Effective Date: October 15, 2026 Version: 1.0 Applies to: All Company employees.
Article 1: Introduction and Scope
1.1 This document states what the Company does when an incident is reported: how a report is received and graded, who responds and in what order, what the response must accomplish, and what record the response creates. The Employee's duty to report an incident is stated in the Employee Code of Conduct; this document governs the Company's response once a report is made, and the duties of each role in that response.
1.2 This document governs the response to an incident in a workplace, in a service, and in a Company System, including an injury to a person, an injury or medical distress of an animal, property damage, a security event, and a suspected disclosure of data. Clinical incidents in veterinary services are also governed by the Clinical Incident Reporting Policy, and a suspected breach of personal data is also governed by the Data Breach Notification; where such a document states a further duty, that duty applies in addition to this document.
1.3 If a provision of this document conflicts with the Terms of Use, this document controls for the subject it governs. If a provision conflicts with the terms of a program in which the Employee participates, the program terms control for that program. Help pages explain this document; they do not amend it.
Article 2: Definitions
2.1 The definitions in the Employee Code of Conduct are incorporated into this document by reference. This article defines only the additional terms used in this document, in alphabetical order.
2.2 Incident: an event that causes, or credibly threatens, harm to a person, to an animal, to property, to data, or to the operation of the business, including a near-miss.
2.3 Incident Record: the record of an Incident created under Article 6, comprising the report, the severity assigned, the response taken, and the closure.
2.4 Severity: the grade assigned to an Incident under Article 4: Low, Medium, High, or Critical.
Article 3: The Duty to Report and Immediate Safety
3.1 An Employee who experiences or observes an Incident shall report it promptly to the Employee's Manager and, where the incident system provides a report form, shall file the report. The report states the facts in order: what happened, when, who and what was involved, the severity the Employee assigns under Article 4, and the action already taken. A report made in the incident system is recorded with the reporter's identity and the time of the report, and is linked to the appointment or record the Incident concerns where one exists.
3.2 Safety comes before the record. Where an animal is in medical distress, a person is injured, or a danger is continuing, the Employee shall stop the work, secure the animal, the person, and the area, and obtain assistance, including emergency services where the event requires them, before filing any report. The response to an animal in care is governed by the Pet Safety and Handling.
3.3 A report does not replace a conversation. For an Incident graded Medium or higher, the Employee shall also inform the Manager directly and immediately, so that the response begins on the conversation and is confirmed by the record. An Employee shall not file an Incident report for a routine difficulty that involves no harm and no credible threat of harm; such a matter is raised with the Manager or by support ticket under the Acceptable Use of Admin Tools Policy.
3.4 Where an Incident involves suspected misconduct, fraud, or a violation of law, the report is made through the channel the Whistleblower and Internal Reporting Policy provides, and the protections of that policy apply to the reporter. An Incident report under this document does not remove that protection where the same event is reported under both documents.
Article 4: Severity
4.1 Severity is assigned on the facts of the event, not on the outcome hoped for (a) Low: minor, handled on the spot, with no ongoing risk; for example a small clipper nick with no bleeding, or minor property damage;
(b) Medium: harm or risk that required real attention and was resolved; for example a bite that broke skin without requiring medical care, or a pet that panicked and was calmed;
(c) High: significant harm or risk; for example an injury that requires veterinary or medical treatment, or a serious confrontation with a customer; and
(d) Critical: the gravest grade; for example an animal in medical distress, a severe bite, an event involving emergency services, or a suspected compromise of credentials or disclosure of customer or payment data at any scale.
4.2 Severity drives who is notified and how fast the response proceeds. The Employee who reports shall assign the severity the facts support; understating severity to reduce the response is a violation of this document. The Manager who receives the report may raise the severity, and shall record the change and the reason in the Incident Record; severity is not lowered during the response except on facts that show the original grade was mistaken.
Article 5: The Response
5.1 On receipt of a report, the Manager shall: (a) confirm that immediate safety measures under Article 3 are complete; (b) grade or confirm the Severity; (c) notify the persons the Severity requires, which for High and Critical Incidents includes the manager above the Manager and, where data, a credential, or legal process is involved, notice to legal@aapawz.com; (d) assign the response to a named Employee; and (e) open the Incident Record.
5.2 The response shall, in order: contain the Incident, so that the harm does not continue or extend; establish the facts, from the report, the records the business keeps, and the accounts of the persons involved; remedy the harm so far as remedy is possible, including notice to a customer whose animal, property, or data is affected, as the governing document for the subject provides; and identify the change that prevents recurrence, which may be a change to a procedure, to training under the Training and Certification Policy, to access under the Data Access and Least Privilege Policy, or to a Company System.
5.3 For a security Incident: a suspected compromised credential, unauthorized access, or disclosure of data: the response includes the steps the Authentication Controls Policy and the Information Security Policy state: sessions are ended, credentials are reset, access is reviewed, and the audit log is preserved and examined under the Record Keeping and Audit Policy. Where the Incident is a suspected breach of personal data, the duties in the Data Breach Notification apply and the response under this document is coordinated with them.
5.4 The Employee who reported the Incident, and every Employee whose duties the response touches, shall cooperate with the response, shall preserve every record that relates to the Incident, and shall not alter, delete, or reconstruct such a record. A failure to cooperate, and any alteration of a record after an Incident, is a violation of this document independent of the Incident itself.
5.5 The Manager shall close the Incident when the steps in clause 5.2 are complete, and shall record the closure, the remedy given, and the preventive change made or the reason no change was made. An Incident graded Critical is closed only by the manager above the responding Manager, on the completed Incident Record.
Article 6: The Incident Record
6.1 The Incident Record is a Company record, kept under the Record Keeping and Audit Policy and retained for the periods the Regulatory Record Retention states. The contents of an Incident Record are Confidential Information under the Confidentiality and Non-Disclosure Policy, and access to Incident Records is limited to the persons whose duties require it.
6.2 The Employee who filed a report may see the reports the Employee filed. No Employee may edit another Employee's report or alter an Incident Record after closure; a correction is made as the Record Keeping and Audit Policy provides, so that the original and the correction both remain visible.
Article 7: Liability
7.1 The Employee is responsible for the Employee's own conduct and shall bear the loss that the Employee's violation of this document causes, to the extent permitted by applicable law. Nothing in this document makes the Company responsible for a loss caused by an act taken in violation of this document or outside the scope of employment, and nothing in this document transfers to a reporting Employee the responsibility for an Incident the Employee reported but did not cause.
7.2 To the fullest extent permitted by law, neither party is liable to the other for indirect, incidental, special, punitive, or consequential damages, or for lost profits, lost revenue, or loss of goodwill, arising out of or relating to this document, even if the party has been advised of the possibility of those damages.
7.3 To the fullest extent permitted by law, the Company's total liability arising out of or relating to this document shall not exceed one hundred dollars ($100). This clause does not limit (a) wages, commissions, benefits, or other compensation owed under applicable law or a written agreement; (b) benefits, including workers' compensation benefits, that applicable law provides; (c) indemnification obligations under this document; (d) liability for fraud or willful misconduct; or (e) liability that cannot be limited under applicable law.
7.4 The parties agree that this article allocates risk between them, that it is an essential part of the basis of their bargain, and that it applies even if a limited remedy fails of its essential purpose.
Article 8: Indemnification
8.1 The Company shall indemnify, defend, and hold harmless the Employee from and against a claim, loss, liability, judgment, settlement, cost, and expense (including reasonable attorneys' fees) brought by a third party and arising out of an act the Employee took within the scope of employment and in compliance with this document and applicable law, including an act taken in the response to an Incident under Article 5.
8.2 The Company does not indemnify an Employee for the Employee's own unlawful acts. No indemnification is owed under this article for a claim arising out of (a) the Employee's willful misconduct or fraud; (b) an act outside the scope of employment; or (c) an act taken in violation of this document.
8.3 The Employee shall indemnify, defend, and hold harmless the Company and its members, managers, employees, and agents from and against every claim, loss, liability, judgment, settlement, cost, and expense (including reasonable attorneys' fees) arising out of (a) the Employee's breach of this document; (b) the Employee's violation of any law or of the rights of any person; and (c) an act outside the scope of employment.
8.4 The party seeking indemnification shall give prompt written notice of a claim under this article. The indemnifying party shall control the defense with counsel reasonably acceptable to the other party; the indemnified party may participate at its own expense. The indemnifying party shall not settle a claim in a manner that imposes an obligation on the other party, or that does not release the other party fully, without the other party's prior written consent. This article survives the end of employment.
Article 9: Enforcement and Appeals
9.1 The Company may investigate any suspected violation of this document. The Employee shall cooperate with an investigation and shall produce the records this document requires the Employee to keep.
9.2 If the Company determines that the Employee has violated this document, the Company shall give written notice stating the provision violated and the facts relied on, except where notice would compromise an investigation of fraud, a safety risk, or a legal obligation. The Employee may submit a written response within ten (10) business days, and the person deciding the matter shall consider the response before a measure is imposed. Where a violation is capable of cure, the Employee has ten (10) business days from notice to cure it and to confirm the cure in writing; no cure period applies to fraud, a safety risk, an unlawful failure to report, or a violation that cannot be cured.
9.3 If a violation is established, the Company may, proportionate to the violation: (a) issue a written warning; (b) require retraining; (c) restrict or withdraw access or a Grant; (d) place the Employee on a written improvement plan; (e) suspend the Employee's employment; (f) terminate the Employee's employment; and (g) exercise any other right or remedy available at law. A failure to report an Incident, the understatement of Severity, and the alteration of a record after an Incident are serious violations for the purposes of this article.
9.4 The Employee may appeal a measure under this article in writing to legal@aapawz.com within thirty (30) days of the measure, stating the grounds and attaching the records relied on. The appeal is decided by a person who did not make the original decision, and the Company's decision on appeal is final. A measure remains in effect during an appeal unless the Company directs otherwise in writing.
9.5 No measure under this article may be imposed in retaliation for a report made in good faith under this document or under the Whistleblower and Internal Reporting Policy, or for the exercise of a right protected by applicable law. A good-faith report that proves mistaken is not a violation of this document. The Company's delay in acting on a violation is not a waiver of the violation or of any later violation of the same kind.
Article 10: Term and Termination
10.1 This document applies from the commencement of employment until the employment ends for any reason. The duty to preserve records relating to an Incident, and to cooperate with a response that is open at separation, survives separation until the Incident is closed.
10.2 On the end of employment, Articles 7, 8, 9 (for measures taken before the employment ended), 11, and 12 survive. The end of employment and of access is governed by the Termination and Offboarding Policy.
Article 11: Dispute Resolution
11.1 Any dispute arising out of or relating to this document, or to the relationship it governs, is governed by the Dispute Resolution Policy, which is incorporated into this document by reference.
11.2 Nothing in this document limits an Employee's right to file a charge or complaint with a government agency, to participate in an agency proceeding, or to engage in concerted activity protected by applicable law, and no provision of this document requires the Employee to give notice of, or to obtain consent to, the exercise of such a right.
Article 12: General Provisions
12.1 The Company may amend this document by posting the amended document in the Document Center and giving notice to the Employee at the email address in the Employee's employment record. An amendment that materially increases the Employee's obligations takes effect thirty (30) days after notice; other amendments take effect on posting.
12.2 Legal notices under this document shall be sent to legal@aapawz.com; operational notices and all other communications shall be sent to support@aapawz.com. A notice to the Company is effective when the Company acknowledges receipt or, for email, one business day after sending, whichever is earlier. Notices to the Employee are effective when sent to the email address in the Employee's employment record or posted in the employee portal, whichever occurs first. The Employee shall keep that email address current. Notices under the DMCA and Copyright Policy are given as provided in that policy, to the designated agent at legal@aapawz.com.
12.3 This document is governed by the laws of the State of Tennessee, without regard to its conflict-of-laws rules. Subject to the Dispute Resolution Policy, any proceeding arising out of this document shall be brought in the state or federal courts located in Shelby County, Tennessee, and the parties consent to personal jurisdiction there.
12.4 If any provision of this document is held unenforceable, the provision shall be enforced to the fullest extent permitted, and the remaining provisions continue in full effect.
12.5 This document, together with the documents it incorporates by reference, is the entire agreement between the Company and the Employee for the subject it governs and supersedes every prior statement or agreement on that subject. This clause does not supersede an offer letter or a written employment agreement signed by the Company.
12.6 The Employee shall not assign this document or any right or obligation under it, and an assignment without the Company's prior written consent is void. The Company may assign this document to an affiliate or in connection with a sale of all or part of its business, on notice to the Employee. A waiver of any provision of this document is effective only in writing and only for the instance stated; no waiver is a waiver of any other provision or instance.
12.7 Headings are for convenience only. "Including" means "including without limitation." This document shall not be construed against a party on the ground that the party prepared this document. The English-language text controls over any translation.
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