Employee Handbook

Version #19

8/19/2019 Table of Contents

Welcome to Accolade! 4 Our mission is that one day, every American has a person they trust to support them 5 through their entire healthcare journey. We believe this mission is a worthy one. 5 How do we carry out our mission? 5 Our Cultural Cornerstones 6 Accolade Origins 7 Origin Story 7 Our Leaders 7 GSD - Getting Stuff Done 14 At-Will Employment 14 Open Door Policy 14 Resolving Differences 14 Equal Employment Opportunity and Policy Against Discrimination and Harassment 15 Equal Employment Opportunity 15 Policy Against Harassment and Discrimination 15 Reasonable Accommodations 16 What To Wear 16 Travel, Entertainment, and Expenses 17 Office Life 17 Visitors 18 Postage, Shipping, and Office Supplies 19 Personal Property 19 Emergency Procedures and Weather 19 Communication 19 Updating Personal Information 20 Performance and Progress 21 Performance Management 21 Performance Support 21 Transfers and Promotions 22 Employee Referrals 22 Your Time 23 Work/Life Balance 23 Employment Status 23

©2020 Accolade Inc. Page 1 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Overtime 24 Off-The-Clock Work 24 Working Hours 24 Lactation Breaks 24 Paid Time Off 24 Time Off to Vote 25 Holidays 25 Day of Service 25 Floating Holidays (pro-rated based on hire date) 26 Leaves of Absences 26 Family and Medical Leave 26 Short-Term and Long-Term Disability 28 Maternity and Parental Bonding Leave 29 Military Leave 29 Jury Duty 29 Bereavement Leave 30 Crime Victim Leave 30 Leave for Emergency Services Personnel 31 Personal Leaves of Absence 32 Total Rewards 33 Total Rewards 33 401(k) Plan 33 Pay 33 Error in Pay 33 Workplace Injuries & Workers Compensation 34 Keeping it Real 35 No Smoking 35 Drug and Alcohol Policy / Substance Abuse Testing 35 Prohibited Use and Possession 36 Individuals Subject to Testing 36 Circumstances Under Which Testing May Be Required 36 Disciplinary Consequences 37 Your Privacy 38 No Violence 38 Confidentiality, Technology Invention and Intellectual Property Policy 39 Security Incident Response 39

©2020 Accolade Inc. Page 2 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Conflicts of Interest 39 Former Employer Confidential Information 40 External Business Ventures 40 Outside Employment 41 No Solicitation/No Distribution 41 Information Technology 42 Information Technology 42 Personal Device Acceptable Use Policy 42 Who is permitted to use a personal device to access Accolade systems? 43 Am I required to use a personal device for Accolade business? 43 No Texting While Driving! 43 Employee Social Media Policy 43 Guidelines 44 Know and Follow the Rules 44 When Posting About Accolade 44 Using Social Media at Work 45 Retaliation is Prohibited 45 Media Contacts (Speaking with the Media or other Third Parties) 45 Working From Home 46 Work from Home Audit Process: 46 Return of Company Property and Equipment 46 State Specific Appendices 48 Appendix A: Arizona 48 Military Leave 48 Constructive Discharge Notice 48 Appendix B: Washington 49 Meal Periods 49 Rest Periods 50 Washington Family Leave Act (WFLA) 50 Discussion of Wages 50 Wages and Salaries – (Seattle Only) 51 Background Checks – (Seattle Only) 51 Let's Talk 52

Hite m@@@e y Jp Z C I6 eIn N lY 3 R p b 2 l4 td G 9 ljL T A u oMS J9 @@@ !

We're so happy that you're a part of the Accolade family and look forward to the amazing work we will do together to reinvent healthcare.

At Accolade, our beliefs and values are very important, so we urge you to understand them and incorporate them into everything you do. This Handbook is designed to reinforce what makes Accolade unique, make sure you always know your purpose here, and how we get things accomplished at Accolade. It is the responsibility of every Accoladian to hold others accountable to everything in this Handbook.

If you save this Handbook as a favorite, you can easily access it as an on-going reference. As you grow with our company, you may have ideas for improving this content. Your ideas are always welcome and can be shared with us through email at [email protected].

Sincerely,

The People & Culture Team

Watch Video: https://www.youtube.com/watch?v=9czZ1rzwyik

©2020 Accolade Inc. Page 4 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Our mission is that one day, every American has a person they trust to support them through their entire healthcare journey.

ite m@@@e y Jp Z C I6 In N lY 3 R p b 2 4 td G 9 jL T A u MiJ9 @@@ We believe it’s time to think differently about healthcare. To recognize that conventional approaches are failing American families. To reject the notion that healthcare has to come with complexity, jargon, runarounds, and frustration. It's time to expect a better healthcare experience. We believe this mission is a worthy one.

Aite m@@@e y Jp Z C I6 tIn N lY 3 R p b 2 4 Atd G 9 jL T A u My J9 @c@@ colade, we recognize that healthcare is highly personal. That’s why we’ve created one, consumer-focused service to simplify care for our members. It’s why we treat people as individuals, not disease states. It’s why we pull together the best technology and analytics to support development of personalized action plans for every individual we serve. How do we carry out our mission?

Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oA u N C J9 @@@lade’s “high touch” approach isn’t possible without the array of advanced technologies that support our daily operations and help us identify opportunities for greater influence. Our integrated technology platform pulls in 150+ claims feeds every night from health plans, benefit administrators, and pharmaceutical benefit managers, integrating them into the decision support system used by every health assistant.

Our unique system provides a holistic, 360-degree view of every individual and covered family member, providing information ranging from benefits and claims eligibility to medical conditions, medications, and motivators. It also integrates gold-standard clinical knowledge databases, enabling consistent, evidence-based guidance.

No other company creates such a comprehensive, integrated picture of each person’s health needs. No other company marries that data to a trusted service model with proven results.

Accolade MBA Want to learn even more about how we carry out our mission? Check out Accolade MBA!

Our Accolade MBA program offers Accolade employees the opportunity to work towards a unique Masters in the Business of Accolade. The program helps employees understand the fundamentals of our business, why our customers are engaged with us, and the value we deliver them. Additionally, the modules provide an overview of the Accolade Solutions & Services, what powers those solutions, and our place in the competitive marketplace. Our Cultural Cornerstones

©2020 Accolade Inc. Page 5 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Cite m@@@e y Jp Z C uI6 In N lY 3 R p b l2 4 td G t9 jL T A u N S J9 @@@ re is sometimes hard to define. Dictionaries call it a set of beliefs, values, symbols, artifacts, and stories that shape action. Even if you can’t define it, you know it when you see it. At Accolade our cultural cornerstones link the best aspects of our past to what we aspire to be - a company, and a community of colleagues with a shared commitment to take care of our members and take care of each other. We find joy & purpose in serving others

Every day we bring the best of Accolade to everyone we serve. Compassion and empathy are pervasive in our actions. And our interactions. That's how we build personal, enduring relationships that can change someone's day. Someone's life. The world.

Making a difference is what we do. We do the right thing for the right reasons – and we do it well. Even when it's hard. We're boldly & relentlessly reinventing healthcare

We're on a mission to build an exceptional, enduring company. A company that changes the world, one person at a time.

It's why we dream BIG, believe BIG, act BIG. Then repeat.

We have an insatiable appetite to be the best. We aren't afraid of barriers. We knock them down, learn and then build something better. Bold decisions? Calculated risks? Super high expectations? Bring it on! Our curiosity drives us. And our passion and determination to improve healthcare for everyone provides the fuel. We call that being Accodacious. We're strong individually & together we're powerful

Unique. Quirky. Exceptional. Individuality is our strength. Embracing our differences enables us to solve tough problems in creative ways. Share ideas freely. Grow our careers and inspire each other. That's why we deliberately seek out the best people, new approaches, and fresh ideas to sustain and advance our mission.

We're all change agents. We believe in each other, in honesty, and in having fun. You won't find egos or office walls here. Because we aren't defined by titles – but by actions, behaviors, and results. We roll up our sleeves & get stuff done

Being wildly successful is more than a goal – it's a serious commitment. It's why we're disciplined, purpose-driven, and accountable for our results. And we go above and beyond to deliver on promises.

Results motivate us. And we aren't afraid of the hard work or tough decisions that get us there. We celebrate our successes. From big milestones to small moments, together we're improving the world and each other.

Hite m@@@e y Jp Z C I6 oIn N lY 3 R p b 2 w4 td G 9 jL T E ifQ = = @@ @ the heck did we get here? Origin Story

Bite m@@@e y Jp Z aC I6 In N lY 3 R p cb 2 4 td G 9 jL kT E u MS J9 @ @@ in 2007, all we had were a few desks and chairs, a disruptive idea, and a handful of people who were passionate about making healthcare less complicated. We set out to help individuals and families avoid costly mistakes and frustrating missteps. Along the way, we've proved that personalizing healthcare — taking an approach built on relationships, trust and a view of the whole person — works. We're demonstrating that providing this level of support allows us to guide people toward more effective, more cost-efficient care. Our Leaders

Tite m@@@e y Jp Z hC I6 In N lY 3 R p eb 2 4 td G 9 jL T E u MiJ9 A@@@ ccolade leadership team shares a commitment to transforming the healthcare experience by applying world-class expertise in healthcare, consumer services, technology, data science and large-scale change management. Their passion and talent help Accolade create high value for customers, and a long-term strategy for reinventing healthcare for millions of American businesses, individuals and their families.

Raj Singh

Chief Executive Officer

“What Accolade has already done, actually changing people’s lives in a way that’s so real and so human, is absolutely inspiring.”

Raj is currently the CEO of Accolade, the market leading on demand healthcare concierge for employers, health plans, and health systems. Raj joined the company as a board member, investor, and CEO in November, 2015. Today, Accolade has 700 employees focused on driving better outcomes and increased satisfaction for healthcare consumers while delivering incredible savings for payers.

Prior to that, Raj co-founded Concur (NASDAQ: CNQR), the global leader in travel and expense management, in 1993, two years after graduating from college. His initial role at Concur was in product management and his early years were focused on the product management and development organizations. In the twenty years that followed, he worked in nearly every role in the business – culminating in his final role as president, chief operating officer, and board director for the last nine years of his tenure.

In that role, he was responsible for all operational functions of the business ranging from sales and marketing to customer services to R&D and human resources. During that timeframe, the company grew from $60mm in revenues to over $800mm in revenues before eventually being acquired by SAP AG (NYSE:SAP) for $8.3bn in 2014.

Raj is married with two children. He graduated from Western Michigan University in 1991 (BSE). Today, he serves on the board of Avalara, a top provider of cloud-based tax compliance automation for businesses, Apptio, a SaaS technology business management solutions provider, and Seattle Children’s Hospital Foundation, a nonprofit 501(c)(3) organization.

Mike Hilton

Chief Product Officer

“The mission is so inspiring – the lives that have been changed and the successful journey that Accolade has already had – that’s why I’m here.”

©2020 Accolade Inc. Page 7 of 52 Employee Handbook • Version 19 • Published 8/19/2019 In the role of Chief Product Officer, Mike Hilton is responsible for our product, technology and analytics efforts.

Prior to Accolade, Mike was a co-founder of Concur, a pioneer in the cloud computing and travel and expense management space, and remained there during its entire 21-year history (prior to being acquired by SAP in 2014). At Concur, Mike served in various product and technology leadership roles, most recently as chief product officer.

“I listened in on a call with a health assistant and never looked back,” said Mike. “The mission is so inspiring – the lives that have been changed and the successful journey that Accolade has already had – that’s why I’m here. The opportunity to be part of the mission and to make a huge difference is one that I’m honored to accept.”

Before co-founding Concur, Mike helped launch the sales force automation space as part of the team that created ACT! at Contact Software/Symantec, and began his career at Apple Computer, where he led the development efforts for MacWrite Pro, at the time the leading word processor for the Macintosh.

Robert Cavanaugh

President

“The incredible mission and the spirit of the amazing people here is infectious.”

Rob Cavanaugh serves as the president of Accolade. In this role, he leads the company’s sales, operations, marketing, business development, and implementation services.

Rob formerly served as president, worldwide enterprise, SMB & Government at Concur. He held various positions over his 15+ year tenure, including executive vice president, client development, executive vice president, business development, and senior director of client services.

“I had months of soul-searching about what I wanted to do next after Concur, and there isn’t any other place in the world that I wanted to be more than Accolade,” Rob said.

Prior to joining Concur, Rob held consulting and implementation management positions at Seeker Software and Ceridian Corporation.

Rob served as an officer in the Unites States Army Reserve from 1991-2000. He holds a B.S. from Norwich University.

Carolyn Young

Chief Actuary

As Chief Actuary, Carolyn Young manages the team of actuaries that measure, evaluate and communicate the value of the Accolade solution – including the reduction in healthcare costs and trend, outcomes and improvements in utilization – for employers and health plans.

“I joined Accolade because it is so inspiring to be part of a company that is de-mystifying healthcare and truly helping people improve their health. Accolade helps employers realize cost savings, while delighting members and employees and being their person to help them through their healthcare journey. There isn’t anywhere else I’d rather be.”

Prior to joining Accolade, Carolyn spent nine years at Independence Blue Cross where she oversaw the Medical Cost Analysis and Trend Forecasting unit and created a best-in-class approach to address medical cost variances. Previously, Carolyn spent 10 years at CIGNA in a variety of actuarial roles.

©2020 Accolade Inc. Page 8 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Carolyn is a Fellow of the Society of Actuaries and a Member of the American Academy of Actuaries. She graduated from Villanova University with a Bachelor’s degree in Math. Carolyn and her family love to travel, and she has visited 21 countries to date.

Steve Barnes

Chief Financial Officer

“I love the passion and commitment at Accolade – particularly by Accolade Health Assistants – to help every patient, one at a time, receive the best healthcare outcome.”

As Chief Financial Officer, Steve Barnes is responsible for shaping and driving the financial and investment strategy at Accolade. He also leads efforts to raise capital—a vital aspect of our growth plans that requires forging strong relationships with the investment community.

Notes Steve, “I joined Accolade to be part of a mission-driven company led by passionate people who are tackling an important problem: providing better healthcare outcomes while simultaneously lowering costs.”

Steve comes to Accolade from NRG, which acquired Energy Plus Holdings, where he served as Chief Financial Officer as well as President. In these roles, he oversaw finance, strategy and mergers & acquisitions in support of a rapidly growing business. Prior to that, Steve was Managing Director and CFO at Novitas Capital, and he began his career as a CPA with KPMG.

Passion and creativity are essential leadership skills that Steve values: “I’m inspired by leaders who are unwavering in their desire to find new ways to solve big challenges, and who inspire others to go beyond their comfort zones to achieve great success.”

Steve earned his MBA from The Wharton School at the University of Pennsylvania and his BS in Accounting from Villanova University. He is proud to serve on the board of LiveConnections, a non-profit that brings innovative, cross-genre music experiences to diverse audiences through live performances and interactive education. Steve’s hobbies include music, sports, and spending time with his wife and two children.

Dave Swift

EVP, Chief Service Delivery Officer

“I’m proud to be part of Accolade’s efforts to reinvent healthcare. With empowered people, a heartfelt mission and hard work, we can make the world a better place.”

Dave Swift is the EVP, Chief Service Delivery Officer at Accolade. In this role, Dave is responsible for building Accolade’s services team to deliver exceptional personalized support for our customers and members.

Prior to joining Accolade, Dave had a 13-year career at Aon within the business process, analytics and outsourcing organization. While at Aon, Dave created and delivered analytics-backed services and commercial offers to address unique employer challenges and opportunities. He also worked as a consulting manager with Accenture, leading consulting engagements across a variety of fields including mergers and acquisitions, financial risk management, and supply chain management.

Dave received his Ph.D. in chemical engineering and molecular biology from the University of Pennsylvania and served as a Whitaker Foundation Scholar and a Graduate Fellow at Cornell University. Dave has a Bachelor’s of Science degree in chemical engineering from Clemson University.

©2020 Accolade Inc. Page 9 of 52 Employee Handbook • Version 19 • Published 8/19/2019 When not spending time with his family or working, Dave has a passion for helping people. He and his wife sponsor an Akha hill tribe orphanage in the Golden Triangle region of Northern Thailand.

Phong Nguyen

EVP, Product Management

“It’s inspiring to hear feedback from our customers about the impact we have on their lives. I know I am lucky to be a part of Accolade – to imagine and build products that support this mission and to learn from brilliant people every day.”

Phong Nguyen serves as EVP of Product Management for Accolade. In this role, he is responsible for overall strategy, roadmap and design of the company’s portfolio of products.

Prior to Accolade, Phong served as SVP & General Manager of Concur’s Expense and Invoice products. He also held leadership roles in the company’s Traveler Services, Mobile and Platform businesses. Before joining Concur, Phong worked at SAP for six years as Vice President across key functions including Mobility, Emerging Markets and Corporate Development.

Phong earned his MBA from the Tuck School of Business at Dartmouth College and graduated as a Joseph Wharton Scholar from The Wharton School of the University of Pennsylvania. He’s married with two daughters and enjoys traveling, sports and exploring the outdoors with his family. Phong sits on the board of directors of the Lupus Foundation of America.

Sarah Martino

SVP Product Management

“Hearing the stories of how our Health Assistants and nurses have impacted our members and their families has inspired me greatly. To be able to get the chance to build a platform that can truly help people and their families at what can be the most stressful time of their lives is why I came to Accolade.”

As Senior Vice President of Product Management, Sarah Kuberry Martino is responsible for overall strategy, roadmap, process and design of the company’s portfolio of products.

Prior to joining Accolade, Sarah held a variety of product positions over a 10+ year tenure at Concur, most recently serving as vice president of product management for Concur’s global expense product portfolio. Other roles include leading the product and engineering team for the small and mid-sized business market, and positions in program management and client services. Before joining Concur, she worked for travel and expense start-up Outtask.

Sarah holds a BA from The George Washington University. She is married with an amazing daughter and enjoys traveling, sports and spending time with family. She is a passionate supporter of girls’ education and sits on the board of Seattle Girls’ School.

Harish Naidu

Chief Technology Officer

In his role as Chief Technology Officer, Harish Naidu is responsible for leading and building out Accolade’s product capabilities.

“The demand for consumers to be more involved in their healthcare decisions and management continues to rise and Accolade is at the center of solving this need,” said Harish. “Bringing technology and data science to augment the one on one human interaction to enhance the personalization of healthcare is what attracted me to Accolade. As the need for

©2020 Accolade Inc. Page 10 of 52 Employee Handbook • Version 19 • Published 8/19/2019 innovative digital health solutions grows in our country, so too does Accolade. I’m eager to help drive the technology strategy and roadmap of this expanding company with an eye toward improving the lives of our clients around the country by giving them the means to maximize healthcare benefits in a cost effective manner.”

Harish joined the company in January 2016 as the Senior Vice President of Development before assuming the role of CTO.

He brings to Accolade more than 25 years of experience in the technology industry. Prior to joining Accolade, Harish served as Executive Vice President at GlobalScholar, Inc. and was General Manager for key products and initiatives at Microsoft for 22 years.

Harish holds a Bachelor of Engineering in Electronics and Communications from the College of Engineering Guindy, Chennai and a Master’s in Electrical and Computer Engineering from the University at Buffalo.

When he’s not busy working, Harish enjoys traveling with his family, reading, philosophy, politics and yoga.

Matt Eurey

SVP, Strategic Partnerships

As SVP, Strategic Partnerships at Accolade, Matt Eurey provides strategic oversight of the company’s relationships with employer customers, health plans and third-party administrators (TPAs). In this role, he is responsible for customer success and retention, as well as expanding and strengthening Accolade’s strategic relationships with health plans and TPAs. Previously, Matt also directed and supported the company’s relationships with industry consultants and other strategic partners.

Matt was formerly Vice President of Total Rewards at Lowe’s, where he was responsible for strategic oversight of all employee programs including employee satisfaction, compliance, and financial management. Prior to joining Lowe’s, Matt served as the Vice President of Benefits for Time Warner Cable for five years where he managed benefits and M&A activity for HR.

He holds a Bachelor of Science degree in business administration with a concentration in accounting from The Citadel in Charleston, S.C.

Elizabeth Napolitano

EVP, People & Culture

“We’re about genuine support, which means that we go to amazing lengths for our clients - and each other.”

As Executive Vice President of People & Culture, Elizabeth Napolitano plays a key role in shaping our employee experience across Accolade and ensuring we attract, develop, retain and engage our talent.

“A supportive work environment enables us each to do our best work every day to support our clients and customers. In my role, I’m able to lead the charge to ensure that a supportive culture is maintained and on ‘Making Accolade the best place to work,’” said Elizabeth.

Prior to moving into her People & Culture role, Elizabeth served as the Executive Vice President of Operations and Client Experience, tasked with making certain that our Accolade Health Assistants had the training, coaching, tools and support needed to answer people’s questions and get the care that’s right for them.

“We view patients as people. Often they’re hurting, confused, scared or frustrated,” Elizabeth said. “But they’re never defined by their medical issues. Our Health Assistants honor that, and support each other in our mission.”

©2020 Accolade Inc. Page 11 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Before she joined Accolade, Elizabeth’s career focused on building and providing a world-class consumer experience to premium brands and their customers. She was general manager & VP of Client Experience at Circles and, prior to that, area director for The Ritz-Carlton Hotel Company.

Elizabeth has a bachelor’s degree in American Government from Georgetown University.

Inspired by beautiful places and interesting people (just like Accolade!), Elizabeth loves to travel. At home, her husband & children revel in the Red Sox culture along with their family dog, Lola, and cats, Bo and Sox.

Todd Clardy

EVP, Marketing

As Executive Vice President of Marketing, Todd Clardy is responsible for defining and promoting Accolade’s brand promise and personal advocacy solutions to employers, consultants and health plans. He provides strategic oversight for the company’s segment and product marketing, field marketing and corporate communications initiatives. Prior to assuming this role, Todd served as Senior VP of Product Marketing, responsible for developing Accolade’s product and segmentation strategy. He joined Accolade from Concur, a cloud-based travel and expense management company, where he held a variety of leadership roles over 12 years, including Senior Vice President of Global Marketing.

Todd brings more than 23 years of experience in the software industry, specializing in cloud-based technologies. He holds a Bachelor of Arts degree in Financial Administration from Michigan State University.

Tina Gilbert

Sr Dir, Inclusion & Diversity

As Senior Director of Inclusion and Diversity (I&D), Tina Gilbert is responsible for defining and driving the company’s I&D strategy and building the frameworks for I&D programs and policies. She identifies opportunities to build diverse talent pipelines for promotions and hiring needs.

Prior to joining Accolade, Tina was the Inclusion and Diversity Leader for Teva Pharmaceuticals. As the first I&D leader at Teva, she guided the organization’s evolution from diversity compliance management to recognizing its value as a business imperative. Her progress was recognized in 2017 by Diversityinc Magazine.

Before working as a Diversity Practitioner, Tina spent more than 15 years in management consulting at Accenture, where she led large transformation projects, business strategic planning programs, and operations/organizational design.

Tina is a Board member of Leadership Philadelphia, a member of the Healthcare Business Women’s Association, and has participated in Vision 2020’s Leadership Circle and the Philadelphia Chamber’s Diversity Executive Network.

She holds a bachelor of science degree from Spelman College, an Industrial Engineering degree from the Georgia Institute of Technology, and an MBA from The Wharton School, University of Pennsylvania. Tina and her husband reside in suburban Philadelphia with their two daughters. Both Philly natives, they are huge Eagles and Sixers fans.

Rich Eskew

EVP, General Counsel, and Chief Privacy Officer

“It’s an honor to work for a company that has as its North Star the goal of making people’s lives better. Accessing the healthcare system when you need it the most can be a frustrating process, and we spend every day trying to figure out how to make that experience better and less expensive for our customers and their employee families.”

©2020 Accolade Inc. Page 12 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Rich Eskew serves as EVP, General Counsel, and Chief Privacy Officer at Accolade. In these roles, he is responsible for helping Accolade close new deals, bring new products and services to market, and manage the company’s legal and regulatory risk. With trust and privacy at the core of how Accolade supports its members, Rich focuses on maintaining a world-class privacy program and ensuring that all Accolade employees are trained on Accolade’s privacy policies.

Prior to Accolade, Rich served as Executive Director of Corporate Legal and Compliance for Nomura Holding America (the North American division of the Global Japanese Wholesale and Investment Bank) and its subsidiary Instinet (an electronic trading firm). As part of his responsibilities, Rich led Nomura America’s and Instinet’s data protection and privacy compliance efforts. Before that, Rich was Special Counsel in the Manhattan law firm of Stroock & Stroock & Lavan LLP where he helped his clients close deals, litigate technology and IP disputes, and comply with various data protection regulations. Rich is a registered Patent Attorney and has filed hundreds of patent applications for his clients in various industries, including financial services.

Rich earned his JD from the Fordham University School of Law, and holds an Engineering degree from Manhattan College. He’s married with two daughters and enjoys playing and watching sports, helping his youngest daughter with her dance moves (you don’t want to see that), and going to the shore with his family.

Hite m@@@e y Jp Z C I6 oIn N lY 3 R p b 2 w4 td G 9 jL T IifQ = = @@@ we do things around here. At-Will Employment

Eite m@@@e y Jp mZ C I6 In N lY 3 R p b 2 4 td pG 9 jL T Iu MS J9 l@@@ oyment at Accolade is on an “at-will” basis, which means that an employee’s employment can be terminated by Accolade or the employee at any time and for any reason, with or without advance notice, except as prohibited by law. This at-will status cannot be changed by any verbal statement or agreement, but only by a legally binding, written contract governing employment status signed by the CEO. No other officer or employee has the authority to offer or promise anything different. Your offer letter is not an employment agreement, and does not change the "at-will" nature of your employment.

The policies and procedures contained in this Handbook are guidelines to employment with Accolade and do not create a contract of employment, express or implied, or otherwise create any contractual rights or obligations on behalf of the Company, or alter the “at-will” status of the Company’s employees. Open Door Policy

Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oIu MiJ9 @@@ lade has an “open door” policy under which employees are welcome to bring their concerns or complaints about anything related to their employment to management or People & Culture. Any work-related situation that an employee feels is affecting his or her performance, ability to perform the job, or the atmosphere of the work environment should be brought to the employee’s Leader. In many cases, problems can be corrected by direct communication between the individuals involved. If not, employees may pursue the matter further with a member of the People & Culture team, who is available to assist employees at any time. Remember, a problem cannot be resolved unless the Company is made aware of it.

Accolade also provides the opportunity to submit questions or complaints anonymously. If you see a violation of this Handbook, Accolade’s Code of Conduct, or of an applicable law, rule or regulation, and you believe that the matter requires investigation by Accolade’s Legal and Compliance team, you can report the matter via Accolade’s Compliance and Ethic’s Hotline, at http://accolade.ethicspoint.com or Telephone: 844-537-9525, which is hosted by a third party and allows anonymous reporting.

Employees are protected against retaliation for bringing complaints and/or participating in an investigation in good faith.

Resolving Differences

Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oIu My J9 @@@ ladians should strive to live our values at all times. This includes when you have challenges or issues with another colleague at Accolade. Be fearless and go talk with them!

Be sure to "walk a mile in their shoes" beforehand and, while you're talking through things, make sure you first get on the same page with the problem definition, before you start coming up with solutions.

Everyone can remind anyone in the company about these guidelines. If there is a disagreement about the interpretations, the discussion can be raised to other leaders within the Company without repercussions. If your issue is with your leader, talk to their Leader, or a member of People & Culture.

Equal Employment Opportunity and Policy Against Discrimination and Harassment

Equal Employment Opportunity Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oIu N C 4 x In 0 = l@@@ ade is committed to Equal Employment Opportunity and to compliance with all federal, state, and local laws that prohibit workplace discrimination and unlawful retaliation. Accordingly, it is Accolade’s policy to select, develop, promote, compensate, and retain employees based on their ability and job performance without discrimination on the basis of race, ancestry, color, age, national origin, ethnicity, religion, physical, mental, or sensory disability, marital or familial status, genetic information, military or veteran status, sex (including pregnancy, childbirth, breastfeeding, or related medical condition), gender (including gender identity and gender expression), sexual orientation, citizenship status, whether an individual is an actual or perceived victim of domestic violence, sexual assault, or stalking, or any other status or classification protected by applicable federal, state, and/or local laws. In addition to the protected categories identified above, Accolade prohibits discrimination on the basis of HIV/AIDS, on the use of a trained guide dog or service animal, and on the basis of political ideology.

Accolade will not tolerate discrimination or harassment based upon these characteristics or any other characteristics protected by applicable federal, state or local law.

This policy applies to all terms and conditions of employment, including, but not limited to, recruitment, hiring, placement, promotion, transfer, termination, layoff, leaves of absence, compensation, benefits, discipline, and training.

Policy Against Harassment and Discrimination Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oIu N C 4 y In 0 = l@@@ ade is committed to maintaining a work environment that is free from discrimination and unlawful harassment. To achieve these goals, we have established standards of conduct that are higher than required by federal, state and local laws. Specifically prohibited is any type of behavior involving physical, verbal or visual conduct by any employee which harasses, disrupts, or interferes with another’s work performance or which creates an intimidating, offensive or hostile work environment.

Harassment or intimidation includes, but is not limited to, actions, words, jokes or comments based upon an individual’s protected category as outlined above.

Sexual Harassment Sexual harassment is a form of unlawful harassment and is a violation of this policy. Prohibited harassment of a sexual nature includes any unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual or otherwise hostile nature if:

•Submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment; •Submission to or rejection of such conduct by an individual is used as the basis for employment decisions or benefits affecting such individual; or •Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive work environment.

Prohibited harassment may take different forms and may be based on any of the protected categories listed above. Examples include, but are not limited to, making derogatory comments based on any of the protected categories listed a above; joking or making fun of people because of their protected category; making suggestive remarks or insinuations based upon a person’s protected category; telling jokes or making remarks about sexual activities or preferences; making obscene gestures or displaying photographs or other depictions of sexual activity; making inappropriate comments about a person’s protected category in e-mails, text messages or on social media, displaying offensive symbols; and unwanted physical contact, including touching, brushing against other people, pinching, or blocking access to an exit. This list is not all inclusive, but represents examples of the types of conduct that are prohibited by this policy.

Employees should never assume any such conduct is welcome by another. For example, a joke that one employee may not find offensive may be offensive and unwelcome by another employee.

©2020 Accolade Inc. Page 15 of 52 Employee Handbook • Version 19 • Published 8/19/2019 All employees, visitors, and third parties doing business with the Company will be required to comply with this policy. Any employee who engages in conduct contrary to this policy will be subject to disciplinary action, up to and including termination.

Employees should promptly report any violations of this policy that they experience, witness, or of which they are otherwise made aware, to their Leader and/or any member of the People & Culture team. However, employees are not required to report violations to a Leader involved in the conduct and instead can report the matter to any member of the People & Culture team or another Leader. Leaders who witness or receive reports of harassing behavior are required to promptly report it to People & Culture.

Reports of harassment and discrimination will be handled in a timely and confidential manner to the greatest extent possible consistent with the Company’s obligation to perform a prompt and thorough investigation. Investigation of a complaint will normally include talking with the parties involved and any named or apparent witnesses. If it is determined that a violation of this policy has occurred, the Company will act promptly to eliminate the offending conduct, and where appropriate, impose disciplinary action, up to and including termination.

During investigations, we will work to protect confidentiality as much as possible. Employees will not be subject to any retaliation for making a good faith report of harassment or discrimination or for assisting in an investigation in good faith. Employees who knowingly make false accusations of discrimination or harassment may be subject to discipline, up to and including termination.

Reasonable Accommodations Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oIu N C 4 zIn 0 = @l@@ ade is committed to complying with the Americans with Disabilities Act (ADA), and applicable state law prohibiting discrimination in employment against qualified individuals with disabilities, including pregnancy-related disabilities. Accolade will provide a reasonable accommodation to a qualified individual with a known disability to enable that employee to perform the essential functions of his or her job, unless doing so would result in undue hardship to the Company. The interactive process of identifying a reasonable accommodation begins when an employee or applicant discloses a disability, provides documentation, and requests an accommodation. Volunteering information about a disability will not subject an employee or applicant to any adverse treatment or penalty. All information concerning disabilities will be treated as confidential and will be released only in accordance with the ADA and state law.

Accolade will make reasonable accommodations for the sincerely held religious beliefs of employees and applicants, unless undue hardship would result.

Accolade will make reasonable accommodations for an employee who is the victim of domestic violence, sexual assault, or stalking, unless undue hardship would result.

Individuals who feel they need an accommodation in order to apply for a position or to perform their work should contact People & Culture so that an interactive dialogue can begin on the subject of a proposed accommodation. Requests for a reasonable accommodation due to a protected disability (including a pregnancy-related disability) or a sincerely held religious belief will be evaluated on a case-by-case basis. No employee will be retaliated against for requesting reasonable accommodation.

What To Wear

Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oIu N S J9 @@@ lade has a relaxed but professional dress environment. Employees are expected to use good judgment and show courtesy to their colleagues by dressing in a fashion that is professional, presentable, and appropriate. Employees are to dress in appropriate business attire for meetings with customers or vendors at Accolade's offices or other locations.

Travel, Entertainment, and Expenses

©2020 Accolade Inc. Page 16 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Wite m@@@e y Jp Z C I6 In N lY 3 R ep b 2 4 td G 9 jL T Iu N iJ9 s@@@ hould each act like an owner of Accolade -- and spend our investors’ money as if it were our own. We will all benefit from this approach.

Employees will be reimbursed for reasonable expenses incurred in connection with approved travel on behalf of Accolade. All expenses for reimbursement must be submitted using Accolade's expense report system, Concur. Intentional violation, abuse or misuse of this policy could be grounds for discipline or termination.

You can find the full travel and expense policy here: Travel & Expense Policy

Office Life

Oite m@@@e y Jp Z C I6 In uN lY 3 R p b 2 4 rtd G 9 jL T Iu N y J9 o@@@ ffices are located at the addresses listed below. For more information about your location, please click here:

Plymouth Meeting 660 West Germantown Pike Suite 500 Plymouth Meeting, PA 19462

Scottsdale 8777 E. Hartford Drive Suite 200 Scottsdale, AZ 85255

Seattle One Convention Place 701 Pike Street, Suite 700 Seattle, WA 98101

Occasionally, Accolade has visitors in the office. The Company’s surroundings should always reflect a professional appearance. While encouraged to step away and take a break, employees may eat at their desks, but should do so unobtrusively and in a manner that prevents damage to valuable Company equipment and other property. All employees are personally responsible for keeping the area around their workstations clean and presentable. Employees are also responsible for returning meeting areas to a clean and presentable condition after use.

Visitors Bite m@@@e y Jp Z eC I6 In N lY 3 R p cb 2 4 td G 9 jL aT Iu N y 4 x In 0 u= @@@ se we work with confidential personal health information throughout our offices every day, only customers and authorized visitors are permitted at the Company’s offices. This means unauthorized salespersons or those collecting for charitable causes are prohibited from the office. Visits from friends and family should be kept to a minimum and should not disrupt our support of members or team members.

Employees are responsible for the conduct of their guests. If you are expecting a visitor, you must log them in Accolade's Access Manager before their visit. All visitors must enter through the reception area, sign the Secrecy Agreement, and receive a name badge. Any employee that notices an unauthorized visitor should notify his or her Leader and/or People & Culture immediately.

Visitor forms are available at the front desk in every Accolade office. Without appropriate authorization of Legal & Compliance or People & Culture, visitors may not be permitted access to Accolade’s premises if they refuse to sign the Visitor form. Visitor Forms also may be downloaded here.

©2020 Accolade Inc. Page 18 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Field Operations (Sales) personnel are advised to consider proactively sharing the Visitor form with individuals from customers, prospects and/or consultants that will be participating in site visits. Typically, such individuals may need to review the Visitor form with their legal counsel.

Postage, Shipping, and Office Supplies Pite m@@@e y Jp oZ C I6 In N lY 3 R sp b 2 4 td G 9 tjL T Iu N y a4 y In 0 = @@@ge and shipping services and office supplies paid for by the Company are for business purposes and are not to be used for an employee’s personal purposes.

Personal Property Tite m@@@e y Jp Z hC I6 In N lY 3 R p eb 2 4 td G 9 jL T Iu N y 4 CzIn 0 = @@@ ompany does not assume responsibility for any personal property located on its premises. Employees are to use their own discretion when choosing to bring personal property into the office and do so at their own risk. Additionally, employees may not bring or display in the office any property that would violate the Company’s Policy Prohibiting Discrimination & Harassment. Emergency Procedures and Weather

Eite m@@@e y Jp vZ C I6 In N lY 3 eR p b 2 4 td G 9 rjL T Iu O C yJ9 @@@ weather situation is different and each Accolade location will always do its best to make decisions about office closings due to inclement weather that support our members whenever possible while also recognizes the safety and effort of team Accolade. We recognize that there will be more accurate information available to us throughout the weather forecast update, so please check your e-mail or the Accolade Special Message Alert line at 267-515-5746 for final plans.

In the event of an office closing, an Accolade Safety Check may be activated and sent to you. All Accolade personnel are responsible for responding to the Safety Check even if the event is not in your area. Click here for more details.

If the Company is closed for business, non-exempt employees may use their available PTO or the time off will not be paid. Exempt employees will be paid unless the location is closed for a full workweek or longer.

All employees may use their available PTO for time taken off due to poor weather conditions when the Company is open for business. Otherwise, the time off is unpaid. If a non-exempt employee is late for work due to inclement weather conditions, the employee will be paid only for time worked. Exempt employees will be paid in full-day increments.

As a quick refresher, you can check your Accolade e-mail via the web at https://mail.accolade.com.

Communication

Mite m@@@e y Jp Z C I6 In N lY 3 uR p b 2 4 td G 9 cjL T Iu O S J9 @h@@ of the work we do daily involves collaborating with others -- sharing information, asking or answering questions, and offering feedback. Effectively communicating with peers not only helps us get our jobs done, but also helps to build relationships with our teammates which can make coming to work everyday fun and enjoyable! But with so many ways to communicate in our modern age, it can be really hard to decide what the best channel is. And in the workplace specifically, it can be even harder to make that decision. Take a peek at the tips we've called out below to help you work best with your teammates - great communication is at the core of being 'Powerful Together'!

•Understand your own style ○Here at Accolade each new team member gets to go through the True Colors course, which helps us better understand our self and others. Are you a story teller? Or a stick to the facts kind of person? Knowing your preferred style is super valuable when interacting with others. •Understand the other person's style ○Once you know how a person likes to receive information, it is your responsibility to tailor your communications that way. And it doesn't have to be difficult. Next time you have to talk to someone about something, ask them if they'd like to setup a meeting to discuss or if you should just send an email!

©2020 Accolade Inc. Page 19 of 52 Employee Handbook • Version 19 • Published 8/19/2019 •Use the right channels ○We have such an array of mediums to use - but don't just shoot off that email yet. There are some things that make sense to send over quickly in an instant message (i.e. slack or lync), others that an email makes more sense, and sometimes a good old fashion face-to-face conversation is necessary. Using the right approach makes all the difference in the world when it comes to how the other person will receive your message. •Assume positive intent ○Do you think your coworker came to work wondering how they could really irk you today? Doubt it! Put yourself in their shoes for a moment, and be empathetic. It could make all the difference in your communication and ultimately your relationship with them. •It still won't be perfect - but take a crack at fixing it ○ No matter how hard you try there will inevitably be times when things don't go as planned. Don't sit on it - let that person know that you value the relationship, and you want to talk things out. Establishing or rebuilding that trust and communication channel will lead to a more successful working relationship and, ultimately, a much happier working environment! •Do some groundwork ○How many of us have griped about getting a super simple question when the answer was already out there? See if you can look up information yourself before asking someone for help. Doing a little legwork, even if you don't end up with the answer you need, can go a long way in earning someone's respect. No one likes to spend time putting a document together, only for someone to ask a question that could have been answered just by doing a little digging on your own. Updating Personal Information

Wite m@@@e y Jp Z C I6 In N lY 3 R ep b 2 4 td G 9 jL T Iu MT nA ifQ = = @@@ eed to maintain up-to-date information about you so we can aid you and/or your family in matters of a personal emergency and to maintain current information for tax and benefits purposes. Changes in name, address, telephone number, marital status, number of dependents, or changes in next of kin and/or beneficiaries should be updated in Workday promptly.

Bite m@@@e y Jp Z eC I6 In N lY 3 R p ib 2 4 td nG 9 jL T MifQ = = g@@@ all that you can be. Performance Management

Pite m@@@e y Jp eZ C I6 In N lY 3 R rp b 2 4 td fG 9 jL T Mou MS J9 @@@ rmance management at Accolade takes place throughout the year and involves setting goals, receiving continuous feedback, evaluating your own performance/results, receiving peer & leader feedback, and finally being rewarded based on performance. This process is driven by our feedback culture and ensures we are continuously improving and aligned around the right things—taking care of our members and each other. Please check out the portal for more detailed information about our Performance Enablement Process. Performance Support

Tite m@@@e y Jp Z hC I6 In N lY 3 R p eb 2 4 td G 9 jL T Mu MiJ9 f@@@ ollowing outlines Accolade's Performance Support Process. This process is designed to provide feedback and coaching to aid employees' growth in addressing performance issues. Additionally, this process is in place to address any ethical or professional concerns as well as violations of Accolade's policies.

The following outlines Accolade's Performance Support Process. This process is designed to provide feedback and coaching to aid employees' growth in addressing performance issues. Additionally, this process is in place to address any ethical or professional concerns as well as violations of Accolade's policies.

Accolade expects that all employees will conduct themselves in a professional and ethical manner. An employee should not conduct business that is unethical in any way, nor should an employee attempt to influence other employees to act unethically. In the event that an employee becomes aware of another employee’s behavior or action that he or she believes is unethical, inappropriate, illegal, in violation of Accolade’s policies, or in any way inhibiting or affecting the employee’s job performance or the Company’s work environment, the employee should discuss such behavior or actions with his or her leader and/or member of the People & Culture team. All reasonable concerns will be promptly, thoroughly and confidentially investigated by the Company, and, where warranted, appropriate action will be taken.

Typically, Accolade uses a progressive support process that may contain any of the following steps:

•Step 1. Written Reminder 1 •Step 2. Written Reminder 2 •Step 3. Final Reminder, Termination and/or Separation Agreement

This support process is designed to provide feedback and coaching to aid employee’s growth in addressing performance issues. Accolade may begin the support process sequence at any step or may bypass steps, including proceeding directly to employment termination, in at Accolade's sole discretion, depending upon the nature and severity of the offense or performance issue and/or the employee's past history of performance issues.

The non-exhaustive list below includes the types of unacceptable behavior that may result in disciplinary action, up to and including termination:

1.Insubordination, including refusal to follow lawful instructions, rules, or direction from a leader (such as refusing to perform jobs other than those the employee typically performs). 2.Behaviors not aligned with Company's Cultural Cornerstones. 3.Violation of Company’s policy prohibiting substance use. 4.Theft of Company’s property or the property of other employees; possessing Company property or the property of other Company employees without permission. 5.Damaging the Company’s property or the property of other employees. 6.Falsifying or altering Company records, including employment records, time records, or job applications.

©2020 Accolade Inc. Page 21 of 52 Employee Handbook • Version 19 • Published 8/19/2019 7.Possession of weapons on the Company’s property, except when and to the extent permitted by applicable federal, state, and local laws. 8.Violation of the Company’s Attendance Guidelines. 9.Violation of the Company’s Equal Employment Opportunity policy and the Company’s policy prohibiting discrimination & harassment. 10.Failure to immediately report job‑related injuries or accidents. 11.Poor job performance. 12.Failing to cooperate or give accurate information in a Company investigation. 13.Unauthorized use of the Company’s equipment or materials. 14.Violation of the No Solicitation/No Distribution policy. 15.Violation of any other policy in this Employee Handbook.

Transfers and Promotions

Iite m@@f@e y Jp Z C I6 In N ylY 3 R p b 2 4 td oG 9 jL T Mu My uJ9 @@@ are interested in applying for a promotion or transferring to another role or department within Accolade, you should discuss it with your Leader.

A promotion typically involves an advancement in career level, which reflects a meaningful change in the individual’s level of accountability, scope, complexity, influence and impact of their role; all which require a higher level skill set to be successful.

A transfer typically involves movement within a career level to a new role, which reflects expanded or changed responsibilities, and a similar level of accountability, scope, complexity, influence and impact of their role; all which typically require a similar level of skill to be successful.

Although we favor promotions from within, we reserve the right to recruit, interview and hire from outside of the Company to obtain the best qualified candidate, in Accolade's sole discretion.

To be considered for a transfer or promotion, an employee must typically be employed in his or her current role for a minimum of 12 months, have a performance rating of ‘Valued’ or ‘Exceptional,’ and be qualified for the new position based upon the role description.

Employee Referrals

Kite m@@@e y Jp Z C I6 In N lY 3 R p b o2 4 td G 9 jL T Mwu N C J9 @@@ someone who would be awesome for a role at Accolade? We'd love to have them in the pipeline. Please remember that we hire based on our needs and merit, so if your referral doesn't get hired for a specific role, encourage them to keep trying!

Submit all of your referrals to the Talent Acquisition team.

Accolade discourages the hiring of relatives of current employees into positions in which one employee would supervise or be supervised by another family member. Relatives may be hired by the company if (1) the persons concerned will not work in a direct supervisory relationship, and (2) the employment will not pose difficulties for supervision, security, safety or morale. We also try to avoid placing relatives in positions in which they work with or have access to sensitive information about other family members. The same general considerations apply if two employees marry, become involved in a domestic-partner relationship or are involved in a romantic relationship while working at Accolade.

Employees are required to disclose a family relationship to People & Culture. If employees who marry or live together work in a supervisory relationship with one another, the company will attempt to reassign one of the employees to another position for which he or she is qualified, if such a position is available. If no such position is available, then one of the employees may be required to leave the company.

For the purposes of this policy, relatives are defined as spouses or domestic partners, children, siblings, parents or in-laws.

Bite m@@@e y Jp Z eC I6 In N lY 3 R p cb 2 4 td G 9 jL aT Q ifQ = = @@@use work isn't 24/7. Work/Life Balance

Iite m@@n@e y Jp Z C I6 In N lY 3 R pb 2 4 td G 9 jL rT Q u MS aJ9 @@@ ctice, our current team works core hours of 8 am-8 pm ET, with some starting earlier and some ending later.

At Accolade, attendance means you are serving our members when expected. Being at work on time and when scheduled gives our members the best possible experience and minimizes the times when your colleagues need to cover for you. Regardless of your role, we hired you because what you do matters. It matters to our members and it matters to the rest of us, so we need you working when expected and as much as expected. For more details, please review the guidelines here.

Any employee who fails to report to work for a period of three consecutive days or more without notifying his or her leader will be considered to have abandoned the job and voluntarily terminated the employment relationship.

Absences may be excused for reasons of vacation, personal illness, jury duty, or other reasons at the discretion of Accolade or pursuant to Accolade's leave policies. Accolade may request validation of the reason for the absence. Employment Status

Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oQ u MiJ9 @@@ lade maintains standard definitions of employment.

Employees are classified as either full-time or part-time.

Full‑time: Employees who are regularly scheduled to work 30 or more hours per week. Full-time employees are eligible for benefits.

Part‑time: Employees who are regularly scheduled to work at least 5 but fewer than 30 hours per week. Part-time employees are not eligible for most benefits.

Temporary/Contractors/Interns: Regularly scheduled workers whose work has a predetermined starting and ending date of employment. These workers are not eligible for benefits.

Additionally, employees are classified as either exempt or non-exempt in accordance with federal and state law based on factors such as their compensation, the nature of their work, and their duties and responsibilities. Accolade will tell you whether you are classified as exempt or non-exempt.

1.Exempt: are not eligible for overtime pay. Instead, the salary paid to exempt employees is intended to compensate them for all hours worked in a workweek. 2.Non‑Exempt: are eligible for overtime pay for hours worked in excess of 40 in a workweek, in accordance with federal and state law.

Employees with questions about their classification should consult their Leader and/or People & Culture.

Recording Time Worked (for non-exempt employees):

Accolade keeps accurate records of, and compensates employees for, all hours worked, as required by federal and state law. Keeping accurate records of employees’ working hours is crucial for Accolade to:

•Ensure employees are paid for all hours worked; •Comply with applicable federal and state laws; •Accurately track employees’ accrued leave balances and other benefit accounts; and

Accordingly, all non-exempt employees are responsible for making a daily record of their hours worked and ensuring such information is accurately submitted in Workday. Employees who have a concern that they have not been paid correctly for all time worked, or are not certain that their pay is correct, should immediately contact their Leader and/or People & Culture. Under no circumstances may an employee record time worked by another employee or falsify his or her own time sheet information. If it is determined that someone knowingly/intentionally reported time worked or submitted a time sheet inaccurately or on behalf of someone else, that is a serious breach of trust— and may be reason for disciplinary action up to and including termination.

Overtime Nite m@@@e y Jp Z C I6 oIn N lY 3 R p b 2 n4 td G 9 jL T Q u -Mi4 x In 0 = e@@@ xempt employees are compensated with overtime pay by Accolade in accordance with applicable law, typically on the basis of a 40-hour workweek. Except where applicable law provides for a different calculation of overtime hours, hours worked in excess of 40 hours during the weekly pay period shall be considered overtime hours. Compensation for overtime hours is paid at the rate of 1 and ½ times the employee’s hourly rate. The hourly rate is determined by dividing the employee’s weekly wage by 40 hours. Accolade does not provide compensatory time (“comp time”) off in lieu of overtime pay. In many cases, the employee’s Leader must approve overtime in advance. If an employee is unsure, it's recommended they connect with their Leader to confirm expectations prior to working overtime. Employees who fail to follow appropriate business processes will be subject to discipline, up to and including termination. Off-The-Clock Work Nite m@@@e y Jp Z C I6 oIn N lY 3 R p b 2 n4 td G 9 jL T Q u -Mi4 y In 0 = e@@@ xempt employees may not perform work off-the-clock. Leaders are not authorized to ask or permit a non-exempt employee to work off-the-clock. Any non-exempt employee who is asked to perform work off-the-clock should immediately contact People & Culture. Working Hours Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oQ u Mi4 zIn 0 = @l@@ ade's standard operating days are Monday through Friday. Exempt employees may need to work additional time to accommodate certain deadlines, and are expected to work with their Leaders to best manage their time. Questions about your work schedule should be directed to your Leader. Lactation Breaks

Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oQ u My J9 @@@lade supports and encourages the practice of breastfeeding and the expression of breast milk by employees who are breastfeeding when they return to work. Additionally, it is Accolade's policy to prohibit discrimination and harassment of breastfeeding employees who exercise their rights under this Policy.

Upon return to work after the birth of a child, breastfeeding employees shall be allowed a reasonable period of time to express milk during work hours. The employee should speak with her Leader to arrange for appropriate and reasonable break times or flexible scheduling for expressing milk.

Mother's rooms are available for this purpose. Employees are not expected to use the restroom for expressing milk.

Accolade has designated a separate area in a refrigerator at each location for the storage of breast milk. Any breast milk stored in the refrigerator must be labeled with the name of the employee and date. Any nonconforming products stored in the refrigerator may be disposed of. Employees storing breast milk in the refrigerator assume all responsibility for the safety of the milk and the risk of harm for any reason, including improper storage, refrigeration and tampering.

Paid Time Off

ite m@@@e y Jp Z C I6 In N lY 3 R p b 2 4 td G 9 jL T Q u N C J9 @@@

©2020 Accolade Inc. Page 24 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Given the demands of our members and customers, our personal lives, and the high standards we set for ourselves, it is important that we each take some time off to relax and recharge. Take a look here to understand our Taking Time Off practices.

Accolade offers our employees Paid Time Off, which is an allotment of sick days, vacation days, and personal days that employees can use as the need or desire arises. Given that all of these types of days off are to improve our personal well- being, we feel this approach is both the simplest and the fairest. The PTO policy is intended to comply with all applicable state and local Earned Sick Leave Laws and runs concurrently with earned sick leave.

Accolade has a detailed process for requesting and scheduling time off. If you are unclear of any of the guidelines or have a question on what to do, please reach out to your Leader first. If you are still unclear or questions remain, please reach out to People & Culture. Accolade will try to grant PTO for the time an employee requests. However, PTO cannot interfere with the operations of the business and therefore must be approved by an employee's Leader.

In order for time to be authorized, an employee must notify his or her Leader as soon as the employee is aware of the dates to be scheduled, with as much notice as possible. To request time off, employees must submit a request in Workday (or the Workforce Management System for AHAs) to be approved by their Leader. Notice may be waived on a case‑by‑case basis if merited in emergencies.

Upon separation of employment for any reason, an employee will be paid out their accrued and unused PTO in a final paycheck. As a new Accolade employee, you will sign the "Accolade Paid Time Off Repayment Agreement" indicating your agreement to repay any negative PTO balances and permit Accolade to deduct any such negative PTO balance amounts through payroll deductions, including from your final paycheck if you leave employment with Accolade. Time Off to Vote

Eite m@@@e y Jp mZ C I6 In N lY 3 R p b 2 4 td pG 9 jL T Q u N S lJ9 @@@oyees who are not able to vote on recognized election days because of their work schedule will be permitted up to three hours of paid time off to vote. Employees must inform their supervisor of the need for time off as soon as possible but in no event later than three workdays before Election Day.

Employees may be required to vote at the beginning or end of their shift, and to provide a voter's receipt before being paid.

Holidays

Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oQ u N iJ9 @@@ lade celebrates these holidays as official days off:

•New Year's Day •Memorial Day •Independence Day •Labor Day •Thanksgiving Day •Day after Thanksgiving •Christmas Day

If you're taking any additional days off around these holidays, be a good team member and proactively share those dates with the team prior to your time off. Don't forget to enter your PTO requests in Workday, or in the Workforce Management System if you are an Accolade Health Assistant.

Day of Service

ite m@@@e y Jp Z C I6 In N lY 3 R p b 2 4 td G 9 jL T Q u N i4 x In 0 = @@@

©2020 Accolade Inc. Page 25 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Martin Luther King Jr. Day is reserved as a day of service. It is not a day-off and employees are expected to report to work or participate in at least one of the available volunteer activities. Please refer to Accolade’s Philanthropy page on The Beat for more information.

Floating Holidays (pro-rated based on hire date) Tite m@@@e y Jp Z hC I6 In N lY 3 R p rb 2 4 td G e9 jL T Q u N i4 y eIn 0 = @@@ days (24 hours) of Floating Holiday Time is available for employees who desire to observe a religious holiday that is not recognized by the Company. Some people think the day they were born should be a holiday- they can use their Floating Holiday Time for that as well (or for any other personal reason)! Part-time employees are eligible for a pro-rated number of Floating Holiday time. Please note that employees are entitled to a total of 24 hours of Floating Holidays, regardless whether the employee regularly works an eight-hour or ten-hour day.

Some things to consider regarding Holidays & Floating Holidays: •Should a holiday fall on a weekend, the holiday will be observed on the work day closest to the holiday. •If your schedule is less than a five day work week, work the days you are scheduled. If your standard work schedule falls on a Company holiday, please don't report to work as we'll be closed. •If your schedule is less than a five day work week, you are paid your usual pay whether or not the holiday falls on one of your scheduled days or not. •Floating Holidays may be used in 1 hour increments for non-exempt employees. Salaried employees may use Floating Holidays in full or 1/2 day increments. Floating Holidays must be used during the calendar year and cannot be carried over. They can be used to provide salary reimbursement in connection with FMLA, Short-Term Disability, and Military Leave. •Upon termination, Holidays and Floating Holidays will not be paid out. Employees may not take a Floating Holiday during a resignation period. Additionally, Floating Holidays may not be used to extend an employee's termination date.

For additional information, please refer to the Holiday Schedule on The Beat. Leaves of Absences

Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oQ u N y J9 @@@lade recognizes that sometimes an employee may need to take a leave of absence from work. The following provides an overview of Accolade's various leave policies. Family and Medical Leave Iite m@@n@e y Jp Z C I6 In N lY 3 R ap b 2 4 td G 9 jL cT Q u N y 4 x cIn 0 = @@@ ordance with the Family and Medical Leave Act, Employees are eligible to take up to 12 weeks of unpaid family/medical leave within any 12-month period and be restored to the same or an equivalent position upon the employee’s return from leave. To be eligible for FMLA leave, you must have worked for Accolade for at least 12 months, and for at least 1,250 hours in the 12 months preceding the commencement of the requested leave.

The 12-month period in which the employee may take 12 weeks of leave will be calculated as a rolling 12 months measured backward from the beginning of leave. For example, if the employee has taken eight weeks of leave during the 12 months preceding the beginning of leave, the employee is entitled to four remaining weeks of leave.

Eligible employees may take FMLA leave for one or more of the following reasons: 1.For the birth of a child, and to care for the newborn child. 2.For a serious health condition that makes the employee unable to perform any one or more of the essential functions of his or her job. 3.For the placement with the employee of a child for adoption or foster care, and to care for the newly placed child. 4.To care for an immediate family member (child, spouse, domestic partner or parent with a serious health condition). 5.For a “qualifying exigency” relating to the active-duty status or call to active-duty in the armed forces of an employee’s spouse/domestic partner, child or parent. A qualifying exigency occurs when an employee requests FMLA leave related to the active-duty status or call to active duty in the armed forces of the employee’s spouse/domestic partner, son, daughter or parent.

©2020 Accolade Inc. Page 26 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Qualifying exigencies may include, but are not limited to, attending certain military events, arranging for alternative childcare, addressing certain financial and legal arrangements, attending certain counseling sessions, and attending post- deployment reintegration briefings.

Eligible employees may take up to 26 workweeks of leave during a single 12- month period in connection with military caregiver leave to care for a covered service member with a serious injury or illness, when the employee is the spouse/domestic partner, son, daughter, parent or next of kin of the service member.

A “serious health condition” means an illness, injury, impairment, or physical or mental condition that involves a period of incapacity due to one of the following:

1.Any in-patient care in a hospital, hospice, or medical care facility. 2.A period of incapacity of more than three consecutive calendar days that involves “continuing treatment”. 3.Pregnancy or prenatal care, regardless of the period of incapacity. 4.Chronic conditions, which require periodic visits for treatment over an extended period of time and that may have individual episodes of incapacity of less than three days. 5.Conditions that are not normally incapacitating, but that require multiple treatments, such as chemotherapy, radiation, dialysis, physical therapy, and restorative surgery. 6.Conditions involving a period of incapacity that is permanent or long term (not necessarily incurable) and for which treatment may not be effective.

Procedure for Applying for FMLA leave:

Employees seeking to use FMLA leave must contact the Benefits Team before contacting Aetna at 1-866-326-1379 or online www.aetnadisability.com to apply for a leave. The employee will need to provide their anticipated time and duration of the leave.

Employees requesting a leave should provide at least 30 days’ notice in advance if the need for leave is foreseeable and such notice is practicable. In cases where the need for FMLA leave is not foreseeable, employees should contact the Benefits team and Aetna as soon as possible (preferably, at least 24 hours in advance).

Employees must report each and every FMLA absence to both Accolade and Aetna no later than 5 days after the absence. For AHAs, time should be reported through Workforce Management. All other employees should report the time to the Benefits Team. Should an employee not report an absence to Aetna in a timely manner, then those absences may be denied as not protected by the FMLA, which can result in disciplinary action, up to and including termination.

Employees requesting leave for their own serious health condition must timely submit a Medical Certification Form, completed by their physician. The form will be provided by Aetna. Failure to submit a completed Medical Certification Form in a timely manner may result in the delay or denial of leave.

Employees may be required to provide re-certification of the need for leave from time to time upon request.

Second Opinions: The Company may request and pay for a second outside medical opinion at the Company’s expense if the Company has reason to doubt the validity of the initial certification. If the opinions conflict, the Company may pay for a third opinion selected jointly with the employee; this opinion will be binding on both the Company and the employee.

Employees who request to go on FMLA leave to care for a family member may be required to submit a Family Member Medical Certification Form prior to leave. Aetna also reserves the right to require an employee requesting FMLA to provide confirmation of the family relationship through documentation, such as a birth certificate, a court document, a marriage certificate, etc.

In cases where a husband and wife are both employed by Accolade and both are eligible for FMLA leave, they each will be eligible to receive 12 weeks of FMLA, not to extend past 12 months from the birth or adoption of their child.

©2020 Accolade Inc. Page 27 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Intermittent/Reduced Schedule Leave: If medically necessary, FMLA leave may be taken on an intermittent or reduced schedule basis to care for an employee’s own serious health condition, the serious health condition of a family member, or for qualifying exigencies. If you take FMLA leave intermittently or on a reduced schedule, you may be required to temporarily transfer to an alternative position during the leave period that better accommodates your leave (with equivalent pay and benefits). In cases of intermittent or reduced schedule leave, the employee is expected to make every effort to schedule treatment of him or herself or the family member so as not to unduly disrupt departmental operations. Except for emergencies, employees must notify Aetna at least two weeks in advance of medical appointments and treatments.

Employees on an approved FMLA have the option to utilize PTO or take the FMLA leave as unpaid leave.

Health Benefits: During FMLA leave, the employee will remain on Accolade’s group health plan under the same terms and conditions that would apply if the employee was an active employee. If an employee is receiving payments during leave in the form of PTO or short-term disability benefits, the employee’s share of the premiums will be deducted from the employee’s paycheck. An employee on unpaid leave must make arrangements to pay his or her share of the premiums by completing a Repayment Agreement.

Employees who are enrolled in a flexible spending account will continue to have access to use the account; however, premiums will stop while an employee is no longer receiving an active paycheck. Upon return from leave, the employee’s normal biweekly contribution amount will be adjusted to ensure it meets the annual election amount originally elected for the plan year.

Return To Work: Upon return from FMLA leave, the employee will be reinstated to the same or equivalent position. For employees on a continuous FMLA leave for their own serious health condition, the employee must provide a completed Return to Work Note from their provider to the Accolade Benefit’s Team no later than two business days prior to their expected return to work date. Employees will need to fax it to 267-765-0812 or email it to the Benefits Team . Employees will also be responsible to contact Aetna’s assigned Case Manager to inform them they are released by their physician to return back to work. Failure to provide a Return to Work Note to Accolade may result in a denial of job reinstatement until proof of medical release is provided.

Employees on FMLA to care for a family member must contact their Claim Manager at Aetna at least two days prior to their anticipated return to work date.

Failure to return to work once FMLA has been exhausted may result in termination of employment, unless the employee is eligible for another form of leave, including leave as a reasonable accommodation under the ADA.

Operational and staffing changes may result in layoffs or position eliminations for certain employees, including those who may be on FMLA leave. In that situation, the employee’s employment may be terminated.

Under limited circumstances, certain key employees may not be reinstated at the end of their leave. An employee will be notified at the commencement of leave if they are considered a “key” employee and will be given an opportunity to return to work.

Employee Rights: The Company will not interfere with, restrain or deny the exercise of any right provided by the FMLA or discharge or discriminate against any person for opposing any practice made unlawful by the FMLA or for involvement in any proceeding under or relating to the FMLA.

Certain state laws provide for types of family and medical leave, which may or may not run concurrently with FMLA, depending on your particular situation. Check with the Benefits Team for more information. Short-Term and Long-Term Disability Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oQ u N y 4 y In 0 l= @@@ade recognizes there will be times when circumstances may require an employee’s extended absence from work due to his or her own illness or serious health condition. Short-term disability (STD) and Long-term disability (LTD) benefits are provided to eligible employees who work at least 30 hours and are unable to work because of a qualifying disability

©2020 Accolade Inc. Page 28 of 52 Employee Handbook • Version 19 • Published 8/19/2019 resulting from an injury or illness (non-work related). Throughout the leave, employees must provide all requested documentation to Aetna within the required time frame to avoid risk of denial. If the leave is denied, the employee must return to work immediately. Failure to provide documentation or return to work (if denied) may result in termination.

To apply for a short and/or long-term disability, employees must first contact the Benefits Team and then contact Aetna at 1- 866-326-1379.

Maternity and Parental Bonding Leave Gite m@@@e y Jp Z C I6 rIn N lY 3 R op b 2 4 td G 9 jL wT Q u N y 4 zIn 0 = @@@ing your family is a big, exciting, and somewhat overwhelming journey. At Accolade, we believe in providing new parents ample time to get to know the new addition(s) to their family and properly adjust to the changes a new child will bring to their lives. Below is an overview of our maternity and parental bonding leave benefits.

For parents giving birth: Accolade will provide up to nine weeks of maternity leave paid at 100% (split between payments from Aetna and Accolade) of the employee’s salary. At the end of the employee’s maternity leave, Accolade will provide up to an additional nine weeks of paid leave (paid at 100% of the employee’s salary) for bonding leave. Bonding leave may be used intermittently throughout the first year of the child’s life. In addition, the employee may take up to four weeks to transition back to work through a part-time schedule. During the phase-back period, the employee must work 80 hours over the 4 week period.

For partners of parents giving birth: Accolade will provide up to nine weeks of paid leave (paid at 100% of the employee’s salary) for bonding leave. Bonding leave may be used intermittently throughout the first year of the child’s life.

For parents adopting a child: Accolade will provide up to nine weeks of paid leave (paid at 100% of the employee’s salary) for bonding leave. Bonding leave may be used intermittently throughout the first year of the child’s life. In addition, the employee may take up to four weeks to transition back to work through a part-time schedule.

All new parents are encouraged to take advantage of the extensive support system provided by ComPsych, our Employee Assistance Program, which includes free and confidential counseling sessions and many support resources for each stage of your growing family.

Every case will be handled on a case by case basis in accordance with state law. Please see People and Culture if you have any questions.

Military Leave Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oQ u N y 4 0 In 0 l= @@@ade respects and appreciates service men and women who volunteer their time to serve our country. We will observe and comply with all applicable state and federal laws and regulations relating to military service and leave. Fifteen (15) days of paid leave is available per deployment.

To qualify, you must immediately notify your Leader and the Benefits Team in writing of your intent to take leave after receiving official notice of the impending call or order to active duty to allow the Company time to prepare for the employee’s absence. Once received, you must provide a copy of your orders to the Benefits Team. You may use any of your accrued paid time off to which you are entitled, or you may take the leave as unpaid time off.

Employees should speak with the Benefits Team if they have any questions concerning specific application of laws and regulations or questions concerning their obligations. With certain exceptions and limitations, employees are eligible, upon completion of military service, to re-employment with Accolade and to certain benefits while on leave, in accordance with applicable state and federal laws. Upon the completion of military service, employee must notify the Benefits Team of the intent to return to a position within the Company.

Jury Duty

ite m@@@e y Jp Z C I6 In N lY 3 R p b 2 4 td G 9 jL T Q u N y 4 1In 0 = @@@

©2020 Accolade Inc. Page 29 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Employees summoned for Jury Duty will be permitted the necessary time off from work to perform this civic responsibility and are not required to use PTO. Employees should enter the time request through their normal process for requesting time off, and provide a copy of the summons to their Leader and the Benefits Team. Effective January 1, 2018, Accolade will offset employee’s pay with any compensation received from Jury Duty. Employees will be required to provide a copy of the checks they receive for Jury Duty to the Benefits Team. Payroll will reduce the amount of the Jury Duty pay from the next paycheck.

Employees are expected to report back to work on a daily basis if relieved from duty or excused by the court before the end of the employee’s regularly scheduled workday.

Some states have specific jury duty leave requirements. Accolade will honor all state specific requirements.

Bereavement Leave Bite m@@@e y Jp Z eC I6 In N lY 3 R p rb 2 4 td G e9 jL T Q u N y 4 a2 In 0 = @@@ vement leave is a benefit provided to employees who experience a loss of a family member or someone with whom they had a close relationship. For immediate family members, Accolade provides full-time employees up-to five days off with pay (bereavement pay). Employee’s working less than 40 hours are provided pro-rated bereavement pay according to their standard work hours.

In terms of bereavement, immediate family is defined as an employee’s spouse, domestic partner, parents, stepparents, siblings, children, stepchildren, grandparents, parents-in-law, brothers-in-law, sisters-in-law, sons-in-law, daughters-in-law, and/or grandchildren.

For non-immediate family members and close relationships, Leaders have the discretion to provide up to one day of bereavement pay for full-time employees. For employees working less than 40 hours, bereavement pay will be pro-rated according to their standard work hours.

To request time off for bereavement, talk with your Leader/Steward. Accolade Health Assistants will need to coordinate with the Workforce Management team so they can update the Workforce Management System accordingly.

Crime Victim Leave Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oQ u N y 4 3 In 0 l= @@@ade will provide unpaid time off to an employee who is the victim of a crime so that the victim can attend the criminal proceedings. This includes the defendant's initial appearance, post arrest release, plea negotiations to be presented to the court, sentencing, probation revocation, or termination, criminal post-conviction release and any hearing, argument, or other matter scheduled by and held before a trial court at which the defendant also has the right to be present. It also includes proceedings set to reexamine and protect the victim's rights.

An employee who was not the victim of the crime may take leave under this policy only if the victim was killed or incapacitated and the employee is the victim's spouse, parent, child, grandparent, sibling, or personal representative (or is otherwise related to the victim as provided by law), so long as the employee is not the accused.

The employee must provide Accolade with advance notice and provide proper documentation related to the crime, and if applicable, a copy of the notice of each scheduled proceeding. An employee may also take unpaid time off from work to obtain or attempt to obtain an order or an injunction against harassment or any other injunction relief to ensure the health and safety or welfare of the victim or the victim's child. Accolade may limit the amount of leave provided to an employee if the leave creates an undue hardship to Accolade. The employee may elect to use his or her accrued vacation or personal/sick time. Accolade shall keep records regarding the employee's crime victim leave confidential.

Such leave will be administered in compliance with applicable state and federal laws, including but not limited to Washington State Law RCW 49.76.

Leave for Victims of Domestic Violence, Sexual Assault, or Stalking

©2020 Accolade Inc. Page 30 of 52 Employee Handbook • Version 19 • Published 8/19/2019 To the extent required by law, employees who are victims of domestic violence, sexual assault, or stalking, or who are family members of a victim (including child, spouse, domestic partner, parent, parent-in-law, grandparent, or person with whom the employee is in a dating relationship) may receive unpaid time off from work for the following purposes:

•Seek legal or law enforcement assistance or remedies to ensure the health and safety of you or your family members; •Seek treatment by a health care provider for physical or mental injuries caused by domestic violence, sexual assault, or stalking; •Attend to health care treatment for a victim who is your family member; •Obtain, or assist a family member in obtaining, services from a domestic violence shelter, rape crisis center, or other social services program for relief from domestic violence, sexual assault, or stalking; •Obtain, or assist a family member in obtaining, mental health counseling related to an incident of domestic violence, sexual assault, or stalking, in which you or your family member was a victim of domestic violence, sexual assault, or stalking; or •Participate in safety planning, temporarily or permanently relocate, or take other actions to increase your safety or the safety of your family members from future domestic violence, sexual assault, or stalking.

When possible, you must give Accolade notice of your intention to take leave for these purposes at least 30 days in advance. When advance notice cannot be given because of an emergency or unforeseen circumstance due to domestic violence, sexual assault, or stalking, you or someone on your behalf must give notice to Accolade no later than the end of the first day that you take leave.

Accolade reserves the right to require verification that you or your family member is a victim of domestic violence, sexual assault, or stalking, and that the leave taken was for one of the purposes described above. Verification may be provided by written statement confirming these facts, or by other appropriate documentation, and must be provided in a timely manner. You will not be required to provide additional information beyond this required verification, or information that would compromise the safety of you or your family member. Except as otherwise required or permitted by law, Accolade will maintain the confidentiality of all information you provide regarding this leave, including the fact that you are or your family member is a victim or that you have requested leave for these purposes.

When taking leave under this policy, an employee may choose to use any available paid time off. Otherwise, leave will be unpaid. Leave may be taken intermittently, on a reduced work schedule, or in a single block of time, as the circumstances warrant. The leave must be reasonable in duration, which will be determined by management and the affected employee, based upon the circumstances.

Upon return from leave under this policy, an employee will be reinstated to the position held prior to taking leave or to an equivalent position with equivalent employment benefits, pay, and other terms and conditions of employment, subject to certain exceptions as provided under Washington law.

Such leave will be administered in compliance with applicable state and federal laws, including but not limited to Washington State Law RCW 49.76.

Leave for Emergency Services Personnel Tite m@@@e y oJp Z C I6 In N lY 3 R p b 2 4 td G 9 jL hT Q u N y 4 4 In e0 = @@@ extent required by law, Accolade provides leave to qualifying volunteer firefighters, EMTs, reserve peace officers responding to, working at, or returning from a fire alarm or emergency call, or members of the Civil Air Patrol involved in an emergency service operation. To be eligible for such leave, an employee's presence must be requested by the on-scene commander.

Leave under this section is unpaid. However, you may choose to use accrued, but unused paid time off during this time off. Remember, you should notify your Leader as far in advance as possible and please keep in mind that Accolade may request a copy of your certification from the Civil Air Patrol or other verification that you were called to duty to serve. If the requisite

©2020 Accolade Inc. Page 31 of 52 Employee Handbook • Version 19 • Published 8/19/2019 certification is requested by Accolade but the employee does not provide it, the leave may be denied. If proper certification is provided, no action will be taken against any employee in any manner for requesting or taking any time off as provided for under this policy.

Personal Leaves of Absence Uite m@@@e y Jp Z C I6 nI N lY 3 R p b 2 p4 td G 9 jL T Q u aN y 4 5 In 0 = @i@@ d leaves of absence are considered individually and are granted at the sole discretion of Accolade management. The reason for the request, the employee’s length of service, the employee’s performance, and the demands of the employee’s job are examples of the type of factors typically considered in evaluating a request for personal leave of absence. An employee must have used all Paid Time Off prior to going on an unpaid personal leave of absence. Employees will be required to pay their entire cost of benefits during any unpaid personal leave of absence.

Site m@@@e y Jp hZ C I6 In N lY 3 R op b 2 4 td G 9 jL wT U ifQ = = @@@ me the money! Total Rewards

Tite m@@@e y oJp Z C I6 In N lY 3 tR p b 2 4 atd G 9 jL T U u MlS J9 @@ @ Rewards represent the value of working at Accolade. It's the benefits and compensation, enriched by career development and overall experiences that help our team members get the most out of working here. We continue to cultivate an engaged and empowered workforce, and together, we are committed to making Accolade the best place to work in the world. Take a look at some of our medical, dental and vision benefits, plus a variety of voluntary benefits.

Accolade provides eligible employees with a comprehensive health and welfare benefits package. For more details about your benefits, including eligibility, covered expenses, exclusions, and limitations, please refer to the plan documents or the Summary Plan Descriptions for each plan that are available from People & Culture. If any discrepancy exists between this Handbook and the official plan documents, the official plan documents control. Accolade reserves the right to modify or cancel its benefits plans in its sole discretion. 401(k) Plan

Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oU u MiJ9 @@@ lade employees can participate in our 401(k) program. Beginning the first quarter after completing your first year of service, we will match 100% up to 3% of your base salary. Pay

Eite m@@@e y Jp mZ C I6 In N lY 3 R p b 2 4 td pG 9 jL T U u My lJ9 @@@oyees are paid bi-weekly, and we encourage employees to use direct deposit. Employees will be paid on Friday for the previous two weeks of work.

To enroll in direct deposit, please login to Workday and complete the required electronic forms.

All paychecks are required by law to reflect deductions for federal income taxes, state income taxes, and Social Security and Medicare taxes. The amount of these deductions will depend on an employee’s earnings and the information furnished by the employee on W-4 forms regarding the number of allowances claimed. An employee’s paycheck also may reflect certain court-ordered deductions that Accolade is required to honor, such as child support payments or garnishments for payment to creditors. Accolade will give an employee written notification of any orders for these types of deductions received by Accolade. An employee’s paycheck may also reflect other deductions authorized by the employee. All deductions will be listed for the employee’s information. Error in Pay Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oU u My 4 x In 0 l= @@@ade intends to comply with all applicable wage and hour laws, including the Fair Labor Standards Act and applicable state and local law. Non-exempt employees are paid for all hours worked, and improper deductions may not be made from the pay of any employee. Employees are expected to report any errors in pay to Payroll immediately. For example, if you believe that you were not properly paid for all hours worked, or that an improper deduction was made to your salary, you should immediately report this information to your Leader or People & Culture. If it is determined that an error has occurred, it will be corrected promptly.

Exempt employees will be paid a salary in accordance with applicable law. Although exempt employees are generally entitled to their salary for any week in which work is performed, deductions can and will be made when permitted by law. Such deductions are permitted for the following reasons:

•Complete days of absence for personal reasons other than sickness or disability; •Incomplete initial or final weeks of work; •Taxes, garnishments or other withholdings required by law;

©2020 Accolade Inc. Page 33 of 52 Employee Handbook • Version 19 • Published 8/19/2019 •Employee benefits; •Absence from work for one or more full days due to sickness or disability if the deduction is made in accordance with a bona fide plan, policy or practice of providing compensation for salary lost due to illness; •To offset for amounts the employee receives for jury duty or witness fees, or for military pay; •Unpaid disciplinary suspensions of one or more full days imposed in good faith for workplace conduct rule infractions; or •Unpaid leave under the FMLA.

There may also be other occasions when deductions are made from an exempt employee’s salary. Please contact a member of the Payroll team for more information.

Non-exempt employees are paid for time actually worked, as well as holidays and PTO as set forth in other sections of this Handbook. Deductions may be made from the paychecks of non-exempt employees for taxes, garnishments or other withholdings required by law, and for employee benefits. Please contact a member of the Payroll team for more information. Workplace Injuries & Workers Compensation

Iite m@@f@e y Jp Z C I6 In N ylY 3 R p b 2 4 td oG 9 jL T U u N C uJ9 @@@ are injured on the job, regardless of severity, the incident must be reported to your Leader and the Benefits Team. On- the-job injuries are covered by our Workers Compensation Insurance Policy, which is provided to you at no cost.

If you have a true emergency, have someone call 911. If it is not an emergency, you must seek care from doctors and facilities within our panel of doctors and facilities. Transportation should be provided by a family member or by ambulance. Accolade employees must not provide transportation for another team member in the event of a workplace injury.

Upon seeking care, the employee will be required to obtain written notification from the attending physician stating the nature of the injury, when the employee can return to work, and what restrictions, if any, apply.

Fite m@@@e y oJp Z C I6 In N lY 3 rR p b 2 4 td G 9 jL aT Y ifQ = = @@@ safe and comfortable work environment. No Smoking

Iite m@@n@e y Jp Z C I6 In N lY 3 R op b 2 4 td G 9 jL rT Y u MS dJ9 @@@ er to provide and maintain a healthy and safe work environment for all employees, Accolade strictly prohibits smoking in the workplace and in any area that is within 25 feet of an enclosed work area, except in locations that have been specifically designated as smoking areas.

In keeping with Accolade's intent to provide a safe work environment, please follow all posted guidelines regarding designated smoking areas.

Employees are directed to report all violations of this policy to their leader. No employee will be disciplined or retaliated against for reporting smoking that violates applicable State law or this Accolade policy.

Employees who violate this policy will be subject to disciplinary action up to and including termination.

If you need help quitting tobacco, your medical benefits plan may be able to help. Take a look at tobacco cessation assistance programs from our medical benefits provider or contact benefits for help finding this information.

Drug and Alcohol Policy / Substance Abuse Testing

Tite m@@@e y Jp Z hC I6 In N lY 3 R p eb 2 4 td G 9 jL T Y u MiJ9 f@@@ uture of our company is dependent on the physical and psychological health of our employees. We also recognize drug and alcohol dependency as an illness and a major health problem. We will utilize every reasonable means to maintain a drug-free work environment, including people leader training, employee education, and providing employees access to information concerning drug and alcohol abuse programs.

Accordingly, it is Accolade’s policy to maintain a strong commitment to providing a safe, efficient, and productive work environment. Accolade wishes to ensure that employees will perform their duties to the best of their abilities and in the best interests of their colleagues and Accolade. To meet its commitment to provide a safe working environment for all employees, promote the highest standards of employee health and productivity, and to comply with applicable State law, Accolade has implemented a drug and alcohol impairment testing policy.

Everyone shares responsibility for maintaining a safe work environment, and we expect our Leaders to reach out to the People & Culture team whenever they see changes in performance or behavior to suggest the employee has a substance abuse problem for investigation.

All employees who must use a prescription drug or medication that causes adverse side effects (e.g., drowsiness or impaired reflexes or reaction time) should inform their Leader and the Benefits Team they are taking such medication on the advice of a physician. Such employees are responsible for informing their Leader and the Benefits Team of possible side effects of the drug on performance and expected duration of use. If the prescription drug use could cause productivity or safety problems, the employee may be granted leave or temporarily assigned to different duties.

Accolade does not discriminate or retaliate against any qualified individuals with a disability and will implement this policy in compliance with the Americans with Disabilities Act and applicable state law. In addition, Accolade does not discriminate or retaliate against individuals who are medical marijuana cardholders, in accordance with applicable state law. Accolade will keep information concerning test results confidential to the extent required by law. Such information may be disclosed to individuals with a reasonable need to know it, when relevant to a legal claim asserted by or against the employee, when otherwise authorized by law, or with the written consent of the employee.

©2020 Accolade Inc. Page 35 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Definitions As used in this policy, the term: •Drug means amphetamines, cannabinoids, cocaine, phencyclidine (PCP), methadone, methaqualene, opiates, barbiturates, benzodiazepines, propoxyphene, or a metabolite of any such substances. •Prescription medication means a drug or medication lawfully prescribed by a physician for an individual and taken in accordance with such prescription. •Substance means drugs or alcohol.

Prohibited Use and Possession Cite m@@@e y Jp Z C oI6 In N lY 3 R p b n2 4 td G 9 jL T Y su Mi4 x In 0 = u@@@ mption, use, possession, sale, manufacture, and/or transportation of illegal drugs (including marijuana or other prescription drugs to the extent not otherwise permitted under applicable State law) or unapproved alcohol on Accolade's premises or during the hours of employment is strictly prohibited. Employees are further prohibited from reporting to work or working while impaired by the use of drugs or alcohol.

A drug is considered a "legal drug" if it is a drug prescribed or over-the-counter, legally obtained by the employee, and used for the purpose(s) for which it was prescribed or intended by the manufacturer, including but not limited to marijuana used pursuant to a valid prescription. Employees must ensure that any lawfully prescribed or obtained drugs or medications do not impair the employee's ability to fully and safely perform his or her duties within the standard of care normally accepted for that position. Employees may be disciplined or terminated for using marijuana in the workplace, regardless of whether they have a valid prescription for such use. Employees also may be disciplined or terminated for showing evidence of impairment at work due to the use of marijuana for medicinal purposes, if the employee’s conduct falls below the standard of care normally accepted for that position.

•At any time during the hours of employment, Accolade may search employee personal property located on Accolade's premises including, but not limited to, work areas, desks, purses, backpacks, briefcases, file cabinets, lockers, vehicles, and any other item or location where drugs and/or alcohol may be present. The unauthorized presence of drugs or alcohol, or the refusal to consent to a search, may result in discipline, up to and including termination.

Individuals Subject to Testing Aite m@@@e y Jp Z C I6 lIn N lY 3 lR p b 2 4 td G 9 ejL T Y u Mi4 y In m0 = @@@ ployees and prospective employees may be subject to drug and/or alcohol impairment testing, including all officers, directors, managers, and supervisors of Accolade, regardless of race, color, religion, national origin, gender, sexual orientation, gender identity, age, military status, citizenship status, pregnancy, disability or any other status protected by federal, state or local law.

Circumstances Under Which Testing May Be Required Aite m@@@e y Jp Z C I6 sIn N lY 3 R p b 2 4 td G a9 jL T Y u Mi4 zIn 0 = @@C@ ondition of Employment: Prospective employees may be asked to submit to alcohol and drug testing after a conditional offer of employment has been made.

Reasonable Suspicion Testing: In cases when an employee's leader or other Accolade Leader has reasonable suspicion to believe that the employee possesses or is under the influence of drugs and/or alcohol and such use or influence may adversely affect the employee's job performance, or the safety of the employee or colleagues, alcohol and/or drug screening may be ordered.

•A reasonable suspicion may arise from, among other factors, a leader's observation of an employee's appearance, behavior, speech, or other manifestations; co-worker reports or complaints; or other evidence of performance decline or behavioral changes. •Testing may also be required if an employee is found to be in possession of physical evidence, i.e. drugs, alcohol or paraphernalia possibly connected with the use of an illicit drug. Testing may also be required if illegal drugs and/or alcohol are found in the employee's immediate work area.

©2020 Accolade Inc. Page 36 of 52 Employee Handbook • Version 19 • Published 8/19/2019 However, it should be emphasized that possession of drugs or unauthorized alcohol on Company property or while at work is prohibited whether or not it is determined that the employee also used such substances.

Post-Accident Testing: Alcohol and/or drug screening may be required following any work-related accident or any violation of safety precautions or standards, whether or not an injury resulted from such accident or violation, provided that the circumstances give rise to a reasonable suspicion that the employee may be impaired by drugs or alcohol.

•Accolade reserves the right to test under other circumstances for the maintenance of safety for employees, customers, members or the public at large, and for the maintenance of productivity, quality of products or services, or security of property or information. •Employees who have been required to submit to a drug and/or alcohol impairment test as a result of an accident or reasonable suspicion will not be allowed to return to work until the results of the drug and/or alcohol test become available to Accolade.

Testing Methods and Collection Procedures:

•Testing Procedures: Generally, the method of testing for drugs and alcohol impairment will be urinalysis. Accolade reserves the right to use blood, breath, saliva, hair and /or other samples for testing as needed. •Testing Conditions: All sample collection and testing for drugs and alcohol impairment will be performed and documented according to the following conditions and procedures. ○The collection of samples will be performed under reasonable and sanitary conditions. Sample testing will comply with scientifically accepted analytical methods and procedures. Drug testing will be conducted at a laboratory approved or certified by the United States Department of Health and Human Services, the College of American Pathologists, or the Department of Health Services. ○The person being tested must present reliable individual identification to the person collecting samples, and has the right to provide notification of any information that may be considered relevant to the test, including identification of currently or recently used prescription drugs or over-the-counter drugs or other relevant medical information. ○Samples will be collected in a manner to protect the privacy of the individual to the greatest extent possible. ○Samples collections will be documented through proper labeling and chain-of-custody procedures to reasonably preclude the possibility of misidentification of the person tested in relation to the test result provided. Sample collection, storage, and transportation will be performed in a manner reasonably designed to preclude the possibility of sample contamination, adulteration, or misidentification. •Confirmation: Any positive drug test results for employees will be confirmed by use of a different chemical process than was used during the initial drug test. The second or confirmatory drug test will use a chromatographic technique such a gas chromatography-mass spectrometry or another comparably reliable analytical method. •Positive Tests: A drug or alcohol impairment test will be considered positive when the screening levels established by the testing laboratory are exceeded. Information regarding the screening cutoff levels for various drugs and/or alcohol impairment will be made available upon request. •Confidentiality of Results: Access to Records: Information and records relating to test results will be kept confidential to the extent required by law. Accolade will designate appropriate Company representatives to receive all test results. Accolade will not release any information regarding the test results outside of the Company without the written consent of the individual tested, except as otherwise authorized or required by law. •Access/Explanation: The tested individual has the right, upon request, to obtain the written results of any tests conducted on that individual. Individuals that have a positive test result will have the opportunity, upon request, to explain the positive test result in a confidential setting.

Disciplinary Consequences Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oY u Mi4 0 In 0 = l@@@ ade may take the following actions related to drug and alcohol impairment testing:

©2020 Accolade Inc. Page 37 of 52 Employee Handbook • Version 19 • Published 8/19/2019 •Refusal to Participate in Testing or Tampering with a Test: If an employee refuses to sign the requisite acknowledgement and consent form, refuses to participate in drug and/or alcohol impairment testing, or attempts to alter or invalidate a test, Accolade will immediately terminate the employee's employment. If a prospective employee refuses to sign the requisite acknowledgement and consent form, refuses to participate in drug and/or alcohol impairment testing, or attempts to alter or invalidate a test, the prospective employee will not be eligible for hire and the conditional offer of employment will be withdrawn. •Positive Test for Drugs and/or Alcohol Impairment: If an employee tests positive for illegal drugs and/or alcohol impairment, Accolade will discipline the employee, and may terminate the employee's employment, unless the employee reasonably demonstrates that he/she was legally authorized to use the drugs resulting in the positive test and was not impaired by such drugs while on Accolade's premises or during the hours of employment. If a prospective employee tests positive for drugs and/or alcohol impairment, the prospective employee will not be eligible for hire, unless the prospective employee reasonably demonstrates that he/she was legally authorized to use the drugs resulting in the positive test. •Employees who voluntarily come forward and identify themselves as having an alcohol or drug addiction before receiving a positive test result pursuant to this policy will be accommodated in accordance with the ADA and applicable state law, in the absence of an undue hardship.

Your Privacy

Wite m@@@e y Jp Z C I6 In N lY 3 R ep b 2 4 td G 9 jL T Y u Mvy J9 @@@ alue your privacy as an individual, but all of us as employees must recognize that our personal privacy is subject to Accolade’s need to provide for safe and secure workplace. This means that at times we may need to monitor or use your personal information for the benefit of our entire group. These situations are rare and we'll make every effort to discuss it with you when it happens.

During the course of your employment, we may perform and update your background, credit, and reference checks.

In order to maintain the security of our workplace and property, employees, and visitors to our workplace, we may need to utilize surveillance, including video surveillance. We may also need to conduct computer monitoring and search or inspect the contents of offices, storage areas, file cabinets, desks, boxes, workstations, or personal property like packages, backpacks, bags, etc. We reserve the right to do these things at any time for legitimate security reasons only.

While we respect employee privacy, we should not assume that our desk, cubicle, or use of computer devices or telephone equipment is private or confidential. Subject to federal, state and local laws and under the guidance of Legal, Accolade may search and review both incoming and outgoing communications and all device information, including any password- protected employee communications.

No Violence

Wite m@@@e y Jp Z C I6 In N lY 3 R ep b 2 4 td G 9 jL T Y u N aC J9 @@@ re serious about providing a safe and secure workplace for all employees.

Threats, threatening behavior, or other acts of physical or verbal violence, including intimidation, harassment and/or coercion, which involve or affect Accolade or which occur on our or our members’ property will not be tolerated. Acts or threats of violence include conduct which is sufficiently severe, offensive or intimidating to alter the employment conditions at Accolade or to create a hostile, abusive or intimidating work environment for one or more employees, subcontractors or vendors.

We do not allow firearms, knives or other weapons in the workplace, so don't even think about bringing one in. This policy applies regardless of whether an employee possesses a concealed weapons permit (CWP) or is allowed by law to possess a weapon. Employees who violate this policy will be subject to disciplinary action up to and including termination. This policy is not intended to limit Arizona law in which employees in Arizona may be permitted to store a firearm in a privately- owned vehicle or privately-owned motorcycle if the vehicle is locked and the firearm is not visible from outside the vehicle or motorcycle.

©2020 Accolade Inc. Page 38 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Violations of this policy or any potentially dangerous behavior should be reported to your Leader or People & Culture immediately and may lead to disciplinary action up to and including termination. Reports can be made anonymously and all reported incidents will be investigated in as confidential a manner as possible.

Confidentiality, Technology Invention and Intellectual Property Policy

Pite m@@@e y Jp aZ C I6 In N lY 3 R rp b 2 4 td G 9 jL T Y u N S J9 o@@@ f being an Accolade employee means that you are committed to helping Accolade build world class operations and technology, and in so doing keeping Accolade’s confidential and proprietary information secure. As a condition of your employment with Accolade, you have read and signed the Accolade Confidentiality, Technology Invention and Intellectual Property Policy and Agreement, which is required by all employees and other workforce members. If you improperly use or disclose any Accolade confidential or proprietary information, you will be subject to disciplinary action, up to and including termination of employment, regardless of whether or not you received any benefit from the use or disclosure.

Employees are responsible for reading and acknowledging the Accolade Confidentiality, Technology Invention and Intellectual Property Policy and Agreement, which provides more information on treatment and handling of confidential information. By acknowledging the Employee Handbook, you also agree that you have read, understood and agree to the terms and conditions of the Accolade Confidentiality, Technology Invention and Intellectual Property Policy incorporated herein.

Security Incident Response

Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oY u N iJ9 @@@ lade is subject to various federal and state laws regarding its use and storage of personal information (PI) and protected health information (PHI). In addition to the above regarding Accolade’s policy for the use and handling of Confidential Information generally, you are responsible for having read and understood Accolade’s HIPAA Privacy and Security Manual and Information Security Policy.

The HIPAA Manual and Information Security Policy also sets forth the procedure for responding to any security incident or breach event that potentially or actually results in the exposure or unauthorized use, access, or disclosure of PI or PHI.

You should be aware of the following HIPAA definitions:

•A “breach of unsecured protected health information” refers to the acquisition, access, use, or disclosure of unsecured PHI, in a manner not permitted by HIPAA, which poses a significant risk of financial, reputational, or other harm to the affected individual. •A “security incident” refers to the attempted or successful unauthorized access, use, disclosure, modification, or destruction of information or interference with system operations in an information system.

You are responsible to report immediately any suspected or actual breach or security incident to your Leader, the Chief Privacy Officer, Legal and, when the incident involves a security incident, the Chief Information Security Officer. The response to any security incidents and breaches will be handled directly by the Chief Privacy Officer and Chief Information Security Officer at the direction of Legal, and in consultation with senior management. You should not try to act upon the incident or breach by yourself, including by trying to secure computer systems without the direction of Accolade’s Information Security group, and you must not try to conceal any incident or breach.

Failure to follow this policy or the procedures set forth in Accolade’s HIPAA Privacy and Security Manual and Information Security Policies and Procedures may result in discipline up to and including termination. Conflicts of Interest

ite m@@@e y Jp Z C I6 In N lY 3 R p b 2 4 td G 9 jL T Y u N y J9 @@@

©2020 Accolade Inc. Page 39 of 52 Employee Handbook • Version 19 • Published 8/19/2019 A conflict of interest is any situation or activity that involves or appears to involve a conflict between your personal or financial interests and Accolade’s interests. A conflict of interest may arise as a result of an investment, interest, personal or business relationship or other association that interferes or might interfere with your obligation to perform your work or duties objectively and effectively for the best interest of the Company. You should be mindful of situations that might result in a conflict of interest and take appropriate action to address the circumstances giving rise to the conflict, including disclosing any relationship that might be perceived as a conflict of interest to your Leader, your People & Culture representative or Legal.

Conflicts of interest typically arise in the following situations:

•Outside business activities that involve working for a supplier, reseller, or a business that either competes with Accolade or does business with Accolade while being employed at Accolade. •Conducting any non-company business that interferes with the proper performance of our roles, such as conducting non-company business during working hours; utilizing confidential information or processes gained as a company employee; or using company property or equipment for non-company uses (exceeding reasonable personal use). •Using confidential information or processes gained as a company employee for personal gain or to Accolade’s detriment. •Offering or accepting a gift, meal, entertainment, travel expense, or other benefit that could be viewed as a bribe. •Exchanging expensive or lavish personal gifts or services between employees and leaders that could be viewed as favoritism or an attempt to exert inappropriate influence. •Accepting any personal benefit that is or could be interpreted as being given to us because of our role or seniority or because the donors believe we might be in a position to assist them in the future. •Participating in or influencing a company decision that may result in a personal gain, gain for an immediate family member, or gain for someone with whom we have a close personal relationship. •Making use of business opportunities discovered or learned through the use of company property, information, or our positions that may result in a personal gain, gain for an immediate family member, or gain for someone with whom we have a close personal relationship. •Serving on the board of directors or advising a competitor or a company that has or is seeking a business relationship with Accolade, including sponsorships, or owning a significant interest in such an organization, where our ability to make decisions in Accolade’s best interest could be compromised. •Participating in or influencing a company decision to hire a family member, or supervising an immediate family member or someone with whom we have a close personal relationship.

Employees must disclose any conflict of interest to a member of the People & Culture team, and may be required to take action to reduce or eliminate the conflict, in Accolade’s discretion. Failure to disclose a conflict of interest or knowingly engaging in conduct that results in a conflict of interest could lead to discipline up to and including termination.

Please see the Accolade Code of Conduct for more information regarding anti-corruption / anti-bribery, insider trading, and the gifts and entertainment policies.

Former Employer Confidential Information Yite m@@@e y Jp oZ C I6 In N lY 3 R up b 2 4 td G 9 jL T Y u N ay 4 x In 0 = @@r@ e not permitted to bring any intellectual property or confidential information of your former employer to Accolade, unless your former employer provides a written release to Accolade. You must identify any outside intellectual property or confidential information that you intend to use in your work for Accolade, even if owned by you. Accolade People & Culture will provide you with a form to disclose all intellectual property or confidential information that you intend to use in your work for Accolade, including, without limitation, patents, inventions, trade secrets, copyrights, source code, or other programs or algorithms. Unless otherwise agreed to in writing, you understand by using any personal intellectual property or confidential information in your work for Accolade you will be granting perpetual, irrevocable license rights in such personal intellectual property or confidential information to Accolade. Please see Accolade’s Confidentiality, Technology Invention and Intellectual Property Policy and Agreement for more information on your obligations as an employee of Accolade.

External Business Ventures

ite m@@@e y Jp Z C I6 In N lY 3 R p b 2 4 td G 9 jL T Y u N y 4 y In 0 = @@@

©2020 Accolade Inc. Page 40 of 52 Employee Handbook • Version 19 • Published 8/19/2019 If you intend to engage in an outside business or own shares or membership interests in another company in excess of five percent (5%) of that company’s outstanding shares/interests, you must submit the Outside Business Form to People & Culture. Outside business ventures are subject to Accolade approval.

Outside Employment Dite m@@@e y Jp Z C I6 uIn N lY 3 R p b 2 e4 td G 9 jL T Y u N y 4 zIn t0 = @@@o the highly competitive nature of the industry in which Accolade is involved, employees are restricted from certain associations or working arrangements with competing or conflicting organizations during their employment with Accolade. Subject to Accolade's prior written approval, an employee may work for other businesses during the course of his or her employment with Accolade, provided that he or she may not (a) perform work of a nature that conflicts or competes in any way with the business or services of Accolade; (b) use any Accolade resources including, but not limited to, computer hardware and software, telephones, facsimile machines, and copiers, for or in connection with any non-Company work; (c) perform any non-Company work on Accolade premises; or (d) perform any non-Company work during employees’ working hours.

No Solicitation/No Distribution

Site m@@@e y Jp oZ C I6 In N lY 3 R lp b 2 4 itd G 9 jL cT Y u O C J9 @i@@ tation and distribution of literature by non-employees on Company property is prohibited.

Solicitation by employees is prohibited when the person soliciting or the person being solicited is on working time. Working time is the time employees are expected to be working and does not include rest, meal or other authorized breaks. Distribution of literature by employees on company property in working areas is prohibited. Any employee who violates this policy will be subject to discipline, up to and including termination.

Kite m@@@e y Jp Z C eI6 In N lY 3 R p b e2 4 td G 9 jL T c pifQ = = @@@ ing those blip blop bleeps in order. Information Technology

Wite m@@@e y Jp Z C I6 In N lY 3 R p hb 2 4 td G 9 jL T ec u MS J9 @@@n you're using Accolade's IT infrastructure, use good judgment. This means:

•Keep confidential information safe. •No hacking. •No illegal activity. •Respect copyright laws. •No websites you wouldn't look at with your mom in the room. •Be nice to everyone.

The Security Space on Beat houses all of Accolade's Information Security Policies for easy access. You are encouraged to read and understand all policies contained, and reach out to the Security team with any questions or concerns.

All Accolade personnel play a role in protecting Accolade’s information, business assets and networks, and should include information security in their thinking when designing systems or developing business processes. The Security, Privacy, and Compliance organizations should be consulted as necessary to align such systems and business processes with Accolade’s Information Security policies and procedures.

Accolade's General Information Security Policy also defines baseline control measures that everyone at Accolade is expected to be familiar with and to consistently follow. Sometimes called standard of due care controls, these security measures are the minimum required to prevent a variety of different problems including: data breaches, hackings, and other forms of cybercrime, fraud and embezzlement, industrial espionage, sabotage, errors and omissions, and system unavailability. These policies also define the minimum controls necessary to prevent legal problems such as allegations of negligence, breach of fiduciary duty, or privacy violation. This policy document details both reasonable and practical ways for all of us at Accolade to prevent unnecessary losses.

Further, as part of your employment with Accolade, you are responsible for reading and acknowledging Accolade's User Acceptance Agreement pursuant to which you agree to Accolade's privacy and security policies and procedures related to the use of Accolade's computer systems, networks and data. By acknowledging the Employee Handbook, you also agree that you have read, understood and agree to the terms and conditions of Accolade's User Acceptance Agreement incorporated herein. Personal Device Acceptable Use Policy

Aite m@@@e y Jp Z C I6 sIn N lY 3 R p b 2 4 td G a9 jL T c u MiJ9 @n@@ Accolade employee, you may have access to certain Accolade systems, applications, and services (“Accolade Services”) to support your work for our members. In certain instances, Accolade may permit you the privilege of using a personally owned device of your choosing to conveniently access Accolade Services in accordance with this Policy. The Personal Device Acceptable Use Policy sets forth the terms and conditions of your usage of personally owned devices for Accolade business purposes. By using a personally owned device for Accolade business purposes, you are expressly agreeing to the terms of this Policy. Accolade reserves the right to change this Policy from time to time and will post new versions of the Policy as part of this Employee Handbook and can be found on the Security Space on The Beat.

This Policy is intended to protect the security, integrity and confidentiality of Accolade’s data and technology infrastructure. Limited exceptions to the personal device program may occur due to variations in devices and platforms. If you do not abide by the terms of this Policy, you may be subject to disciplinary action, including termination of employment.

©2020 Accolade Inc. Page 42 of 52 Employee Handbook • Version 19 • Published 8/19/2019 IMPORTANT: NON-PUBLIC PERSONALLY IDENTIFIABLE INFORMATION (NPI) OR PROTECTED HEALTH INFORMATION (PHI) MUST NOT BE SENT BY EMAIL OR OTHER ELECTRONIC MESSAGE IN AN INSECURE MANNER WHETHER ON YOUR PERSONAL DEVICE OR OTHERWISE. IF YOU HAVE A LEGITIMATE BUSINESS NEED TO SEND NPI OR PHI BY EMAIL OR ELECTRONIC MESSAGE, YOU MUST CONSULT WITH THE PRIVACY AND SECURITY OFFICERS FOR APPROVAL AND TO ENSURE PROPER USAGE OF SECURITY MEASURES (INCLUDING ENCRYPTION) TO PROTECT NPI AND PHI.

Who is permitted to use a personal device to access Accolade systems? Pite m@@@e y Jp eZ C I6 In N lY 3 R rp b 2 4 td mG 9 jL T c u Mi4 x In 0 = @i@@ ssion to access Accolade production systems via a personal device is determined on a case-by-case basis by your Leader (VP and above). Final approvals are determined by Accolade’s Security and Legal groups. Accolade may withdraw approval at any time, even if you are in compliance with this Policy.

Am I required to use a personal device for Accolade business? Nite m@@@e y Jp Z C I6 oIn N lY 3 R p b 2 .4 td G 9 jL T c Yu Mi4 y In 0 = @o@@ u are not required to use a personally owned device for Accolade business purposes. Accolade does not require you to own a personal device, purchase a voice or data plan from a wireless carrier or otherwise purchase any applications for accessing Accolade Services. If you choose to purchase any third party services (including voice and data services from a wireless provider), you are doing so by your own choice and at your own cost. Business use of your personal device may result in increases to your personal monthly service plan costs. Except in limited circumstances, as approved by your Leader (VP and above) and Finance based on business need, Accolade will not pay for or in any way reimburse you for any costs you incur as part of using your personal device. If your mobile service plan costs are currently being reimbursed, please be advised that Accolade reserves the right to terminate or reduce the reimbursement program at any time.

If you decide to use a personal device for Accolade business purposes, you do so at your own risk and Accolade will not be liable for any damage to such personal device, including remote wiping of your personal information. You may only use device types and operating systems that are supported by Accolade IT, and must not use any jailbroken device. You will also be required to implement certain security requirements, such as using a pin or password to access your device and turning on encryption. These requirements are more fully set forth below. Accolade reserves the right to restrict or revoke your right to use a personal device for Accolade business or on Accolade premises at any time.

You understand that contacting vendors for troubleshooting and support of third-party software is solely your responsibility, and Accolade has no obligation to support usage of your personal device. However, Accolade may, in its sole discretion, provide limited configuration support and advice provided by Accolade’s IT department.

Please see the Personal Device Acceptable Use Policy for more information regarding the guidelines and requirements for use of a personal device by employees. By acknowledging the Employee Handbook, you also agree that you have read, understood and agree to the terms and conditions of Accolade's Personal Device Acceptable Use Policy incorporated herein.

No Texting While Driving! Bite m@@@e y Jp Z eC I6 In N lY 3 R p b 2 4 td sG 9 jL T c u Mai4 zIn 0 = @@@ fe! Accolade has a zero-tolerance policy for texting or emailing while driving in connection with Accolade business. Use hands-free talking devices while driving or in other situations where attention to your personal safety is advisable. Employee Social Media Policy

ite m@@@e y Jp Z C I6 In N lY 3 R p b 2 4 td G 9 jL T c u My J9 @@@ Accolade’s Commitment Your Commitment We will respect your privacy and your personal views. We won’t You will follow Accolade policies that preclude actively monitor your personal online and social accounts. However, discrimination, harassment, and/or threats of if your social media activity is brought to our attention, we will violence, or similarly unlawful conduct. ensure that it is consistent with these guidelines and other Accolade policies.

©2020 Accolade Inc. Page 43 of 52 Employee Handbook • Version 19 • Published 8/19/2019 We will enforce company policy against harassment, discrimination, You will identify yourself properly when engaging in threats and other violence. social media activity. You will not disclose any confidential and trade secret information about Accolade’s business We will provide communication channels for feedback, guidance and operations, its finances, customers or clients information. including protected health information. See below for more information.

At Accolade, we understand that social media can be a fun and rewarding way to share personal and professional views and information. However, use of social media also presents risks and carries with it certain responsibilities. To assist you in making responsible decisions about your use of social media and other online behaviors, we have established these guidelines. Guidelines Dite m@@@e y Jp Z C I6 eIn N lY 3 R p b 2 f4 td G 9 jL iT c u Mny 4 x In 0 = @@i@ ng social media. In the rapidly expanding world of electronic communication, social media can mean many things. Social media includes all means of communicating or posting information or content of any sort on the Internet, including:

•Your own or someone else’s blog, journal or diary •Personal website •Social networking sites or applications •Partner/affinity websites •Web bulletin board, group or a chat room, whether or not associated or affiliated with Accolade •Any other form of electronic communication

Know and Follow the Rules Cite m@@@e y Jp Z C aI6 In N lY 3 R p b r2 4 td G 9 ejL T c u My 4 y fIn 0 = @@u@ lly read these guidelines and the Accolade Discrimination & Harassment Prevention Policy, to ensure your postings are consistent with these policies. Social media activity should follow the same guidelines as outlined in our Discrimination & Harassment Prevention Policy, which means that postings that include discriminatory remarks, harassment, and/or threats of violence, or unlawful conduct, will not be tolerated and may subject you to disciplinary action up to and including termination.

Remember…

1.Ultimately, you are solely responsible for what you post online. Don’t let others access your social media accounts. 2.Before creating or posting online content, consider some of the risks that may be involved. 3.Always be fair and courteous to fellow associates, customers, members, partners, suppliers or people who work on behalf of Accolade. 4.Make sure you are always honest and accurate when posting information or news, and if you make a mistake, correct it quickly. It is considered a best practice to be open about any previous posts you have altered. Remember that the internet archives almost everything; therefore, even deleted postings can be searched. Never post any information or rumors that you know to be false about Accolade, fellow associates, members, customers, suppliers, and people working on behalf of Accolade or competitors.

Note: If you decide to post complaints or criticism, avoid using statements, photographs, video or audio that reasonably could be viewed as malicious, obscene, threatening or intimidating, that disparage customers, members, associates or suppliers, or that might constitute harassment or bullying. Examples of such conduct might include offensive posts meant to intentionally harm someone’s reputation or posts that could contribute to a hostile work environment on the basis of age, race, national origin, sex, sexual orientation, disability, religion or any other status protected by law or company policy.

When Posting About Accolade

ite m@@@e y Jp Z C I6 In N lY 3 R p b 2 4 td G 9 jL T c u My 4 zIn 0 = @@@

©2020 Accolade Inc. Page 44 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Maintain the confidentiality of Accolade trade secrets and private or confidential information. Trades secrets may include information regarding the development of systems, processes, products, know-how and technology. Do not post internal reports, news, policies, procedures or other internal business-related confidential communications. Confidential information also includes non-public personally identifiable and protected health information of our members, and other non-public information about the Company. However, we don’t intend any meaning of confidential information that would prevent you from discussing your salary or wages, terms of employment, workplace conditions or other protected activity.

Identify yourself. Do not create a link from your blog, website or other social networking site to an Accolade website without identifying yourself as an Accolade employee.

Express only your personal opinions. Never represent yourself as a spokesperson for Accolade. If Accolade is a subject of the content you are creating, be clear and open about the fact that you are an employee, and make it clear that your views do not represent those of Accolade, fellow employees, members, customers, suppliers or people working on behalf of Accolade. It is best to include a disclaimer, such as: “The postings on this site are my own and do not necessarily reflect the views of Accolade.”

Contact Marketing for support. If you are unsure of what is appropriate to post about Accolade, please contact the marketing team for guidance.

Using Social Media at Work Aite m@@@e y Jp Z C I6 sIn N lY 3 R p b 2 4 td G a9 jL T c u My 4 0 In 0 = @@@ Accolade employee, you are a steward of Accolade’s brand on and offline. Be proud of your company, team and opportunities and share as you feel appropriate.

At Accolade, we use various social platforms – Facebook, LinkedIn, Twitter, YouTube, Instagram and Google+ – to bring our brand to life and to engage with different audiences about the issues we care about as an employer, a service provider and a member of the greater healthcare and local communities. We welcome employees to support and be involved with Accolade through social media by liking and sharing our content as well as sharing your own stories and perspectives.

After all, your support helps us reach more potential employees, customers, members and potential employees while building our corporate brand.

Personal social media should be limited during work hours, unless it is work-related and/or authorized by your/an Accolade manager. Do not use an Accolade email address to register on social networks, blogs or other online tools utilized for personal use.

Retaliation is Prohibited Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T oc u My 4 1In 0 = l@@@ ade prohibits taking negative action against any associate for reporting a possible deviation from this policy or for cooperating in an investigation. Any associate who retaliates against another associate for reporting a possible deviation from this policy or for cooperating in an investigation will be subject to disciplinary action, up to and including termination.

Media Contacts (Speaking with the Media or other Third Parties) Aite m@@@e y Jp Z C I6 lIn N lY 3 lR p b 2 4 td G 9 rjL T c u Mey 4 2 In 0 = @@q@ uests made by the media for any information about Accolade’s business or operations should be referred to the Marketing and Communications group, via [email protected]. No employee should speak to the media about or on behalf of Accolade’s business or operations, unless approved by the Marketing and Communications group and Legal.

If someone from the media contacts you, please direct the individual to Marketing and let them know as soon as possible that you have been contacted by the media. If the inquiry pertains to a legal matter, please contact the Legal team. In either instance, you can simply say something like: “You know, I’m not the right person to answer those questions but I’m happy to have the right folks contact you.”

Tite m@@@e y Jp Z hC I6 In N lY 3 R p eb 2 4 td G 9 jL T rc u N C J9 e@@@ are a whole bunch of Accoladians who roll up their sleeves and get things done no matter where they happen to be. Having the ability to work remotely can be really valuable in helping to juggle work and life. And in the event of an emergency affecting an Accolade site, having the ability to log on from alternate locations can ensure we can support our members when they need us the most.

In order to maintain Accolade's security and safety standards no matter where you are, it is imperative that each employee of Accolade takes responsibility to understand and comply with the guidelines set forth in this Handbook. Acknowledgement of this handbook will serve as certification that you have/agree to the following when you are working remotely:

•Your home is wired for high-speed access to the internet ○Your home must be wired for remote technology set-up, including a wired connection to broadband internet router •You have a remote work space, which includes ○Home office or dedicated work space during business hours ○Work space is set-up so that remote employee can work undisturbed by family, pets, personal phones, or visitors ○Work space meets all requirements outlined on the Work From Home (“WFH”) portal. ○Work space is ergonomically acceptable ○Computer and any related information will be secured in a locked area ○PHI guidelines and procedures will be maintained in the home environment •Remote employee understands that at a minimum, they are expected to log in and work their normal schedule, regardless of inclement weather when the Accolade office is open. •Remote employee consents to home inspections at any time during their remote work schedule.

In order to ensure that the experience of both members and employees is held to the same Accolade standards both in and out of the office, and that Accolade’s privacy and security policies are adhered to, Accolade reserves the right to conduct both informational and on-site audits of WFH employees’ workplaces. Consistent with Accolade’s information security practices, as further set forth in this handbook, Accolade also reserves the right to monitor WFH employees’ computer systems and activities. This process is to protect both WFH employees and Accolade for any liability risks, including HIPAA compliance and other important legal issues, and to guarantee satisfaction across all Accolade members.

Work from Home Audit Process: Pite m@@@e y Jp rZ C I6 In N ilY 3 R p ob 2 4 td G 9 jL T rc u N C 4 x In 0 = t@@@ o WFH approval, an employee may be subject to an informational, virtual, and/or on-site audit at Accolade’s discretion. An informational audit will require the employee to attest that its space meets the requirements of these guidelines, and further may require the employee to provide information about their remote workspace, including pictures of the space for evaluation by the WFH approver. 1.An initial post-approval audit for new remote employees will be completed within 2 weeks of their remote work start date and may include an informational or on-site audit at Accolade’s discretion. 2.Once the employee passes both the pre-approval and post-approval audits, Accolade will have the right to perform informational or on-site audits on an annual basis or periodically at its discretion. 3.If the employee does not pass an audit at any time, they will be provided written notice of all the items that did pass expectations. A failure to pass an audit may result in disciplinary action, up to and including revocation of WFH privileges or termination of employment. 4.Audit results will be housed with employee’s leader and with People & Culture.

Return of Company Property and Equipment

ite m@@@e y Jp Z C I6 In N lY 3 R p b 2 4 td G 9 jL T c u N C 4 y In 0 = @@@

©2020 Accolade Inc. Page 46 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Employees are expected to return all Company property and equipment that is in their possession in good condition to the Company in the event of termination of employment or immediately upon request. Accolade reserves the right to take any lawful action to recover or protect company property and equipment, in accordance with applicable law.

Fite m@@@e y oJp Z C I6 In N lY 3 rR p b 2 4 td G 9 jL oT g ifQ = = @@@ur friends in AZ and WA. Appendix A: Arizona

Tite m@@@e y Jp Z hC I6 In N lY 3 R p eb 2 4 td G 9 jL T g u MS fJ9 @@@ ollowing policies apply to Arizona employees of Accolade, and supplement the policies set forth in the Employee Handbook. If any of the policies in this Appendix conflict with the policies in the Employee Handbook, this Appendix controls. Arizona employees with questions about the policies contained in this Appendix or any other matters should contact People & Culture.

The contents of this Addendum are guidelines only. Neither this Appendix nor any other Accolade guidelines, policies, or practices creates an employment contract. Accolade reserves the right to change, correct, modify, or revoke this Appendix or any of its terms at any time with or without notice. Nothing in this Appendix alters the at-will nature of your employment. Although other terms, conditions, and benefits of employment with Accolade may change from time to time, the at-will nature of employment with Accolade is one aspect of the employment relationship that cannot be changed by any oral statement or alleged oral statement. It can only be changed pursuant to a written agreement covering employment status and signed by an authorized Accolade manager.

Military Leave Pite m@@@e y Jp uZ C I6 In N lY 3 R rp b 2 4 td sG 9 jL T g u MuS 4 x In 0 = @@a@ nt to Section 26-168, Arizona Revised Statutes, and the Uniformed Services Employment and Reemployment Rights Act (USERRA), Accolade provides leaves of absence to members of the National Guard or United States armed forces reserves for the purpose of complying with competent orders of the state or United States for active duty, or to attend camps, maneuvers, formations, or armory drills. To qualify, you must give Accolade advance notice of your intent to take leave within five business days of receiving official notice of the impending call or order to active duty. Once received, you must provide a copy of your orders to the Benefits Team. Employees are entitled upon completion of military service to re-employment with Accolade to his or her previous position or to a higher position consistent with the employee’s ability and experience, as seniority or precedence would ordinarily entitle the employee, in accordance to Arizona and federal law. Upon the completion of military service, employee must notify the Benefits Team of the intent to return to a position within the Company. Time off pursuant to competent orders may not impact an employee’s vacation rights. However, Accolade may count a military leave of absence when calculating an employee’s eligibility for and amount of PTO.

Constructive Discharge Notice Tite m@@@e y Jp Z hC I6 In N lY 3 R p eb 2 4 td G 9 jL T g u MS f4 y In 0 = o@@@ llow information is provided pursuant to Section 23-1502, Arizona Revised Statutes: An employee is encouraged to communicate to the employer whenever the employee believes working conditions may become intolerable to the employee and may cause the employee to resign. Under section 23-1502, Arizona Revised Statutes, an employee may be required to notify an appropriate representative of the employer in writing that a working condition exists that the employee believes is intolerable, that will compel the employee to resign or that constitutes a constructive discharge, if the employee wants to preserve the right to bring a claim against the employer alleging that the working condition forced the employee to resign. Under the law, an employee may be required to wait for fifteen calendar days after providing written notice before the employee may resign if the employee desires to preserve the right to bring a constructive discharge claim against the employer. An employee may be entitled to paid or unpaid leave of absence of up to fifteen calendar days while waiting for the employer to respond to the employee's written communication about the employee's working condition. Notwithstanding any other requirements of this section, an employee may bring a constructive discharge claim without prior written notice in the event of outrageous conduct by the employer or by a managing agent of the employer including sexual assault, threats of violence directed at the employee, a continuous pattern of discriminatory harassment by the employer or

©2020 Accolade Inc. Page 48 of 52 Employee Handbook • Version 19 • Published 8/19/2019 by a managing agent of the employer or other conduct if the conduct would cause a reasonable employee to feel compelled to resign.

Appendix B: Washington

Tite m@@@e y Jp Z hC I6 In N lY 3 R p eb 2 4 td G 9 jL T g u MiJ9 f@@@ ollowing policies apply to Washington employees of Accolade supplement the policies contained in the Employee Handbook. If any of the policies in this Addendum conflict with the policies in the Employee Handbook, this Appendix controls. Washington employees with questions about the policies contained in this Appendix or any other matters should contact People & Culture.

Meal Periods Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T og u Mi4 x In 0 = l@@@ ade provides Washington employees who work more than five (5) hours in a day with an unpaid 30-minute, uninterrupted duty free meal period. Employees must start their meal period no less than two hours and no more than five hours from the beginning of their shift. Accolade provides employees who work more than ten (10) hours a day with a second unpaid 30-minute, uninterrupted duty free meal period starting before the beginning of the 10th hour of work. Employees who work at least three (3) hours longer than a normal work day (i.e., the shift that the employee is regularly scheduled to work) will also be provided an unpaid 30-minute, uninterrupted duty free meal period before or during the overtime period.

No employee will be permitted to work more than five (5) consecutive hours without a meal period, unless the employee requests to waive his or her meal period, and Accolade approves that request. The request and approval must be in writing. An employee may cancel a request to waive a meal period at any time.

Employees are entitled, encouraged, afforded and expected to take all meal periods provided under the Meal Period policy and not waived. Accolade completely relieves employees of all work duties and does not exercise control over employees’ activities during their uninterrupted, duty free meal period.

Employees are free to leave the work site during the meal period and are free to spend their meal period time as they choose (consistent with any other Accolade policies that may apply during off-duty time). No supervisor or Leader may impede or discourage employees from taking meal periods provided under this policy.

Meal periods taken by non-exempt employees are unpaid. Non-exempt employees must record the start and stop times of their meal periods and must follow their scheduled meal period. Employees may not work through their meal periods so that they can leave work early. Meal periods must be taken in a continuous block of time and not taken in the aggregate.

Non-exempt employees should not be asked to take a late meal period. Should business necessitate that a non-exempt employee be required to work through any of a thirty minute meal period or be asked to take a late meal period, such employee will be paid for all time worked. In that regard, if an employee is required to miss a meal period, take a late meal period, or work during a meal period, the employee must immediately report it to People & Culture so that the employee can be properly paid.

If you feel that you were not provided a meal period that complies with this policy, you must inform your leader or People & Culture immediately.

©2020 Accolade Inc. Page 49 of 52 Employee Handbook • Version 19 • Published 8/19/2019 Rest Periods Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T og u Mi4 y In 0 = l@@@ ade authorizes and permits non-exempt employees to take a 10-minute paid rest period for every four (4) hours of working time. No employee is required to work more than three hours without a rest period. The 10-minutes off-duty rest period does not include the reasonable time it takes to walk to and from the break area. No employee will be permitted to work more than three (3) consecutive hours without a 10-minute rest period.

Rest periods are paid and counted as hours worked. Therefore, non-exempt employees should not record their rest periods on timesheets or clock out for rest periods. Employees should take their rest periods in the middle of each four (4) hour work period to the extent practical to do so. Employees cannot combine rest periods with meal periods or skip rest periods to leave work early.

If you feel that you were not permitted or not provided an opportunity to take all rest periods authorized and permitted under this policy, you must inform your Leader or a member of the People & Culture team immediately.

Washington Family Leave Act (WFLA)

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Like the federal Family and Medical Leave Act (FMLA), the Washington Family Leave Act (WFLA) provides Washington employees up to 12 weeks of job-protected leave in a 12-month period to eligible employees. Employees are eligible if they have at least 12 months of service and have worked at least 1,250 hours in the 12-month period preceding the requested leave. The WFLA will run concurrently with the FMLA, except in the following instances:

•Pregnancy Disability Leave. Even if you are not eligible for FMLA/WFLA leave, if temporarily disabled by pregnancy, childbirth or related medical conditions, you may be entitled to take a pregnancy disability leave for the period of the temporary disability. If you are eligible for WFLA, the pregnancy disability leave will be provided in addition to the 12 work weeks of leave provided under the WFLA. This means that the employee will have more total protected leave from work than the 12-week entitlement under the FMLA, because, in most cases, the pregnancy disability leave will count against the 12 weeks of FMLA but not against the employee’s WFLA allotment. Instead, the 12 weeks of WFLA leave will begin to run when the employee’s physician releases her to work following the birth of the child, usually six to eight weeks after the date of birth. A physician’s statement may be required to verify the leave period relating to pregnancy or childbirth consistent with the verification required by Accolade for other temporary disabilities. •In a case when an employee qualifies for FMLA and the employee needs leave to care for a registered domestic partner with a serious health condition, the employee can use up to 12 weeks of WFLA for this purpose. Only the WFLA will run, and the employee will still have 12 weeks of FMLA available for FMLA-qualifying purposes. •If a qualifying employee exhausts all or part of his or her FMLA entitlement because of a qualifying military exigency leave, the employee may still have access to all 12 weeks of WFLA. This is because certain military exigencies are not covered under the WFLA and certain covered service members do not meet the definition of family member under the WFLA. In such cases, the WFLA will not run when the FMLA is running for those purposes.

If you want more information regarding your eligibility for a leave under the WFLA and/or the impact of the leave on your seniority and benefits, please contact the Benefits Team.

Discussion of Wages Nite m@@@e y Jp Z C I6 oIn N lY 3 R p b 2 4 td G 9 ejL T g u Mi4 0 In m0 = @@@ ployee is prohibited from inquiring about, disclosing, comparing or otherwise discussing his or her wages or the wages of another employee or from asking the Company to provide a reason for the employee's wages and/or lack of opportunity for advancement. The Company also will not retaliate against any employee because he or she aids or encourages another employee to exercise his or her rights to discuss or disclose wage information.

Employees are not required to disclose their wages.

©2020 Accolade Inc. Page 50 of 52 Employee Handbook • Version 19 • Published 8/19/2019 This policy does not apply to disclosure of other employees' wage information by employees who have access to such information solely as part of their essential job functions and who, while acting on behalf of the Company, make unauthorized disclosure of that information. Company representatives may disclose employees' wages in response to a complaint or charge, in furtherance of an investigation or when otherwise consistent with the Company's legal duty to provide information.

Wages and Salaries – (Seattle Only) Aite m@@@e y Jp Z C I6 cIn N lY 3 R p b c2 4 td G 9 jL T og u Mi4 1In 0 = @l@@ ade complies with the requirements of the Seattle “Wage Theft Ordinance” No. 123596 which prohibits the intentional nonpayment of wages due from the employer to an employee. Beginning with date of hire, Accolade will provide written information to employees regarding their rate of pay, pay basis (e.g., hour, shift, day, week, commission), and pay day. Each pay day, Accolade will provide written notice of the wages and tips employees received during the pay period. Accolade will keep and maintain payroll information for three (3) years.

Under the Ordinance, employees have the right the right to make inquiries about rights protected under the Ordinance; the right to file an oral or written complaint” about an alleged violation with the Office of Labor Standards (“OLS”); the right to inform an employer and/or legal counsel about an employer’s alleged violation; the right to cooperate with OLS in its investigations; the right to oppose any policy, practice, or act that is unlawful under the Ordinance; and the right to inform other employees of their potential rights under the Ordinance.

Background Checks – (Seattle Only) Iite m@@f@e y Jp Z C I6 In N tlY 3 R p b h2 4 td G 9 jL T g eu Mi4 2 In 0 = @ @@ Accolade determines to conduct a background check on prospective employees, it will comply with the City of Seattle Background Check Ordinance (Seattle Municipal Code 14.17). After an applicant for a position has been screened for minimum qualifications necessary for a position, Accolade may perform a background check on the applicant. Seattle’s Background Check Ordinance prohibits employers from rejecting an otherwise qualified job applicant, or taking an adverse employment action (for example, discharging, suspending, disciplining, demoting, or denying a promotion) to an employee solely on the basis of an arrest record. Before taking an adverse action based on the conduct relating to an arrest, a conviction or a pending criminal charge in criminal history that is revealed by any background check, Accolade will inform the applicant / employee of the information that it is relying on and give the person a reasonable opportunity to explain or correct that information. Accolade will hold open the position for two business days after notifying the applicant / employee that it will be making an adverse business decision solely on the basis of conduct relating to an arrest, a conviction or a pending criminal charge, and provide a reasonable opportunity for the person to respond, correct or explain that information.

Iite m@@f@e y Jp Z C I6 In N ylY 3 R p b 2 4 td oG 9 jL T k ifQ = = u@@@ have any questions, comments, or concerns about anything in this Handbook, you always have someone to talk to. Send us a note anytime! People & Culture [email protected]