It Is the Policy of Sidewinder That Potential Occupational Health Hazards in the Workplace

Health, Safety, & Environment Manual HSE System Components Occupational Health Substance Abuse

POLICY 2.7 It is the policy of Sidewinder that potential occupational health hazards in the workplace be identified, associated risks assessed, and procedures defined to provide an appropriate level of control to eliminate or mitigate harm to personnel.

EXPECTATION 2.7.2 The use or possession of illegal drugs, drug paraphernalia, unauthorized substances, unlicensed firearms, or weapons at any office or work location of Sidewinder is prohibited.

PROCEDURE 1 When employees are prescribed new medication during their off days, details of the prescription medication must be phoned in, by the employee, to Axiom, at 1-877-502- 9466 prior to bringing the medication to a Sidewinder drilling location. Axiom will review the details of the medication and the employee will either be granted or denied permission to bring the medication to the drilling location. 2 No one will enter any Company work location if they are intoxicated by alcohol or under the influence of an illegal or improperly utilized drug. 3 Company functions involving the consumption of alcoholic beverages may not take place on Sidewinder premises without prior written authorization from a Company Officer. If authorized, during these functions employees are expected to exercise moderation and good judgment with regard to the amount of alcohol they consume. Abusing alcohol at any Company function may result in discipline up to and including termination. 4 As a safety precaution, entry into, presence upon or leaving any office, or work location of Sidewinder is conditioned upon the Company’s right to search and test or examine the person and personal effects of any employee or others for drugs, drug paraphernalia, unauthorized substances, unlicensed firearms or weapons and contraband. Searches are conducted by authorized persons only in as private and discreet a manner as possible. 5 Sidewinder has the right to conduct searches of company facilities, vehicles parked on company or customer property, in addition to the persons and their personal property or the property of Sidewinder employees, for the presence of prohibited substances. 5.1 Unannounced searches may be made on a random basis with the assistance of trained drug detection dogs or for the purpose of collecting samples for urinalysis. 5.2 Any search conducted of persons or personal property will be done with the permission of the employee involved and will be conducted in a manner to avoid undue damage to such property. Sidewinder will compensate for any damage resulting from the search. 6 Refusal to submit to a search or the discovery of prohibited substances will be grounds for immediate termination. 7 Sidewinder reserves the right to conduct scientific drug screening (urinalysis, blood tests, or the like) of employees or others entering, present upon or leaving the Company’s facilities, to detect drug use or abuse at any time. From time to time, and

Revision: 3 Page 1 of 2 Section 2 Document Validity Expires: 31-Dec-13 SubSection 2.7.2 Health, Safety, & Environment Manual HSE System Components Occupational Health Substance Abuse

without prior announcement, searches and scientific drug screening by authorized representatives will be made. 8 Refusal to submit to search and/or scientific testing, or the violation of this policy by possession of or a confirmed positive test for prohibited substances, will be considered cause for immediate termination with no eligibility for rehire. 9 The Company has an Employee Assistance Program (EAP) in place and strongly encourages employees to take advantage of it. This program is managed by a 3rd party provider. Employees may contact the provider at 1-800-511-3920 in confidence and without fear of reprisal, for additional assistance. 10 Asking for LAP assistance after being requested to provide a sample for testing or after testing reveals a confirmed positive for prohibited substances, does not protect a person from termination. 11 No employee will report to work under the influence of any substances, such as those prescribed by a physician, which may impair the safety of people or equipment. 12 The supervisor or manager will: 12.1 Notify all employees of the above policy at the time of employment. 12.2 Post the policy on alcohol and drug use in a prominent location at each operating area. 12.3 Assess the fitness for duty of all employees under his direction. 12.4 Immediately refer to the next level of management any symptoms of the use of drugs, as evidenced in speech, mannerisms, etc., to determine whether immediate relief from duty is necessary. 12.5 Follow standard disciplinary procedures. 13 Authorization of Tests. Any Sidewinder manager may, upon reasonable cause, authorize the administration of tests of breath or body fluids to determine the usage of drugs with the permission of the employee involved. Tests will be used to substantiate assessment of the employee's condition.

Revision: 3 Page 2 of 2 Section 2 Document Validity Expires: 31-Dec-13 SubSection 2.7.2