this Policy means being able to safely and
acceptably perform assigned duties without any limitations due to the use or after-effects of Alcohol
or Drugs;

"Non-Prescription Drug" means any Drug that can be lawfully purchased without a prescription;

"On-Call" means the designated period during which an Employee is expected to respond to
Pembina business or be available to work outside of his or her normal working hours;

"Pembina" means Pembina Pipeline Corporation and its subsidiaries;

"Pembina Event" means any Executive-approved Pembina-sponsored social event or social


function;

"Pembina Office" means Pembina’s head office and any permanent Pembina office;

"Pembina Vehicle" means: (i) a Pembina owned, rented, leased or otherwise controlled motor
vehicle; or (ii) a motor vehicle that is being operated on Pembina business where Pembina is paying
or reimbursing the Personnel or Contractor for such motor vehicle. For greater certainty, motor
vehicle includes, without limitation, a car, truck, SUV or any other motorized equipment capable of
transporting people or goods;

"Pembina Worksite" means any place where Pembina conducts business, including, without
limitation, property, buildings, equipment, road systems and Pembina Vehicles, whether owned,
leased or rented;

"Policy" means this Alcohol and Drug Policy, as such document may be amended from time to
time;

"Prescription Drug" means any Drug that can only be obtained with a prescription from a physician
licensed to prescribe Drugs. Prescriptions must be made out to a specific individual and filled by a
licensed pharmacist;

"Reasonable Cause" means whenever an authorized Pembina representative has reasonable


grounds to believe that the actions, appearance or conduct of an Employee or Contractor while on
duty are indicative of the use of Alcohol or Drugs (other than the approved use and possession of
Prescription Drugs and Non-Prescription Drugs in accordance with Section 1.2). Reasonable
grounds may include, without limitation, the physical and behavioural symptoms identified in
Appendix B;

"Safety-Sensitive Position" means a position in which an Employee or Contractor has a key or


direct role in an operation where any action or decision he or she makes, if not carried out properly,
could result in a serious incident. The potential consequences of such an incident may include
fatalities, serious life altering injury to Employees, Contractors, customers, visitors or the public,
significant property damage or significant environmental damage. A matrix describing various
safety sensitive roles and responsibilities is set out in the Safety Sensitive Position Matrix. For
greater certainty, all Executives shall be considered to occupy Safety-Sensitive Positions.

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"Site Specific Standards" means those standards that relate to a specific Pembina Worksite or
business unit, including but not limited to the Camp Rules; and

"Substance Abuse Expert" means an individual with knowledge of and clinical experience in the
diagnosis and treatment of Alcohol and Drug related issues.

III. PRINCIPLES
1. ALCOHOL AND DRUG WORK RULE
1.1 Work Rule
Personnel shall not:

• use, possess (other than as permitted by Section 1.3 of this Policy) or offer for sale Alcohol
(other than as permitted by Section 1.3 of this Policy) or Drugs (other than as permitted by
Section 1.2 of this Policy) or any product or service that may be used to attempt to tamper with
any sample for an Alcohol or Drug test while on a Pembina Worksite;

• tamper with a sample for an Alcohol or Drug test;

• refuse to comply with a request under this Policy;

• subject to compliance with Section 1.6 wherein Pembina has a zero tolerance policy for the
use of Alcohol or Drugs when operating a Pembina Vehicle, report to work or be at work with
an Alcohol level equal to or in excess of 0.040 grams per 210 litres of breath (other than as
permitted by Section 1.3 of this Policy);

• report to work or be at work while his or her ability to perform his or her duties is adversely
affected because of the use of a Prescription Drug or Non-Prescription Drug (other than as
permitted by Section 1.2 of this Policy); or

• report to work or be at work with a Drug level equal to or in excess of the concentrations set
out in the standards endorsed by Energy Safety Canada.

Personnel shall:

• restrict consumption of Alcohol and Drugs where scheduled to work or be On-Call; and

• where applicable, ensure that no safety sensitive decision is made while under the influence of
Alcohol or Drugs.

1.2 Prescription Drugs and Non-Prescription Drugs


Personnel are expected to use Prescription Drugs, Non-Prescription Drugs and other medications
responsibly in accordance with this Policy and the directions of their physician or pharmacist and the
manufacturer of the Prescription Drug, Non-Prescription Drug or other medications. The misuse of
Prescription Drugs and/or Non-Prescription Drugs while engaged in Pembina business or on a Pembina
Worksite is prohibited. Prescription Drugs and Non-Prescription Drugs of particular concern are those that
inhibit or may inhibit a Personnel’s ability to safely perform his or her job and be Fit for Work.

The possession or use of Prescription Drugs and Non-Prescription Drugs is permitted only under the
following conditions:

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• in the case of a Prescription Drug, such drug has been prescribed to the Personnel by a
physician;

• the Personnel is using the Prescription Drug or Non-Prescription Drug for its intended purpose
and in the manner directed by the Personnel's physician or pharmacist and the manufacturer
of the Prescription Drug or Non-Prescription Drug;

• the use of the Prescription Drug or Non-Prescription Drug does not adversely affect the
Personnel's ability to safely perform his or her duties and be Fit for Work; and

• the Personnel has notified his or her supervisor or manager before starting work of any
potentially unsafe side effects associated with the use of the Prescription Drug or Non-
Prescription Drug.

Personnel are expected to investigate and fully understand (through their physician or pharmacist) whether
a Prescription Drug or Non-Prescription Drug may affect the performance of their job-related functions and
take appropriate steps to minimize any associated risk. For further guidance on the use of medications,
please refer to the Medication Conventions.

Personnel are expected to abide by any requirement for work modification or other appropriate course of
action to minimize any safety risk associated with the use of Prescription Drugs or Non-Prescription Drugs.
Pembina reserves the right, on a confidential basis, to confirm any requirement for modified work with the
Employee's physician or pharmacist.

1.3 Social Situations


Pembina recognizes that consumption of Alcohol may occur with prior Executive approval at Pembina
Events. Accordingly, where permitted, Alcohol may be consumed by Personnel responsibly and in
moderation at Pembina Events.

Pembina’s Code of Ethics Policy, Respectful Workplace Policy and this Policy remain in effect at Pembina
Events. Consistent with the above, if Alcohol is made available in the course of conducting business during
or after the formal work day at a Pembina Event, Personnel are expected to:

• exercise good judgment and be responsible in hosting others;

• consider the impact of any Alcohol consumption on judgment and behaviour; and

• restrict consumption of Alcohol such that an appropriate level of professionalism and personal
decorum is maintained.

All Personnel are further responsible to use safe transportation and not to operate a motorized vehicle
under the influence of Alcohol or Drugs following Pembina Events. Personnel who operate a Pembina
Vehicle must also comply with the requirements set out in Section 1.6. A failure to abide by this requirement
will be treated in accordance with Sections 1.6 and in Part IV (Compliance) of this Policy.

Personnel are responsible for Pembina guests at Pembina Events. If a Personnel suspects that a Pembina
guest is under the influence of Alcohol or Drugs, the Personnel will ensure safe transportation for such
guest.

Notwithstanding anything else in this Policy, possession, recreational use, distribution and/or the selling of
marijuana, cannabis or any derivative product of marijuana or cannabis at Pembina Events is strictly

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prohibited. A failure to abide by this requirement will be treated in accordance with Part IV (Compliance) of
this Policy.

Personnel at a Pembina Office may store Alcohol on site in limited circumstances. Specifically, Personnel
at a Pembina Office may temporarily store Alcohol in a factory sealed container in the company kitchens,
his/her office or a personal vehicle parked on Pembina premises or in a vehicle provided or assigned by
Pembina when the vehicle is not being used for Pembina business, provided it is locked in the trunk of the
vehicle or otherwise appropriately secured. The Alcohol must at all times remain sealed and be removed
as soon as possible.

Such limited exception does not apply to Personnel working at any Pembina Worksite other than a Pembina
Office. For greater certainty, no such Personnel will be permitted to store or possess any Alcohol at any of
Pembina's Worksites. Personnel's obligations in this respect will continue to be governed by Site Specific
Standards (as further discussed at Section 1.5 of this Policy).

1.4 On-Call and Emergency Call-In


Any Personnel scheduled to be On-Call is expected to remain Fit for Work, in compliance with this Policy,
and be capable of responding to Pembina business throughout his or her On-Call period.

If any Personnel is not On-Call and is requested to perform unscheduled work while under the influence of
Alcohol or Drugs and not Fit for Work, it is the Personnel's responsibility to declare himself or herself as not
Fit for Work and decline the work. If any such Personnel declares himself or herself as not Fit for Work at
such time, the Personnel shall not be penalized for declining such work.

If any Personnel is being asked to provide advice or guidance on Pembina business and he or she is under
the influence of Alcohol or Drugs and not Fit for Work, it is the Personnel's responsibility to declare himself
or herself as not Fit for Work and refrain from providing advice or guidance on Pembina business. In such
situations, the decision or advice will be deferred to the next reasonably qualified person to provide the
advice or guidance.

1.5 Site Specific Standards


This Policy sets out requirements which may be enhanced or modified by any Pembina Worksite or
business unit where justified. Any enhancements or modifications must be in the form of a Site Specific
Standard that is supported by justification and brought forward for approval by Pembina's safety, legal and
human resources departments in consultation with the applicable business unit leader.

1.6 Vehicles and Licenses


All Personnel operating motor vehicles on Pembina's behalf are required to maintain a valid driver's license.
Personnel is required to notify his or her manager as well as Pembina's human resources department
immediately upon suspension or disqualification of his or her license to operate a motor vehicle, regardless
of the reason or duration of the suspension or disqualification. In the event of a suspension or
disqualification, the Personnel will no longer be qualified to drive on Pembina's behalf.

Pembina has a zero-tolerance policy for Personnel who operate a Pembina Vehicle with an Alcohol or Drug
concentration greater than zero (other than approved use of Prescription or Non-Prescription Drugs in
accordance with Section 1.2).

Any Personnel charged with an impaired driving offence (impairment testing, including but not limited to,
blowing over the applicable legal limit, driving while impaired or refusing to be tested for impairment) when

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operating a vehicle on Pembina's behalf must immediately notify his or her manager as well as Pembina's
human resources department.

Receipt of an impaired driving charge will result in an investigation by Pembina. Following such
investigation, the Personnel may be subject to a range of consequences pursuant to Part IV (Compliance)
of this Policy which may include, depending on the circumstances, modified work, referral to an assessment
with a Substance Abuse Expert and/or discipline up to and including termination of employment.

Notwithstanding the foregoing, failure to report an impaired driving charge will generally constitute grounds
for termination of employment for cause. A conviction for an impaired driving offence when driving on
Pembina business or in a Pembina Vehicle will generally also constitute grounds for termination of
employment for cause.

2. PREVENTION, ASSISTANCE AND VOLUNTARY TREATMENT


2.1 Prevention
Pembina recognizes the importance of prevention and early identification for Personnel with Alcohol or
Drug problems. Information about the health and safety issues associated with Alcohol and Drug abuse
and dependency is available to all Personnel. Assistance for problems associated with Alcohol or Drugs is
available to Personnel through Pembina’s Employee Family Assistance Program.

2.2 Assistance
Pembina strongly encourages any Personnel with Alcohol or Drug problems to seek counseling and
treatment. Any Personnel who believes he or she may have a problem with Alcohol or Drugs can access
help through: (i) Pembina's EFAP (ii) his or her physician or appropriate community services; and/or (iii)
Pembina's human resources department.

Personnel must seek assistance before an Alcohol or Drug problem adversely affects his or her work
performance or he or she is subject to testing in accordance with this Policy. No Personnel will be disciplined
or discriminated against for seeking assistance in accordance with this Policy.

2.3 Responsibilities
Notwithstanding the foregoing, declaring a problem with Alcohol or Drugs or accessing assistance does not
negate Personnel's obligation to remain Fit for Work in accordance with this Policy. Additionally, testing in
accordance with this Policy cannot be avoided by declaring a problem with Alcohol or Drugs, requesting or
accessing assistance for an Alcohol or Drug problem or disclosing that the Personnel is already involved in
a treatment program.

2.4 Aftercare
All Personnel who complete treatment for substance abuse or dependency in accordance with this Policy
will be required to participate in a structured aftercare program to maintain recovery. In such cases,
Personnel will be expected to enter into a written agreement with Pembina which outlines, in accordance
with Part IV (Compliance) of this Policy under the heading “Conditions of Return to Work”, the terms and
conditions governing his or her return to work and the consequences of failing to meet those terms and
conditions.

2.5 Confidentiality
Disclosure of Personnel's personal information in connection with this Policy will be restricted as much as
possible and limited to those individuals who have a need-to-know such information. For example, limited

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disclosure of personal information may be necessary for determining Personnel's Fitness for Work,
appropriate work accommodations and/or work re-entry initiatives. All Personnel personal information will
be collected, used, disclosed, stored and retained in accordance with all applicable privacy laws and
Pembina's Privacy Policy.

3. ALCOHOL AND DRUG TESTING


3.1 Standards for Alcohol and Drug Testing
Alcohol testing is completed in accordance with the standards of the U.S. Department of Transportation.
Drug testing is completed in accordance with the standards of the U.S. Department of Health and Human
Services and is conducted by laboratories certified by the U.S. Substance Abuse and Mental Health Service
Administration.

U.S. Department of Health and Human Services standards have been adopted by the Standards Council
of Canada. The U.S. Substance Abuse and Mental Health Service Administration has been responsible for
certifying laboratories in both Canada and the U.S. since 1998.

3.2 Types of Alcohol and Drug Testing


Pre-Employment Testing

Applicants applying for Safety-Sensitive Positions are required to successfully complete pre-employment
Alcohol and Drug testing as part of the job application process.

In the event of a positive Alcohol and Drug test, Pembina may:

• decline to extend a job or engagement offer to the Applicant; and

• advise the Applicant that the positive test result does not preclude the Applicant from re-
applying for a position with Pembina in the future.

Reasonable Cause Testing

Personnel in a Safety-Sensitive Position may be subject to Alcohol or Drug testing if Pembina has, in its
sole discretion, Reasonable Cause to believe that the Personnel is or may be unable to work in a safe
manner because of the use of Alcohol or Drugs.

The decision to test shall be made by a supervisor, manager or the most senior person on the Pembina
Worksite authorized by Pembina to make a decision under this Policy in conjunction with a second trained
person (e.g., another supervisor, manager or human resources representative) whenever possible. The
decision to test will be based on specific documented observations which may include, but are not limited
to, the factors provided for in Appendix B of this Policy.

Pembina will provide the Personnel with the reason for the Alcohol or Drug test. Personnel must be tested
as soon as possible after the decision to test under this Section 3.2(b) has been made. Pembina may
suspend the Personnel with pay until the results of the Alcohol or Drug test are made available.

Post-Incident and Near Miss Testing

Personnel in a Safety-Sensitive Position may be subject to Alcohol or Drug testing as part of Pembina's
investigation into a serious or significant work-related incident or near miss. A serious or significant work-
related incident or near miss includes:

• a fatality;

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• a serious personal injury to Personnel, Contractors, members of the public or any other
individual;

• an incident with the potential for serious injury to a Personnel, Contractors, members of the
public or any other individual;

• an act of violence;

• an environmental incident or the potential for an environmental incident with significant


consequences;

• significant or the potential for significant loss or damage to property or equipment;

• significant or the potential for significant loss of Pembina revenues or the payment of damages;
or

• an accident involving a Pembina Vehicle, or a motor vehicle involved in an accident on a


Pembina Worksite.

At Pembina's sole discretion, Personnel may also be subject to Alcohol or Drug testing for less serious
incidents or near misses if there was potential for serious or significant consequences to persons, property
or the environment.

Personnel will only be directed to such testing if a supervisor, manager or the most senior person on the
Pembina Worksite authorized by Pembina to make a decision under this Policy has reasonable grounds to
believe that the Personnel was involved in or connected to the incident or near miss. The supervisor,
manager or the most senior person on the Pembina Worksite authorized by Pembina to make a decision
under this Policy will make the request for testing under this Section 3.2(c) as soon as reasonably
practicable following the incident or near miss and will provide the Personnel with the reason for the test.

The Personnel must be tested as soon as possible after the decision to test under this Section 3.2(c) has
been made. Pembina may suspend the Personnel with pay until the results of the Alcohol or Drug test are
made available.

In the event a member of the next level of management above the person making the decision to test under
this Section 3.2(c) is present at the location where the incident or near miss occurred, such member of
management must be included in such a decision.

Return to Duty and Follow-Up Testing

Personnel in a Safety-Sensitive Position who, in Pembina's sole discretion, is permitted to return to work
after a positive Alcohol or Drug test or an assessment by a Substance Abuse Expert must successfully
pass an Alcohol or Drug test before returning to duty.

In the event the Substance Abuse Expert determines that the Personnel has a dependency, the Personnel
must: (i) actively participate and successfully complete any treatment program recommended by the
Substance Abuse Expert and comply with any such program before and following his or her return to work;
and (ii) comply with any follow-up testing prescribed by the Substance Abuse Expert.

Other Testing Circumstances

Pembina may require Alcohol and Drug testing in additional situations as a condition of compliance with
client requirements. Such requirements may include an obligation for Personnel to undergo a site access

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Alcohol and Drug test before entering a client's site. Personnel will, where possible, be advised in advance
of any such client requirements.

3.3 Testing Procedures


Pembina will direct the Personnel to a sample collection site designated by a certified lab, hospital or clinic
when testing for Alcohol and Drugs. In most cases, with the exception of pre-employment, return to duty
and follow-up testing: (i) the Personnel will be escorted and provided with transportation to the testing site;
and (ii) the Personnel will be provided with transportation to his or her residence following testing.

At Pembina's discretion, a qualified technician may be brought to the Pembina Worksite to conduct Alcohol
and Drug testing.

For further information regarding the Alcohol and Drug Testing Process, please see Appendix D of this
Policy.

3.4 Alcohol and Drug Testing Results


Alcohol and Drug tests can be returned as negative, positive, refusal to test or cancelled. All test results will
be provided in a confidential written report to a designated Pembina representative with explanation, added
comments and direction where required.

In order to preserve the confidentiality of test results, the designated Pembina representative and any
person to whom disclosure is permitted under this Policy are not permitted to disclose test results to any
person other than a person who needs to know the results to discharge an obligation under this Policy or
as required by law.

Negative Test Result

A negative test result means the Personnel is in compliance with the concentrations set out at Section 1.1
of this Policy. In the event of a negative test result, the designated Pembina representative will notify the
Personnel of such result and that no further steps will be taken under this Policy.

Positive Test Result

A positive test result means the Personnel failed to comply with the concentrations set out at Section 1.1
of this Policy.

Refusal to Test

A test result indicating a refusal to test means the Personnel failed to comply with the requirements set
out at Section 1.1 of this Policy.

Cancelled Test

A test result indicating that the test is cancelled means that the test cannot be relied upon for the purposes
of this Policy and that the Personnel will be required to undergo re-testing.

4. SEARCHES OF PEMBINA WORKSITES


Searches of Pembina Worksites may be conducted and/or supervised by a Pembina security representative
to confirm compliance with this Policy. Searches may be conducted in the following circumstances.

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4.1 Reasonable Cause Searches


Searches at Pembina Worksites may occur where there is Reasonable Cause to believe that a Personnel
or Contractor at a Pembina Worksite is in possession of any Alcohol, Drugs or other substance which is, or
may reasonably be suspected to be, in violation of this Policy or any other Pembina policy, practice,
guideline or rule.

Reasonable Cause to conduct searches will be determined in accordance with Appendix B of this Policy
and the Camp Rules. Searches will be conducted in accordance with the procedures prescribed in the
Camp Rules where applicable. Such searches may be conducted with or without sniffer dogs, and will at
all times be conducted in a reasonable manner.

Prior to work at a Pembina Worksite, Contractors will: (i) advise their employees and contractors that
Pembina may search its Pembina Worksites and any individual or property on these locations to confirm
compliance with this Policy; and (ii) obtain the consent of their employees and contractors to permit
Pembina to perform such searches.

4.2 Random Searches


Searches at Pembina Worksites may occur on a random basis without notice to Personnel or Contractors.
Such searches have been implemented as a means of responding to ongoing incidents with Alcohol and
Drugs at Pembina Worksites.

Random searches will be carried out using sniffer dogs trained in the location and detection of Alcohol,
Drugs and drug paraphernalia. Sniffer dogs will be accompanied at all times by a trained handler. All rooms,
operational areas and common areas at Pembina Worksites may be subject to such a search. Such
searches will be conducted in accordance with the procedures prescribed the Camp Rules where
applicable.

Prior to work at a Pembina Worksite, Contractors will: (i) advise their employees and contractors that
Pembina may search its Pembina Worksites and any individual or property on these locations to confirm
compliance with this Policy; and (ii) obtain the consent of their employees and contractors to permit
Pembina to perform such searches.

IV. COMPLIANCE
CONSEQUENCES OF A VIOLATION
Discipline
Personnel must comply with this Policy at all times. Pembina may discipline Personnel who fail to comply
with Section 1.1 or any other provision of this Policy. Any breaches of this Policy may result in disciplinary
action up to and including termination of employment for cause or termination of engagement without notice,
as well as potential civil and criminal sanctions. Determination of the appropriate disciplinary measure will
depend on the facts of each case, including the nature of the violation, the existence of prior violations, the
response to any prior corrective programs and the seriousness of the violation.

Violations of this Policy should be reported in accordance with Pembina’s Whistleblower Policy.

Pembina Pipeline ® is a registered trademark of Pembina Pipeline Corporation.


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Referral to Substance Abuse Expert

Before making a final decision regarding the discipline of any Personnel who has failed to comply with this
Policy, Pembina may direct the Personnel to meet with a Substance Abuse Expert.

If Pembina directs any Personnel to meet with a Substance Abuse Expert, the Substance Abuse Expert will
complete an initial assessment of the Personnel and provide both Pembina and the Personnel with a
confidential written report of the assessment's outcome and his or her recommendations. The Substance
Abuse Expert's initial assessment and follow-up report must be delivered to Pembina and the Personnel as
soon as possible.

Pembina shall consider the Substance Abuse Expert's report in making its determination on any disciplinary
measure.

Duty to Accommodate

Pembina shall take appropriate steps to determine whether any Personnel who has failed to comply with
this Policy has a disability (as defined by applicable human rights law) for which it has a duty to
accommodate. In the event Personnel who fail to comply with this Policy has such a disability, Pembina
shall accommodate that disability to the point of undue hardship as required by applicable law.

Conditions of Return to Work

A Personnel who, in Pembina's sole discretion, is eligible to return to work after a positive Alcohol or Drug
test or an assessment by a Substance Abuse Expert shall not be permitted to return to work until the
Personnel provides Pembina with:

• a certificate by either: (i) the treatment program service provider, certifying that the Personnel
has successfully completed a treatment program and continues to comply with all the
requirements of the treatment program; or (ii) a licensed physician with knowledge of substance
abuse disorders, certifying that the Personnel is able to safely perform the duties he or she will
be required to perform with Pembina; and

• a statement signed by the Personnel acknowledging that he or she agrees to abide by any
conditions imposed as part of a corrective treatment program and other such reasonable
conditions as set by Pembina.

Such requirements are in addition to the return to duty and follow-up testing obligations set out at Section
3.2(3.2d) of this Policy.

Failure to Follow Recommendations

Failure by the Personnel to attend an assessment with a Substance Abuse Expert or to follow any
recommended treatment program shall be cause for termination of the Personnel's employment for cause.

V. ADMINISTRATION
This Policy shall be administered in accordance with all applicable federal, provincial and local laws and
regulations.

Pembina Pipeline ® is a registered trademark of Pembina Pipeline Corporation.


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VI. REVIEWED AND APPROVED


The Vice President, Technical Services is the executive responsible for this Policy. This Policy will be
reviewed annually by the Vice President, Technical Services and submitted to the Safety Committee for
approval. In addition, this Policy will be reviewed by the Human Resources and Compensation Committee
and the Health, Safety and Environment Committee every three years, or if any there are any material
changes made to the Policy.

This Policy was last approved by the Safety Committee on July 20, 2018.

This Policy was last approved by the Human Resources and Compensation Committee and the Health,
Safety and Environment Committee on August 10, 2018.

VII. RELATED POLICIES


The following relate to the subject matter of this Policy:

• Health, Safety and Environment Policy


• Respectful Workplace Policy
• Whistleblower Policy
• Privacy Policy

VIII. SUPPORTING DOCUMENTS


Rules and Conventions in support of this Policy may be created and approved by Vice President, Technical
Services and the Safety Committee. The following Conventions support this Policy:

• Medication Conventions
In addition, the following matrix is reviewed and approved by Vice President, Technical Services and the
Safety Committee:

• Safety Sensitive Position Matrix


• Cannabis FAQ

Pembina Pipeline ® is a registered trademark of Pembina Pipeline Corporation.


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APPENDIX A
ACKNOWLEDGEMENT OF ALCOHOL AND DRUG POLICY AGREEMENT

I, _____________________________________, understand that Pembina Pipeline Corporation


and its subsidiaries ("Pembina") maintains an alcohol and drug policy (as amended from time to
time, the "Policy") requiring all employees to report to work free from impairment and fit for work.
I acknowledge that I have received and read a copy of the Policy. If I did not understand the
Policy, I have asked for and received an explanation about the obligations set forth in the Policy.
I understand that I am required to review and adhere to any updates or amendments to the Policy
and that any breach of the Policy may result in administrative and/or disciplinary measures, up to
and including termination of my employment for cause.

I also understand that as a condition of my continued employment, where the circumstances exist
requiring testing or a search as outlined in the Policy, Pembina may require me to undergo testing
or a search for the presence of alcohol or drugs and I hereby consent and agree to submit to such
testing or search.
I further consent to the collection, use and disclosure of my Personal Information (as defined
below) by Pembina pursuant to the Policy, and consistent with applicable provincial and federal
privacy laws. I understand that "Personal Information" when used in this acknowledgement
refers to information about me as an identifiable individual. I further understand that my Personal
Information includes my personal health information collected by Pembina for the purposes of
enforcing the Policy, such as the results of any substance testing results and/or assessments by
substance abuse experts being released to Pembina's authorized representative.
I also understand and agree that I am responsible for reporting any alcohol or drug dependency,
and the use of prescription or non-prescription drugs with the potential for causing unsafe side
effects, to my supervisor and/or manager.
THIS AGREEMENT SIGNED this ____ day of _____________20___, in the City of
____________________, in the Province of ____________________.

Witness (Signature) Employee (Signature)

Witness (Print Name) Employee (Print Name)

Pembina Pipeline ® is a registered trademark of Pembina Pipeline Corporation.


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APPENDIX B
REASONABLE CAUSE CHECKLIST

QUESTIONS
PHYSICAL SYMPTOMS YES NO BEHAVIOURAL SYMPTOMS YES NO
Smell of marijuana Disorientation:
Incense or room deodorizers Is the worker confused about:
Eye drops or mouthwash Where he/she is?
Needle marks on arms What day it is?
Smell of alcohol on worker's What time it is?
breath
Shaking or trembling hands Apparent inability to focus on work
Blank stare or expression Unusual or unexplained resistance
Deteriorating physical appearance to authority or refusal to follow
Excessive perspiration reasonable orders
Presence of substances with: Mood:
Appearance of drugs Belligerent
Drug Paraphernalia Moody
Eyes: Ecstatic
Bloodshot More nervous than usual
Dilated pupils Giddy
Pinpoint pupils Talkative
Speech: Drowsy
Slurred Confession that worker was:
Confused Drinking alcohol
Fragmented Using drugs
Slow Confirmation by co-workers
Unusually soft Sudden and/or unpredictable
Unusually loud change in energy level
Excessive trips to the restroom Change in appearance after lunch or
Lack of motor coordination break
Skin colour: Withdrawal/avoidance of peers
Pale Complaints from co-workers
Flushed Excessive absenteeism, especially
Excessive yawning Monday, Friday or the day after
Weariness/fatigue/exhaustion holidays or paydays.
Sunglasses worn at inappropriate Unauthorized or unscheduled
times absences
Prolonged lunch hours
Unusually high incidence of colds,
flu, upset stomachs and headaches
Unusual sneezing/nasal congestion
Tardiness
Unexplained departures from work
or job area
More than the average number of
work-related injuries, incidents or
mistakes?
Decrease in efficiency or productivity
Careless operation of equipment
Careless performance of job
Other signs? Explain below:

Pembina Pipeline ® is a registered trademark of Pembina Pipeline Corporation.


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APPENDIX C
DRUG CATEGORIES

Testing will be conducted in those circumstances outlined under the Policy to determine the presence of
six classes of Drugs: (i) cannabinoids; (ii) amphetamines; (iii) cocaine; (iv) opioids; (v) phencyclidine; and
(vi) Alcohol. If Pembina, in consultation with a Substance Abuse Expert, concludes there is justification to
include additional Drugs in this list, Personnel will be advised of the change. Testing for additional drugs
may also be required on an individualized basis on the recommendation of a treatment centre or Substance
Abuse Professional in a post-treatment situation.

Pembina Pipeline ® is a registered trademark of Pembina Pipeline Corporation.


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APPENDIX D
ALCOHOL AND DRUG TESTING PROCESS

SAMPLE COLLECTION, TESTING AND REPORTING OF RESULTS WILL BE CONDUCTED IN


ACCORDANCE WITH STANDARDS ESTABLISHED BY THE U.S. DEPARTMENT OF HEALTH AND
HUMAN SERVICES AND ACCEPTED THROUGHOUT NORTH AMERICA AND IN ACCORDANCE
WITH APPLICABLE LAW, IF ANY, IN ORDER TO ENSURE THE ACCURACY AND INTEGRITY OF
RESULTS. STEPS IN THE TESTING PROCESS ARE HIGHLIGHTED BELOW.

• Testing will be conducted in those circumstances outlined under the Policy to determine the
presence of six classes of Drugs: cannabinoids, amphetamines, cocaine, opiates, phencyclidine
and Alcohol. If Pembina concludes there is justification to include additional Drugs in this list,
Personnel will be advised of the change. Testing for additional Drugs may also be required on
an individualized basis on the recommendation of a treatment centre or Substance Abuse
Professional in a post-treatment situation.

• Collection of specimens for Drug testing and administration of Alcohol tests will be performed by
trained collection agents. Collection will take place as soon as possible after the decision to test
is made, and attempts at sample collection will cease at 8 hours for the Alcohol test and 32 hours
for the Drug test. All Personnel who are tested are required to sign a form to acknowledge the
accuracy of the Personnel and collector information and authenticity of the specimen(s). They
will be given a copy of the Drug Testing Custody and Control Form and the Alcohol Testing Form
for their records.

• Alcohol tests will be administered by a calibrated evidential breath analyzer with a printout of
test results. Only in those situations when a breath analyzer is not available for testing would an
alternative technology be used. Drug tests will be administered by urinalysis either using split
sample collection for transfer to the laboratory, or using a Point of Collection (quick test) urine
Drug screen at the collection site with confirmation testing at the lab should it be required.
Laboratory analysis of oral fluid samples may also be a part of this program using parallel
technology.

• All laboratory testing will be conducted by a fully qualified and accredited laboratory performing
a confirmation test by gas chromatography/mass spectrometry (GC/MS).

• Laboratory confirmed positive Drug test results will be reviewed by a qualified Medical Review
Officer (MRO). The MRO is an independent physician who will endeavour to discuss the result
with the Personnel in an effort to determine whether a positive test could have resulted from the
legitimate use of medications. The Personnel concerned will be given an opportunity to explain
the finding to the MRO who will then determine whether the result will be reported to the Pembina
Testing Program Administrator as a negative, a verified positive, or a tampered or substituted
specimen result.

• In the case of a verified positive Drug test result, or a tampered or substituted finding, the
Personnel may ask the MRO to require the split sample to be tested (or for single sample
collection, their sample to be retested) within 72 hours of receiving their results. If a second
confirmed positive or tampered test is reported, the person who requested the second analysis
is responsible for reimbursing Pembina for the associated costs.

• If the test is reported as dilute and negative, or cancelled because the specimen is invalid, the
Personnel will be required to provide an additional specimen for testing as soon as possible.

Pembina Pipeline ® is a registered trademark of Pembina Pipeline Corporation.


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• All test results will be reported directly to a designated Pembina representative. Except for the
release of information in accordance with this Policy and in situations affecting the health and
safety of workers and the public, results of all testing will be maintained by the designated
Pembina representative and will be kept confidential unless otherwise required by law or
authorized by order of a tribunal or court.

Pembina Pipeline ® is a registered trademark of Pembina Pipeline Corporation.

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