HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT OF 1996 (HIPAA)

Your employer is committed to maintaining the privacy of protected health information for participants in the Plan in compliance with the privacy rules under the Health Insurance Portability and Accountability Act (HIPAA). This is a reminder that in compliance with HIPAA, the Plan’s Notice of Privacy Practices is available to employees upon request. This Notice of Privacy Practices explains participants’ rights and the Plan’s legal duties with respect to protected health information (PHI) and how the Plan may use and disclose PHI. To obtain a copy or view the Notice of Privacy Practices, or for further information regarding the issues covered by this Notice, please contact the Plan Administrator.

NOTICE REGARDING WELLNESS PROGRAM
The Pernod Ricard USA wellness incentive offering is a voluntary wellness program available to all employees who are enrolled in a HDHP medical plan option offered by Pernod Ricard USA. The program is administered according to federal rules permitting employer-sponsored wellness programs that seek to improve employee health or prevent disease, including the Americans with Disabilities Act of 1990, the Genetic Information Nondiscrimination Act of 2008, and the Health Insurance Portability and Accountability Act, as applicable, among others. If you choose to participate in the wellness program you will be asked to complete a voluntary health risk assessment or “HRA” that asks a series of questions about your health-related activities and behaviors and whether you have or had certain medical conditions (e.g., cancer, diabetes, or heart disease). You are not required to complete the HRA or other medical examinations. However, employees who choose to participate in the wellness program will receive an incentive of $100 deposited into a Health Savings Account for the completion of a health risk assessment (HRA). Although you are not required to complete the HRA or participate in the biometric screening, only employees who do so will receive a $100 deposit into a Health Savings Account. Additional incentive of $100 (deposited into a Health Savings Account) is available for employees who participate in certain health-related activities such as enrolling in a disease management program or going to a well adult visit. If you are unable to participate in any of the health-related activities required to earn an incentive, you may be entitled to a reasonable accommodation or an alternative standard. You may request a reasonable accommodation or an alternative standard by contacting PRUSA Benefits at PRUSABenefits@pernod-ricard.com. The information from your HRA will be used to provide you with information to help you understand your current health and potential risks, and may also be used to offer you services through the wellness program, such as enrollment in a disease management program. You also are encouraged to share your results or concerns with your own doctor.

PROTECTIONS FROM DISCLOSURE OF MEDICAL INFORMATION
We are required by law to maintain the privacy and security of your personally identifiable health information. Although the wellness program and Pernod Ricard USA may use aggregate information it collects to design a program based on identified health risks in the workplace, Aetna will never disclose any of your personal information either publicly or to the employer, except as necessary to respond to a request from you for a reasonable accommodation needed to participate in the wellness program, or as expressly permitted by law. Medical information that personally identifies you that is provided in connection with the wellness program will not be provided to your supervisors or managers and may never be used to make decisions regarding your employment. Your health information will not be sold, exchanged, transferred, or otherwise disclosed except to the extent permitted by law to carry out specific activities related to the wellness program, and you will not be asked or required to waive the confidentiality of your health information as a condition of participating in the wellness program or receiving an incentive. Anyone who receives your information for purposes of providing you services as part of the wellness program will abide by the same confidentiality requirements. The only individual(s) who will receive your personally identifiable health information is (are) [indicate who will receive information such as “a registered nurse,” “a doctor,” or “a health coach”] in order to provide you with services under the wellness program. In addition, all medical information obtained through the wellness assessment and activities will be maintained separate from your personnel records, information stored electronically will be encrypted, and no information you provide as part of the wellness program will be used in making any employment decision. precautions will be taken to avoid any data breach, and in the event a data breach occurs involving information you provide in connection with the wellness program, we will notify you immediately. You may not be discriminated against in employment because of the medical information you provide as part of participating in the wellness program, nor may you be subjected to retaliation if you choose not to participate. If you have questions or concerns regarding this notice, or about protections against discrimination and retaliation, please contact PRUSA Benefits at PRUSABenefits@pernod-ricard.com.

WOMEN’S HEALTH AND CANCER RIGHTS ACT (WHCRA)
The Women’s Health and Cancer Rights Act (WHCRA) requires group health plans and health insurance issuers which provide coverage for medical and surgical benefits with respect to mastectomies to cover all stages of reconstruction and surgery to achieve symmetry between the breasts, prostheses, and complications resulting from a mastectomy, including lymphedema. Please contact your medical plan vendor or benefit team member for more information.

SPECIAL ENROLLMENT PERIODS

CONSOLIDATED OMNIBUS BUDGET RECONCILIATION ACT (COBRA)
The Consolidated Omnibus Budget Reconciliation Act (COBRA) gives workers and their families who lose their health benefits the right to choose to continue group health benefits provided by their group health plan for limited periods of time under certain circumstances.

NEWBORNS’ AND MOTHERS’ HEALTH PROTECTION ACT (NEWBORNS’ ACT) The Newborns’ and Mothers’ Health Protection Act (Newborns’ Act) requires group health plans which offer maternity coverage to pay for at least a 48-hour hospital stay following childbirth (96hour stay in the case of Cesarean section).

CLAIMS PROCEDURES AND APPEALS
Federal law requires your health care provider to offer a process for filing claims for services and supplies that are urgent in nature in addition to procedures for post-service claims.

PATIENT PROTECTION NOTICES
If the Plan provides for or requires the designation of a primary care provider, you have the right to designate any primary care provider who participates in our network and who is available to accept you or your family members. For information on how to select a primary care provider, and for a list of the participating primary care providers, contact the medical plan vendor. For children, you may designate a pediatrician as the primary care provider. You do not need prior authorization from the Plan or from any other person (including a primary care provider) in order to obtain access to a health care professional in our network who specializes in obstetrics or gynecology. The health care professional, however, may be required to comply with certain procedures, including obtaining prior authorization for certain services, following a pre-approved treatment plan, or procedures for making referrals. For a list of participating health care professionals who specialize in obstetrics or gynecology, contact the medical plan vendor.