WORKPLACE VIOLENCE PREVENTION PROGRAM for Malone Workforce Solutions

Our establishment’s Workplace Violence Prevention Plan (WVPP) addresses the hazards known to be associated with the four types of workplace violence as defined by Labor Code (LC) section 6401.9.

Date of Last Review: 06/17/2024

Date of Last Revision(s): 06/17/2024

DEFINITIONS

Emergency – Unanticipated circumstances that can be life threatening or pose a risk of significant injuries to employees or other persons.

Engineering controls – An aspect of the built space or a device that removes a hazard from the workplace or creates a barrier between the employee and the hazard.

Log – The violent incident log required by LC section 6401.9.

Plan – The workplace violence prevention plan required by LC section 6401.9.

Serious injury or illness – Any injury or illness occurring in a place of employment or in connection with any employment that requires inpatient hospitalization for other than medical observation or diagnostic testing, or in which an employee suffers an amputation, the loss of an eye, or any serious degree of permanent disfigurement, but does not include any injury or illness or death caused by an accident on a public street or highway, unless the accident occurred in a construction zone.

Threat of violence – Any verbal or written statement, including, but not limited to, texts, electronic messages, social media messages, or other online posts, or any behavioral or physical conduct, that conveys an intent, or that is reasonably perceived to convey an intent, to cause physical harm or to place someone in fear of physical harm, and that serves no legitimate purpose.

Workplace violence – Any act of violence or threat of violence that occurs in a place of employment.

Workplace violence includes, but is not limited to, the following:

• The threat or use of physical force against an employee that results in, or has a high likelihood of resulting in, injury, psychological trauma, or stress, regardless of whether the employee sustains an injury.
• An incident involving a threat or use of a firearm or other dangerous weapon, including the use of common objects as weapons, regardless of whether the employee sustains an injury.
• The following four workplace violence types:

Type 1 violence – Workplace violence committed by a person who has no legitimate business at the worksite, and includes violent acts by anyone who enters the workplace or approaches employees with the intent to commit a crime.

Type 2 violence – Workplace violence directed at employees by customers, clients, patients, students, inmates, or visitors.

Type 3 violence – Workplace violence against an employee by a present or former employee, supervisor, or manager.

Type 4 violence – Workplace violence committed in the workplace by a person who does not work there, but has or is known to have had a personal relationship with an employee.

Workplace violence does not include lawful acts of self-defense or defense of others.

Work practice controls – Procedures and rules which are used to effectively reduce workplace violence hazard.

RESPONSIBILITY

The WVPP administrator, Glenda Armes, Director of Human Resources, has the authority and responsibility for implementing the provisions of this plan for Malone Workforce Solutions. If there are multiple persons responsible for the plan, their roles will be clearly described.

All managers and supervisors are responsible for implementing and maintaining the WVPP in their work areas and for answering employee questions about the WVPP.

EMPLOYEE ACTIVE INVOLVEMENT

Malone Workforce Solutions ensures the following policies and procedures to obtain the active involvement of employees and authorized employee representatives in developing and implementing the plan:

• Management will work with and allow employees and authorized employee representatives to participate in:
  • Identifying, evaluating, and determining corrective measures to prevent workplace violence.
    • Management will host annual safety meetings with employees and their representatives to discuss identification of workplace violence related concerns/hazards, evaluate those hazards and/or concerns, and how to correct them. These meetings will involve brainstorming sessions, discussions of recent incidents, and reviews of safety procedures.
• Designing and implementing training
  • Employees are notified and encouraged to participate in designing and implementing training programs, and their suggestions are incorporated into the training materials. For example, an employee might suggest a new training scenario based on a recent incident.
• Reporting and investigating workplace violence incidents.
  • Management will ensure that all workplace violence policies and procedures within this written plan are clearly communicated and understood by all employees. Managers and supervisors will enforce the rules fairly and
  • All employees will follow all workplace violence prevention plan directives, policies, and procedures, and assist in maintaining a safe work environment.
• The plan shall be in effect at all times and in all work areas and be specific to the hazards and corrective measures for each work area and operation.

EMPLOYEE COMPLIANCE

Our system to ensure that employees comply with the rules and work practices that are designed to make the workplace more secure, and do not engage in threats or physical actions which create a security hazard for others in the workplace, include at a minimum:

• Training employees, supervisors, and managers in the provisions of Malone Workforce Solutions Workplace Violence Prevention Plan (WVPP)
• Effective procedures to ensure that supervisory and nonsupervisory employees comply with the WVPP by ensuring that all employees complete training annually at a minimum.
• Provide retraining to employees whose safety performance is deficient with the WVPP.
• Recognizing employees who demonstrate safe work practices that promote the WVPP in the workplace by sending email or memo’s thanking them for participation and adherence.
• Discipline employees for failure to comply with the WVPP using Malone Workforce Solutions disciplinary action procedure will include verbal and written corrective action up to and including termination.

COMMUNICATION WITH EMPLOYEES

We recognize that open, two-way communication between our management team, staff, and other employers, about workplace violence issues is essential to a safe and productive workplace. The following communication system is designed to facilitate a continuous flow of workplace violence prevention information between management and staff in a form that is readily understandable by all employees, and consists of one or more of the following:

• New employee orientation includes workplace violence prevention policies and
• Workplace violence prevention training
• Regularly scheduled meetings that address security issues and potential workplace violence hazards
• Effectivecommunicationbetweenemployees andsupervisors aboutworkplace violence prevention and violence concerns.
  • Malone Workforce solutions will ensure that supervisors and employees can communicate effectively and in the employees’ first language.
• Posted or distributed workplace violence prevention information.
• Employees can report a violent incident, threat, or other workplace violence concern to employer or law enforcement without fear of reprisal or adverse action.
  • Examples of how to report an incident, threat or other workplace violence concern include:
    • Employees can report a violent incident via email to HR@malonesolutions.com. To remain anonymous, you can report via phone at 888-242-4560.
    • Employees can call 911 directly if immediate help is necessary.
  • Employees will not be prevented from accessing their mobile or other communication devices to seek emergency assistance, assess the safety of a situation, or communicate with a person to verify their safety.
  • Employees’ concerns will be investigated in a timely manner, and they will be informed of the results of the investigation and any corrective actions to be taken.
    • Updates on the status of investigations and corrective actions are provided to employees through email and at safety meetings. These updates could include information about the progress of investigations, the results of investigations, and any corrective actions taken.
    • Sharing training materials and incident reports with other employers to ensure a coordinated response to any incidents. This could involve sending copies of training materials and incident reports to other employers.

COORDINATION WITH OTHER EMPLOYERS

Malone Workforce Solutions will implement the following effective procedures to coordinate implementation of its plan with other employers to ensure that those employers and employees understand their respective roles, as provided in the plan.

• All employees will be trained on workplace violence prevention.
• Workplace violence incidents involving any employee are reported, investigated, and recorded.
• At a multiemployer worksite, Malone Workforce Solutions will ensure that if its employees experience workplace violence incident that Malone Workforce Solutions will seek copies of the violent incident log from the controlling or host employer.

WORKPLACE VIOLENCE INCIDENT REPORTING PROCEDURE

Malone Workforce Solutions will implement the following effective procedures to ensure that:

• All threats or acts of workplace violence are reported to an employee’s supervisor or manager, who will inform the WVPP administrator. This will be accomplished by calling or emailing the WBPP administrator. If that’s not possible, employees will report incidents directly to the WVPP administrator, Glenda Armes at HR@malonesolutions.com
• Employees can report incidents to their supervisor, HR at hr@malonesolutions.com, or through our anonymous hotline or form.
• Workplace Violence Reporting Hotline: 888-242-4560
• Workplace Violence Reporting form: https://www.surveymonkey.com/r/TVB5MGF

A strict non-retaliation policy is in place, and any instances of retaliation are dealt with swiftly and decisively.

• Any employee who retaliates against a coworker for reporting an incident will receive disciplinary action up to and including termination.

EMERGENCY RESPONSE PROCEDURES

Malone Workforce Solutions has in place the following specific measures to handle actual or potential workplace violence emergencies:

• Effective means to alert employees of the presence, location, and nature of workplace violence emergencies by the following:
  • Text messages, phone calls and emails to employees working at host employers.
• Malone Workforce Solutions will have evacuation or sheltering plans.
  • Employees at host employer locations will follow the designated procedure for those companies.
  • Employees located in a Malone Workforce Solutions office will shelter under desks or exit the building via the closest, safest exit.
• How to obtain help from staff, security personnel, or law enforcement.
  • If there is immediate danger, call for emergency assistance by dialing 9-1-1 or contact the Riverside police department at 951-354-2007.
  • Then notify the Glenda Armes by calling 502-242-3175 or emailing hr@malonesolutions.com

In the event of an emergency, including a Workplace Violence Emergency, contact the following:

WORKPLACE VIOLENCE HAZARD IDENTIFICATION AND EVALUATION

The following policies and procedures are established and required to be conducted by Malone Workforce Solutions to ensure that workplace violence hazards are identified and evaluated:

• Inspections shall be conducted when the plan is first established, after each workplace violence incident, and whenever the employer is made aware of a new or previously unrecognized hazard. Malone Workforce Solutions will work with our clients (host employers) to inspect on an annual basis.

 Review all submitted/reported concerns of potential hazards:

• • Immediate review of all submitted and reported concerns.
  • Anonymous hotline
  • Online form for reporting workplace violence hazards
  • Voicemail/email/text messages

Periodic Inspections 

Periodic inspections of workplace violence hazards will identify unsafe conditions and work practices. This may require assessment for more than one type of workplace violence. Periodic Inspections shall be conducted annually.

Periodic inspections to identify and evaluate workplace violence and hazards will be performed by the following designated personnel in the following areas of the workplace:

Inspections for workplace violence hazards include assessing:

• The exterior and interior of the workplace for its attractiveness to
• The need for violence surveillance measures, such as mirrors and
• Procedures for employee response during a robbery or other criminal
• Procedures for reporting suspicious persons or
• Effective location and functioning of emergency buttons and alarms.
• Posting of emergency telephone numbers for law enforcement, fire, and medical services.
• Whether employees have effective escape routes from the workplace.
• Whether employees have a designated safe area where they can go to in an emergency.
• Adequacy of workplace security systems, such as door locks and entry codes.
• Frequency and severity of threatening or hostile situations that may lead to violent acts by persons who are service recipients of our establishment.
• Effectiveness of systems and procedures that warn others of actual or potential workplace violence danger or that summon assistance, e.g., alarms or panic buttons.
• Access to and freedom of movement within the workplace by non-employees, including recently discharged employees or persons with whom one of our employees is having a dispute.
• Frequency and severity of employees’ reports of threats of physical or verbal abuse by managers, supervisors, or other employees.
• Any prior violent acts, threats of physical violence, verbal abuse, property damage or other signs of strain or pressure in the workplace.

WORKPLACE VIOLENCE HAZARD CORRECTION

Workplace violence hazards will be evaluated and corrected in a timely manner. Malone Workforce Solutions will implement the following effective procedures to correct workplace violence hazards that are identified:

• All corrective actions taken will be documented and dated on the appropriate The latest edition of our corrective action forms can be obtained by email hr@malonesolutions.com. Employees will work with HR to complete and administer the plans.
• Corrective measures for workplace violence hazards will be specific to a given work area.
  • Make the workplace unattractive to robbers by:
    • Improve lighting around and at the workplace.
    • Post of signs notifying the public that no cash is kept on the premises and that cameras are monitoring the facility.
    • Utilize surveillance measures, such as cameras and mirrors, to provide information as to what is going on outside and inside the workplace and to dissuade criminal activity.
    • Install security surveillance cameras in and around the workplace.

• • Provide workplace violence systems, such as door locks, violence windows, physical barriers, emergency alarms if applicable.
  • Ensure the adequacy of workplace violence systems
  • Post emergency telephone numbers for law enforcement, fire, and medical services
  • Control, access to, and freedom of movement within, the workplace by non-employees, include recently discharged employees or persons with whom one of our employees is having a dispute.
  • Install effective systems to warn others of a violence danger or to summon assistance, e.g., alarms or panic buttons.
  • Ensure employees have access to a telephone with an outside line. Provide employee training/re-training(refreshers) on the WVPP, which could include but not limited to the following:
    • Recognizing and handling threatening or hostile situations that may lead to violent acts by persons who are service recipients of our establishment.
    • Ensure that all reports of violent acts, threats of physical violence, verbal abuse, property damage or other signs of strain or pressure in the workplace are handled effectively by management and that the person making the report is not subject to retaliation by the person making the threat.
    • Improve how well our establishment’s management and employees communicate with each other.
    • Procedures for reporting suspicious persons, activities, and packages.
    • Provide/review employee, supervisor, and management training on emergency action
  • Ensure adequate employee escape
  • Increase awareness by employees, supervisors, and managers of the warning signs of potential workplace violence by requiring annual and new start training.
  • Ensure that employee disciplinary and discharge procedures address the potential for workplace violence by requiring annual and new start training.
  • Ensure that employees are aware of our weapon free workplace policy.

PROCEDURES FOR POST INCIDENT RESPONSE AND INVESTIGATION

After a workplace incident, the WVPP administrator or their designee will implement the following post-incident procedures:

• Visit the scene of an incident as soon as safe and practicable.
• Interview involved parties, such as employees, witnesses, law enforcement, and/or security personnel
• Review security footage of existing security cameras if applicable.
• Examine the workplace for security risk factors associated with the incident, including any previous reports of inappropriate behavior by the perpetrator.
• Determine the cause of the incident.
• Take corrective action to prevent similar incidents from occurring.
• Record the findings and take corrective actions if necessary.
• Obtain any reports completed by law enforcement.
• The violent incident log will be used for every workplace violence incident and will include information, such as: [See attached Violent Incident Log]
  • The date, time, and location of the incident.
  • The workplace violence type or types involved in the incident.
  • A detailed description of the incident.
  • A classification of who committed the violence, including whether the perpetrator was a client or customer, family or friend of a client or customer, stranger with criminal intent, coworker, supervisor or manager, partner or spouse, parent or relative, or other perpetrator.
  • A classification of circumstances at the time of the incident, including, but not limited to, whether the employee was completing usual job duties, working in poorly lit areas, rushed, working during a low staffing level, isolated or alone, unable to get help or assistance, working in a community setting, or working in an unfamiliar or new location.
  • A classification of where the incident occurred, such as in the workplace, parking lot or other area outside the workplace, or other area.
  • The type of incident, including, but not limited to, whether it involved any of the following:
    • Physical attack without a weapon, including, but not limited to, biting, choking, grabbing, hair pulling, kicking, punching, slapping, pushing, pulling, scratching, or spitting.
    • Attack with a weapon or object, including, but not limited to, a firearm, knife, or other object.
    • Threat of physical force or threat of the use of a weapon or other object.
    • Sexual assault or threat, including, but not limited to, rape, attempted rape, physical display, or unwanted verbal or physical sexual contact.
    • Animal attack.
    • Other.
  • Consequences of the incident, including, but not limited to:
    • Whether security or law enforcement was contacted and their response.
    • Actions taken to protect employees from a continuing threat or from any other hazards identified as a result of the incident.
    • Information about the person completing the log, including their name, job title, and the date completed.
• Reviewing all previous incidents.
• If the scene of the incident is at a host employer, Malone Workforce Solutions will work with the host employer to obtain all necessary information relating to the incident.
• Support and resources, such as counseling services, are provided to affected employees using our employee resource advisor by calling 888-209-7840.

Ensure that no personal identifying information is recorded or documented in the written investigation report. This includes information which would reveal identification of any person involved in a violent incident, such as the person’s name, address, electronic mail address, telephone number, social security number, or other information that, alone or in combination with other publicly available information, reveals the person’s identity.

TRAINING AND INSTRUCTION

All employees, including managers and supervisors, will have training and instruction on general and job-specific workplace violence practices. These sessions could involve presentations, discussions, and practical exercises. Training and instruction will be provided as follows:

• When the WVPP is first
• Annually to monitor compliance with the plan.
• Whenever a new or previously unrecognized workplace violence hazard has been identified and when changes are made to the plan. The additional training may be limited to addressing the new workplace violence hazard or changes to the plan.

Malone Workforce Solutions will provide its employees with training and instruction on the definitions found on page 1 of this plan and the requirements listed below:

• The employer’s WVPP, how to obtain a copy of the employer’s plan at no cost, and how to participate in development and implementation of the employer’s plan.
• How to report workplace violence incidents or concerns to the employer or law enforcement without fear of reprisal.
• Workplace violence hazards specific to the employees’ jobs, the corrective measures Malone Workforce Solutions has implemented, how to seek assistance to prevent or respond to violence, and strategies to avoid physical harm.
• The violent incident log and how to obtain copies of records pertaining to hazard identification, evaluation and correction, training records, and violent incident logs.
• Opportunities Malone Workforce Solutions has for interactive questions and answers with a person knowledgeable about the Malone Workforce Solutions plan.
• Strategies to avoid/prevent workplace violence and physical harm, such as:
  • How to recognize workplace violence hazards including the risk factors associated with the four types of workplace violence.
  • Ways to defuse hostile or threatening
• How to recognize alerts, alarms, or other warnings about emergency conditions and how to use identified escape routes or locations for sheltering.
• Employee routes of
• Emergency medical care provided in the event of any violent act upon an employee
• Post-event trauma counseling for employees desiring such

EMPLOYEE ACCESS TO THE WRITTEN WVPP

Malone Workforce Solutions ensures that the WVPP plan shall be in writing and shall be available and easily accessible to employees, authorized employee representatives, and representatives of Cal/OSHA at all times. This will be accomplished by storing electronically and giving access to supervisors and managers.

• Whenever an employee or designated representative requests a copy of the written WVPP, we will provide the requester with a printed copy of the WVPP, unless the employee or designated representative agrees to receive an electronic copy.
• We will provide unobstructed access through a company server or website, which allows an employee to review, print, and email the current version of the written WVPP. LINK

RECORDKEEPING

Malone Workforce Solutions will:

• Create and maintain records of workplace violence hazard identification, evaluation, and correction, for a minimum of five (5) years.
• Create and maintain training records for a minimum of one (1) year and include the following:
  • Training dates.
  • Contents or a summary of the training sessions.
  • Names and job titles of all persons attending the training sessions.
• Maintain violent incident logs for minimum of five (5) years.
• Maintain records of workplace violence incident investigations for a minimum of five (5) years.
  • The records shall not contain medical information per subdivision (j) of section 56.05 of the Civil Code.
• All records of workplace violence hazard identification, evaluation, and correction; training, incident logs and workplace violence incident investigations required by LC section 6401.9(f), shall be made available to Cal/OSHA upon request for examination and copying.

EMPLOYEE ACCESS TO RECORDS

The following records shall be made available to employees and their representatives, upon request and without cost, for examination and copying within 15 calendar days of a request:

• Records of workplace violence hazard identification, evaluation, and correction.
• Training records.
• Violent incident logs.

REVIEW AND REVISION OF THE WVPP

The Malone Workforce Solutions WVPP will be reviewed for effectiveness:

• At least annually.
• When a deficiency is observed or becomes apparent.
• After a workplace violence incident.
• As needed.

Review and revision of the WVPP will include the procedures listed in the EMPLOYEE ACTIVE INVOLVEMENT section of this WVPP, as well as the following procedures to obtain the active involvement of employees and authorized employee representatives in reviewing the plan’s effectiveness:

• Review of Malone Workforce Solutions’ WVPP should include, but is not limited to:
  • Review of incident investigations and the violent incident log.
  • Assessment of the effectiveness of security systems, including alarms, emergency response, and security personnel availability (if applicable).
• Review that violence risks are being properly identified, evaluated, and corrected. Any necessary revisions are made promptly and communicated to all employees. [These revisions could involve changes to procedures, updates to contact information, and additions to training materials.]

EMPLOYER REPORTING RESPONSIBILITIES

As required by California Code of Regulations (CCR), Title 8, Section 342(a). Reporting Work-Connected Fatalities and Serious Injuries, Malone Workforce Solutions will immediately report to Cal/OSHA any serious injury or illness (as defined by CCR, Title 8, Section 330(h)), or death (including any due to Workplace Violence) of an employee occurring in a place of employment or in connection with any employment.  If the injury or death of a Malone Workforce Solutions employee occurs at a host employer, Malone Workforce Solutions will report to Cal/OSHA or confirm in writing that the host employer has contacted on our behalf.

 I, Dawn Meyers, CEO of Malone Workforce Solutions, hereby authorize and ensure, the establishment, implementation, and maintenance of this written workplace violence prevention plan and the documents/forms within this written plan. I believe that these policies and procedures will bring positive changes to the workflow, business operations, and overall health and safety as it relates to workplace violence prevention.

Violent Incident Log

This log must be used for every workplace violence incident that occurs in our workplace.  If the incident occurs at a host employer, Malone Workforce Solutions will require host location to provide us with a copy of the incident log. At a minimum, it will include the information required by LC section 6401.9(d).

The information that is recorded will be based on:

• Information provided by the employees who experienced the incident of violence.
• Witness statements.
• All other investigation findings.

All information that personally identifies the individual(s) involve will be omitted from this log, such as:

• Names
• Addresses – physical and electronic
• Telephone numbers
• Social security number

Enter the date the incident occurred (Day, Month, Year)

Enter the time (or approximate time) that the incident occurred a.m./p.m.

Check which of the following describes the type(s) of incident, and explain in detail:

Note: It’s important to understand that “Workplace Violence Type” and “Type of Incident” have separate requirements. For this part of the log, “Type of Incident” specifically refers to the nature or characteristics of the incident being logged. It does not refer to the type of workplace violence.

• Physical attack without a weapon, including, but not limited to, biting, choking, grabbing, hair pulling, kicking, punching, slapping, pushing, pulling, scratching, or spitting.
• Attack with a weapon or object, including, but not limited to, a firearm, knife, or other object.
• Threat of physical force or threat of the use of a weapon or other object.
• Sexual assault or threat, including, but not limited to, rape, attempted rape, physical display, or unwanted verbal or physical sexual contact.
• Animal attack.
• Other.

Explain: Provide a detailed description of the incident and any additional information on the violence incident type and what it included. Continue on separate sheet of paper if necessary.

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Workplace violence committed by: [For confidentiality, only include the classification of who committed the violence, including whether the perpetrator was a client or customer, family or friend of a client or customer, stranger with criminal intent, coworker, supervisor or manager, partner or spouse, parent or relative, or other perpetrator.]

Circumstances at the time of the incident: [write/type what was happening at the time of the incident, including, but not limited to, whether the employee was completing usual job duties, working in poorly lit areas, rushed, working during a low staffing level, isolated or alone, unable to get help or assistance, working in a community setting, or working in an unfamiliar or new location.]

Where the incident occurred: [Where the incident occurred, such as in the workplace, parking lot or other area outside the workplace, or other area.]

Consequences of the incident, including, but not limited to:

• Whether security or law enforcement was contacted and their response.
• Actions taken to protect employees from a continuing threat or from any other hazards identified as a result of the incident.

[Include information on what the consequences of the incident were.]

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• Were there any injuries? Yes or No. Please explain:

[Indicate here if there were any injuries, if so, provide description of the injuries

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• Were emergency medical responders other than law enforcement contacted, such as a Fire Department, Paramedics, On-site First-aid certified personnel? Yes or No. If yes, explain below:

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Did the severity of the injuries require reporting to Cal/OSHA?  If yes, document the date and time this was done, along with the name of the Cal/OSHA representative contacted.

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A copy of this violent incident log needs to be provided to the employer. Indicate when it was provided and to whom.

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This violent incident log was completed by:

[Name of person completing this log], [Job Title of person completing this log], [Date this log was completed]

[Signature of person completing this log]                                                                               [Date of completion]