above; consent may also be obtained through a standalone release form or as part of employee onboarding. Employees cannot withdraw consent for the use of NIL for materials, including digital materials, which have already been distributed or published. Upon withdrawal of consent in writing, AIM will make reasonable efforts to cease future use in new materials. However, previously distributed or archived content may not be withdrawn.

AIM will use NIL in a respectful and professional manner. NIL will not be used in any context that could be defamatory, misleading, or inconsistent with the values of the agency. This policy is intended to comply with all applicable local, state, and federal laws regarding privacy and publicity rights.

Violations of this policy may result in disciplinary action, up to and including termination of employment, and may also expose the Company to legal liability.

AIM Services, Inc. is committed to preventing abuse and neglect of the people we support. An employee who has reasonable cause to suspect abuse or neglect must first address any immediate danger and then make all required reports immediately to the appropriate internal and external contacts, including the employee’s supervisor, AIM On-Call, and, when applicable, the Justice Center. Employees must follow the reporting timeframes and procedures in AIM policy and OPWDD Part 624. Failure to make a required report may result in disciplinary action, up to and including termination, and may also result in civil or criminal liability.

Reasonable Cause means that, based on your observations, training and experience, you have a suspicion that a vulnerable person has been subject to abuse or neglect as described below. Significant incidents that may place a vulnerable person at risk of harm must also be reported. Reasonable cause can be as simple as doubting the explanation given for an injury.

AIM Services, Inc. promotes a positive environment while protecting the people we support, employees, and volunteers. Any inappropriate physical contact by employees or volunteers toward the people we serve will result in disciplinary action up to and including termination. Inappropriate physical contact is strictly prohibited whether an employee is at work or “off the clock.”

Examples of inappropriate physical contact include, but are not limited to kissing, wrestling, any form of sexual contact, displays of inappropriate affection, and any contact with genitals or other private areas that are outside of the documented plan of care.

Employees and volunteers are prohibited from speaking to a person they support in a way that is, or could be construed, as harsh, coercive, threatening, intimidating, shaming, derogatory, demeaning, or humiliating. Employees and volunteers must not initiate sexually oriented conversations (excluding sexual education, as described in someone’s support plans) with the people they support. Employees and volunteers are not permitted to discuss their own sexual activities with people served by AIM. Inappropriate verbal interactions are strictly prohibited whether an employee is at work or “off the clock.”

One-on-one interactions are a routine part of the supports and services AIM provides. Employees and volunteers must follow all AIM policies and person-specific guidance governing physical contact, communication, privacy, supervision, and professional boundaries. They must immediately document