SHADOWSOURCE LLC

COMMUNITY & SAFETY POLICY

Effective Date: September 7, 2026
Last Updated: September 7, 2026

ShadowSource is committed to creating a professional, respectful, and safe community for students, healthcare providers, and the patients and organizations they interact with.

Shadowing is a unique experience because it brings students into real healthcare environments. Maintaining trust requires every member of the ShadowSource community to understand their responsibilities and conduct themselves appropriately.

This Community & Safety Policy (“Policy”) establishes the standards expected of all ShadowSource users and describes how ShadowSource responds to safety concerns, complaints, and violations.

This Policy supplements the ShadowSource Terms of Use, Privacy Policy, and Student Shadowing Agreement.

1. OUR COMMUNITY STANDARD

ShadowSource expects every member of the community to:

• Treat others with dignity and respect;
• Act professionally;
• Respect personal and professional boundaries;
• Protect patient privacy and confidentiality;
• Follow applicable healthcare-facility policies;
• Communicate honestly and respectfully;
• Respect the authority of healthcare providers and facilities during shadowing experiences;
• Put patient safety and privacy first; and
• Report serious concerns promptly.

Our goal is to create an environment where students can learn, providers can mentor, and patients can receive care without unnecessary disruption or risk.

2. WHO THIS POLICY APPLIES TO

This Policy applies to:

• Students;
• Physicians;
• Physician assistants (PAs);
• Nurse practitioners (NPs);
• ShadowSource administrators and representatives; and
• Other individuals authorized to use the ShadowSource Platform.

The Policy applies to conduct:

• On the ShadowSource Platform;
• During a ShadowSource-arranged shadowing experience;
• During communications between ShadowSource users;
• In connection with ShadowSource-related activities; and
• Outside the Platform when the conduct is reasonably related to the safety, integrity, or reputation of the ShadowSource community.

3. PROFESSIONAL CONDUCT

Users must communicate and behave professionally.

Prohibited conduct includes:

• Harassment;
• Bullying;
• Threats;
• Intimidation;
• Discrimination;
• Hate-based conduct;
• Sexual harassment;
• Unwanted sexual attention;
• Sexual misconduct;
• Unwanted physical contact;
• Stalking;
• Retaliation against a person who makes a good-faith report;
• Deliberately humiliating or degrading another person;
• Repeatedly contacting someone after they have asked you to stop;
• Aggressive or threatening communications; and
• Other conduct that ShadowSource reasonably determines is abusive, unsafe, or inappropriate.

ShadowSource may take action even if conduct does not constitute a criminal offense or violate a specific law.

4. ZERO TOLERANCE FOR SERIOUS MISCONDUCT

ShadowSource may permanently remove a user from the Platform for serious misconduct.

Examples include:

• Violence or threats of violence;
• Sexual assault or sexual misconduct;
• Exploitation of another user;
• Stalking;
• Credible threats to personal safety;
• Serious harassment;
• Deliberate disclosure of confidential patient information;
• Unauthorized access to patient records;
• Fraud or identity deception;
• Impersonating a healthcare professional;
• Providing unauthorized patient care;
• Serious violations of healthcare-facility policies;
• Retaliation against a person who reports misconduct; or
• Other conduct that ShadowSource determines presents a significant risk to users, patients, healthcare organizations, or the Platform.

ShadowSource may permanently remove a user even when the conduct occurs outside the Platform if ShadowSource reasonably determines that continued participation would create a safety or integrity concern.

5. PATIENT SAFETY AND PRIVACY

Patients are not ShadowSource users, but their safety, privacy, dignity, and autonomy are fundamental to the ShadowSource community.

Students must:

• Respect every patient’s right to privacy;
• Respect a patient’s decision to permit or decline observation;
• Leave immediately when requested by a patient or Provider;
• Maintain confidentiality;
• Avoid unnecessary patient interaction;
• Never represent themselves as healthcare professionals;
• Never provide patient care unless separately and lawfully authorized outside the ShadowSource experience; and
• Follow all Provider and healthcare-facility requirements.

Students must never:

• Access a patient’s medical record without authorization;
• Photograph or record patients;
• Photograph medical records or computer screens;
• Record clinical encounters;
• Share patient information on social media;
• Use patient information for personal purposes;
• Contact patients outside the clinical setting;
• Enter patient-identifying information into ShadowSource; or
• Use ShadowSource to store or transmit protected health information (PHI).

Providers are responsible for determining and obtaining any patient authorization or consent required for a Student to observe a clinical encounter.

A patient may decline observation or withdraw permission at any time.

6. SHADOWING IS OBSERVATIONAL

ShadowSource shadowing experiences are intended to be observational.

Students may not independently:

• Diagnose patients;
• Treat patients;
• Perform examinations;
• Take medical histories;
• Administer medications;
• Perform procedures;
• Provide medical advice;
• Document patient information;
• Enter information into an electronic health record;
• Make clinical decisions; or
• Perform other clinical tasks unless separately authorized under an arrangement that is outside the scope of the ShadowSource shadowing experience.

Providers may establish additional restrictions.

If there is uncertainty about whether an activity is appropriate, the Student should not perform the activity and should ask the Provider.

7. PERSONAL BOUNDARIES

ShadowSource users are expected to maintain appropriate personal and professional boundaries.

Users must not:

• Pressure another person into unwanted contact;
• Pursue romantic or sexual contact with another user through coercion or harassment;
• Make sexually explicit or inappropriate comments;
• Request intimate photographs;
• Share sexually explicit material;
• Repeatedly contact someone who has requested no further contact;
• Use professional access to obtain someone’s personal information;
• Attempt to establish an inappropriate relationship with a patient; or
• Exploit a power imbalance between a Provider and Student.

Users are responsible for respecting reasonable boundaries even when another person does not explicitly state that a particular interaction is unwelcome.

8. COMMUNICATIONS & MESSAGING

ShadowSource messaging is intended to facilitate legitimate communication related to shadowing, education, professional development, recruiting, and other appropriate Platform activities.

Users must not use messaging to:

• Harass or threaten another user;
• Send spam;
• Solicit inappropriate personal relationships;
• Send sexually explicit material;
• Request confidential patient information;
• Share PHI;
• Conduct fraudulent activity;
• Impersonate another person;
• Attempt to obtain another user’s account credentials;
• Circumvent ShadowSource safety measures; or
• Engage in other prohibited conduct.

ShadowSource may review, preserve, or disclose messages when reasonably necessary to address safety concerns, investigate complaints, enforce this Policy, comply with legal obligations, or protect ShadowSource or others.

9. HONESTY AND AUTHENTICITY

Users must provide truthful and accurate information when creating and maintaining a ShadowSource account.

Users may not:

• Create an account using another person’s identity;
• Impersonate another person;
• Falsify professional credentials;
• Falsify educational information;
• Falsify NPI information;
• Misrepresent professional experience;
• Submit fraudulent documents;
• Maintain multiple accounts for deceptive purposes; or
• Misrepresent their relationship with a healthcare organization.

Providers must maintain accurate professional information.

Students must maintain accurate educational information.

ShadowSource may verify information when appropriate.

10. REVIEWS AND FEEDBACK

ShadowSource encourages honest feedback after shadowing experiences.

Reviews should be:

• Truthful;
• Relevant to the shadowing experience;
• Professional;
• Based on the user’s actual experience; and
• Free of patient-identifying information.

Users must not:

• Submit knowingly false reviews;
• Threaten another user with a negative review;
• Offer compensation in exchange for a favorable review;
• Submit a review on behalf of another person;
• Attempt to manipulate the review system;
• Include PHI; or
• Use reviews to harass or retaliate against another user.

Reviews may be confidential and may be visible to the person being reviewed.

ShadowSource administrators may access review history for safety, quality, enforcement, and investigative purposes.

ShadowSource may remove or restrict reviews that violate this Policy.

11. RECOMMENDATION LETTERS

Recommendation-letter tools are intended to assist Providers in preparing professional recommendations for Students.

Users must not:

• Fabricate information about a Student;
• Pressure a Provider to provide a false recommendation;
• Alter a Provider’s recommendation without authorization;
• Sign a recommendation letter on behalf of a Provider;
• Represent an AI-generated draft as a Provider-approved recommendation; or
• Include patient-identifying information.

Providers are responsible for reviewing and approving any recommendation letter before submitting or distributing it.

Students may not represent a recommendation as having been authored or approved by a Provider when that is not the case.

12. PERSONAL INFORMATION AND PRIVACY

Users should exercise care when sharing personal information through the Platform.

Users should not request or share unnecessary:

• Home addresses;
• Personal financial information;
• Account passwords;
• Authentication codes;
• Government identification numbers;
• Patient information;
• Medical information; or
• Other sensitive personal information.

Users should never request another user’s ShadowSource password or authentication credentials.

ShadowSource will not ask users to provide their password through an unsolicited message.

13. PHI AND CONFIDENTIAL INFORMATION

ShadowSource is not intended to be used as a repository for patient information or protected health information.

Users must not enter PHI into:

• Profiles;
• Messages;
• Reviews;
• Recommendation-letter tools;
• AI prompts;
• Uploaded documents;
• Job-board postings; or
• Other Platform features.

Users must also respect confidential information belonging to Providers, healthcare organizations, employees, students, and other individuals.

If confidential information is accidentally submitted to ShadowSource, the user should report it promptly through the ShadowSource reporting process.

14. SAFETY DURING A SHADOW

Students and Providers may end a shadowing experience at any time.

Students

A Student should leave immediately if they feel:

• Unsafe;
• Threatened;
• Harassed;
• Pressured to perform inappropriate activities;
• Uncomfortable with a situation; or
• Concerned that continuing the shadow would violate this Policy or facility requirements.

Providers

A Provider may end a shadowing experience if a Student:

• Violates facility rules;
• Behaves unprofessionally;
• Creates a safety concern;
• Violates confidentiality;
• Interferes with patient care;
• Refuses to follow reasonable instructions; or
• Engages in inappropriate conduct.

Neither party is required to continue an unsafe or inappropriate experience.

Health and exposure. Students are responsible for their own health, immunizations, and insurance and are not covered by ShadowSource or, unless separately arranged, by a facility’s occupational-health or workers’-compensation programs. If a Student experiences a potential exposure or injury during a shadow (for example, an infectious exposure or a needlestick), the Student should notify the Provider and facility immediately, follow the facility’s exposure protocol, and seek appropriate medical care.

By using ShadowSource, users acknowledge the inherent risks of in-person shadowing experiences and the Assumption of Risk and Release set out in the ShadowSource Terms of Use, Student Shadowing Agreement, and Provider Shadowing Agreement.

15. REPORTING A PROBLEM

ShadowSource encourages users to report safety concerns, misconduct, privacy violations, and other policy violations promptly.

Reports may be submitted through the reporting functionality on the Platform or by contacting:

info@shadow-source.com

Whenever reasonably possible, users should report significant incidents within 24 hours.

Reports should include enough information to allow ShadowSource to understand and investigate the concern.

Where appropriate, include:

• Date and time;
• Location;
• Individuals involved;
• Description of what occurred;
• Relevant messages or documentation;
• Witness information; and
• Any immediate safety concerns.

Do not include unnecessary patient-identifying information in a report.

If patient information is necessary to communicate the nature of a concern, provide only the minimum information necessary and use the appropriate reporting channel.

16. EMERGENCIES

ShadowSource is not an emergency-response service.

If you are experiencing an immediate threat to your safety or believe someone is in immediate danger, contact the appropriate emergency services or on-site emergency personnel first.

Do not wait for ShadowSource to respond to an emergency.

After the immediate danger has been addressed, notify ShadowSource when appropriate.

17. HOW SHADOWSOURCE HANDLES REPORTS

ShadowSource takes good-faith safety reports seriously.

Depending on the circumstances, ShadowSource may:

1. Acknowledge the report;
2. Request additional information;
3. Review relevant Platform information;
4. Review applicable messages or other communications;
5. Review relevant account history;
6. Contact involved users;
7. Review relevant reviews or prior complaints;
8. Consult with appropriate third parties when necessary;
9. Temporarily restrict an account;
10. Cancel upcoming shadowing sessions;
11. Permanently remove a user; or
12. Take other reasonable action.

ShadowSource may take immediate action before completing an investigation when reasonably necessary to protect users, patients, healthcare organizations, or the Platform.

18. INVESTIGATIONS

ShadowSource may conduct investigations at its discretion.

Users may be asked to provide information relevant to an investigation.

ShadowSource may consider:

• Available evidence;
• Messages;
• Reviews;
• Reports;
• Account history;
• Information provided by involved individuals;
• Information provided by healthcare organizations;
• Applicable policies; and
• Other relevant circumstances.

ShadowSource does not guarantee that every investigation will result in a particular outcome or that all details of an investigation will be disclosed to the reporting party.

ShadowSource may limit disclosure of investigative information to protect privacy, safety, confidentiality, legal interests, or the integrity of an investigation.

19. CONFIDENTIALITY OF REPORTS

ShadowSource will make reasonable efforts to handle reports appropriately and limit disclosure to individuals who need the information to address the matter.

However, ShadowSource cannot guarantee absolute confidentiality.

Information may be disclosed when necessary to:

• Conduct an investigation;
• Protect users or patients;
• Comply with law;
• Respond to legal process;
• Enforce ShadowSource policies;
• Address a security or privacy incident; or
• Protect ShadowSource’s legal rights.

Users should not assume that a report is completely anonymous unless ShadowSource expressly states otherwise.

20. RETALIATION IS PROHIBITED

ShadowSource prohibits retaliation against a person who makes a good-faith report or participates in a ShadowSource investigation.

Retaliation may include:

• Threats;
• Harassment;
• Intimidation;
• Attempts to harm someone’s professional reputation;
• Attempts to interfere with a person’s education or employment;
• Unwanted continued contact; or
• Other adverse conduct intended to punish someone for reporting a concern.

Retaliation may result in suspension or permanent removal from ShadowSource.

21. FALSE REPORTS

ShadowSource encourages good-faith reporting.

Knowingly submitting a materially false report, fabricating evidence, or intentionally making false allegations may violate this Policy.

ShadowSource will distinguish between:

• A good-faith report that cannot be substantiated; and
• A knowingly false or intentionally fabricated report.

A report does not need to be proven correct for it to be considered a good-faith report.

22. ENFORCEMENT ACTION

ShadowSource has broad discretion to determine the appropriate response to a policy violation.

Possible actions include:

• Warning;
• Educational intervention;
• Removal of content;
• Restriction of Platform functionality;
• Cancellation of a shadowing session;
• Temporary suspension;
• Permanent account termination;
• Restriction from future shadowing opportunities; or
• Other action reasonably necessary to protect the community.

ShadowSource may consider the severity, frequency, circumstances, history, and potential impact of the conduct.

23. IMMEDIATE SUSPENSION

ShadowSource may immediately suspend or restrict an account when it reasonably believes that doing so is necessary to:

• Protect a person from potential harm;
• Prevent continued harassment;
• Protect patient privacy;
• Prevent unauthorized access to information;
• Preserve evidence;
• Investigate serious misconduct;
• Prevent fraud;
• Protect the integrity of the Platform; or
• Comply with legal obligations.

An immediate suspension does not necessarily constitute a final determination that a violation occurred.

24. PERMANENT REMOVAL

ShadowSource may permanently remove a user from the Platform when it determines that the user’s continued participation presents an unacceptable risk to the community or violates ShadowSource policies.

Permanent removal may occur after an investigation or, when circumstances warrant, based on available information without an extended investigation.

ShadowSource may retain appropriate records concerning the removal to prevent circumvention of enforcement measures and to protect the community.

25. LAW ENFORCEMENT AND OTHER AUTHORITIES

ShadowSource may contact or cooperate with law enforcement, regulators, healthcare organizations, educational institutions, or other appropriate authorities when reasonably necessary or legally required.

ShadowSource may disclose relevant information when required by law or when reasonably necessary to protect users, patients, the public, or ShadowSource.

ShadowSource does not conduct criminal investigations and does not replace law enforcement or other appropriate authorities.

26. PROVIDER AND HEALTHCARE ORGANIZATION REQUIREMENTS

Providers may impose additional requirements for participation in their shadowing opportunities.

These requirements may include:

• Dress codes;
• Vaccination requirements;
• Facility orientation;
• Identification requirements;
• Confidentiality agreements;
• Infection-control procedures;
• Security procedures;
• Patient-consent procedures;
• Background or credentialing requirements imposed by the facility; and
• Other site-specific requirements.

A Student must comply with applicable requirements communicated by the Provider or healthcare organization.

27. SAFETY AND VERIFICATION LIMITATIONS

ShadowSource may verify certain information provided by users, including provider NPI information.

However, verification does not guarantee that a user is:

• Safe;
• Trustworthy;
• Professionally competent;
• Free from misconduct;
• Suitable for every shadowing experience; or
• Compliant with every applicable law or facility policy.

At launch, ShadowSource does not conduct routine criminal background checks on users.

IMPORTANT: SHADOWSOURCE DOES NOT CONDUCT CRIMINAL BACKGROUND CHECKS ON STUDENTS OR PROVIDERS. VERIFICATION IS NOT A GUARANTEE OF ANY USER’S SAFETY, CHARACTER, HONESTY, OR SUITABILITY.

Because shadowing occurs in person, protect your own safety: confirm the details of a shadowing opportunity independently; tell someone you trust where and when you will be; stay in professional clinical settings; keep personal contact information private until you are comfortable sharing it; trust your instincts; and leave immediately if you feel unsafe. In an emergency, contact appropriate emergency services first, then notify ShadowSource.

ShadowSource may introduce additional verification or screening measures in the future.

28. COOPERATION WITH SHADOWSOURCE

Users agree to cooperate reasonably with legitimate ShadowSource safety investigations.

Users may be asked to:

• Provide additional information;
• Preserve relevant communications;
• Clarify what occurred;
• Identify relevant witnesses; or
• Provide other information reasonably necessary to investigate a concern.

Failure to cooperate does not automatically establish wrongdoing, but ShadowSource may consider available information when determining appropriate action.

29. NO GUARANTEE OF SAFETY

ShadowSource works to promote a safe and professional community but cannot guarantee the behavior of every person using the Platform.

ShadowSource does not control:

• Healthcare facilities;
• Providers;
• Students;
• Patients;
• Employees of healthcare organizations;
• Other visitors; or
• Circumstances occurring during an in-person shadow.

Users are responsible for exercising reasonable judgment and removing themselves from situations they reasonably believe are unsafe or inappropriate.

30. POLICY UPDATES

ShadowSource may update this Community & Safety Policy from time to time.

Material changes may be communicated through the Platform, email, or another reasonable method.

The “Last Updated” date will be revised when changes are made.

For non-material changes, continued use of the Platform following an effective update constitutes acceptance of the revised Policy to the extent permitted by applicable law.

For material changes, ShadowSource will provide notice through the Platform, email, or another reasonable method and, where appropriate, will seek renewed acceptance.

31. CONTACT

Questions, safety concerns, complaints, or reports may be directed to:

ShadowSource LLC
Email: info@shadow-source.com

For immediate emergencies, contact appropriate emergency services or on-site emergency personnel rather than waiting for ShadowSource to respond.

OUR COMMITMENT

ShadowSource exists to help students learn from healthcare professionals and to help providers invest in the next generation of healthcare.

That opportunity depends on trust.

We expect every member of the ShadowSource community to protect patient privacy, respect personal boundaries, act professionally, and speak up when something is not right.

Safety, professionalism, and patient privacy come first.