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Controlled Substances Policy

Effective Date: October 15, 2026 Version: 1.0 Applies to: All Veterinarians who prescribe through the Platform.

Article 1: Introduction and Scope

1.1 This Policy governs controlled substances in connection with services provided through the Platform. It states the Company's default position plainly in Article 3, the conditions under which that position may change for a state or a category, the duties that apply where controlled-substance prescribing is enabled, and the referral duty that applies where it is not.

1.2 Controlled substances sit at the intersection of the strictest federal and state regimes: federal registration and record-keeping requirements, state prescription-monitoring programs, and, in the states that impose one, an in-person examination requirement. Licensure, the VCPR, and prescribing are governed by the law of the state in which the Patient is located. This Policy does not authorize any practice that federal law or the law of that state forbids, and where this Policy and applicable law differ on a clinical matter, the stricter rule prevails.

1.3 No provision of this Policy promises a clinical outcome. If a provision of this Policy conflicts with the Terms of Use, this Policy controls for the subject it governs. If a provision of this Policy conflicts with the terms of a program in which the Veterinarian participates, the program terms control for that program.

Article 2: Definitions

2.1 Account: the account a person or business establishes with the Company to use the Platform.

2.2 Client: the person who holds authority over the Patient.

2.3 Company: All About Pawz, LLC, a Tennessee limited liability company.

2.4 Consultation: a veterinary telemedicine encounter between a Veterinarian and a Client conducted through the Platform, including a teletriage encounter.

2.5 Controlled Substance: a substance classified as a controlled substance under federal law or under the law of the state in which the Patient is located, in any schedule. A substance controlled under the law of either jurisdiction is a Controlled Substance for the purposes of this Policy.

2.6 Patient: the animal that is the subject of a Consultation.

2.7 Platform: the websites, applications, and services the Company operates under the name All About Pawz, including aapawz.com.

2.8 Prescription: an order by a Veterinarian for a medication for a Patient, recorded and transmitted through the Platform.

2.9 VCPR: a veterinarian-client-patient relationship, as defined by the law of the state in which the Patient is located.

2.10 Veterinarian: a veterinarian licensed in the state in which the Patient is located whom the Company has accepted to provide veterinary services through the Platform.

Article 3: The Default Position: Prohibited Through the Platform

3.1 No Veterinarian shall prescribe, order, or authorize a Controlled Substance as a result of a Consultation through the Platform, except where Article 4 is satisfied in full. The prohibition applies to every schedule, to any quantity, and to every encounter type, including a teletriage encounter. The prohibition is a rule of the Platform, independent of the State Telemedicine Matrix: a matrix entry does not lift it, and no individual clinical judgment displaces it.

3.2 The prescribing process shall reject a Prescription flagged as a Controlled Substance while the prohibition applies to that Prescription. Rejection is final for that Prescription; there is no review path by which a prohibited Controlled Substance Prescription proceeds.

3.3 A Veterinarian's registration with the United States Drug Enforcement Administration does not create an exception to this Article. The prohibition applies to the Platform encounter, not to the individual Veterinarian.

Article 4: Enabling a State or Category

4.1 Controlled-substance prescribing through the Platform may be enabled for a state or a category only when each of the following is satisfied, in this order (a) federal law and the law of the Patient's state each expressly permit the prescribing by telemedicine;

(b) federal compliance is confirmed, including verification of each prescribing Veterinarian's Drug Enforcement Administration registration, any state prescription-monitoring program integration the law requires, and satisfaction of any in-person examination requirement that applies;

(c) the State Telemedicine Matrix entry for that state has been legally reviewed and records the category as permitted; and

(d) the Company has enabled the state or category in writing as a change to this Policy, recorded as a policy change and not as a data entry.

4.2 Where a state or category is enabled under Article 4.1, a Veterinarian prescribing a Controlled Substance through the Platform shall: (a) hold a current Drug Enforcement Administration registration and every state controlled-substance registration the law requires for the prescribing; (b) satisfy the in-person examination requirement, where one applies, before the Prescription issues; (c) check the applicable state prescription-monitoring program where the law requires the check, and record that the check was made; and (d) satisfy every other condition in the Prescription Authority and VCPR Requirement, including a valid, current VCPR and licensure in the Patient's state.

4.3 Record-keeping for an enabled Prescription shall include the Prescription record, the VCPR reference, the registration verifications, the prescription-monitoring program check where one is required, and the encounter record. Records shall be retained in accordance with the Regulatory Record Retention and with the record-keeping law that governs the Controlled Substance, whichever requires the longer retention.

Article 5: Referral Where a Controlled Substance Is Indicated

5.1 Where the appropriate therapy for a Patient is a Controlled Substance that this Policy does not permit the Veterinarian to prescribe, the Veterinarian shall refer the Client to in-person veterinary care and shall document the referral in the clinical note under the Clinical Documentation Policy: the substance or class identified as appropriate, the place to which the Client was referred, and the fact that the Platform cannot provide the substance.

5.2 The Company and the Veterinarian shall not facilitate a Controlled Substance transaction that this Policy prohibits in any form: no direction to a pharmacy that might dispense the substance without a lawful prescription, no dosage guidance for a substance the Veterinarian cannot prescribe in the encounter, and no referral that is recorded in form while the encounter in substance directs the Client to the substance.

5.3 The Veterinarian shall not substitute a less appropriate non-controlled medication for the sole purpose of avoiding a referral under this Article. The duty under Article 5.1 is to identify the appropriate therapy honestly and to refer where the Platform cannot provide it. Common presentations this Article covers include pain management for which tramadol or an opioid analgesic is indicated, gabapentin where the Patient's state classifies gabapentin as controlled, androgens, and ketamine.

Article 6: Evasion and Reporting

6.1 An attempt to evade this Policy: including misclassifying a Controlled Substance to defeat the controlled-substance flag on a Prescription, dividing a Controlled Substance order into components presented as non-controlled, or directing a Client to obtain the substance elsewhere while recording a referral that does not reflect the substance of the encounter: is a violation of the most serious kind under the Vet Conduct and Enforcement (Vet Conduct and Enforcement Policy).

6.2 Evasion under Article 6.1 shall be reported to the licensing board of the state in which the Veterinarian is licensed. The report includes the Prescription record, the Consultation record, and the flag history for the Prescription. The duty to report is not discretionary.

Article 7: Liability

7.1 Prescribing responsibility. The Veterinarian bears responsibility for each prescribing decision and for compliance with the federal and state law that governs Controlled Substances. The Company does not practice veterinary medicine and does not direct the Veterinarian's clinical judgment. Nothing in this Article limits liability for personal injury or injury to an animal caused by negligence, where applicable law does not permit the limitation. No provision of this Policy is a promise of a clinical outcome.

7.2 Exclusion of certain damages. 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 Policy, even if the party has been advised of the possibility of those damages.

7.3 Cap. To the fullest extent permitted by law, the Company's total liability arising out of or relating to this Policy shall not exceed the greater of (a) the amounts the Veterinarian paid to the Company under this Policy in the twelve months before the event giving rise to the claim, or (b) one hundred dollars ($100).

7.4 Carve-outs. This Article does not limit (a) a party's indemnification obligations under this Policy; (b) liability for fraud or willful misconduct; (c) amounts the Veterinarian owes for fees, refunds, or other amounts under the Company's documents; or (d) liability that cannot be limited under applicable law.

7.5 Essential purpose. 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 Duty. The Veterinarian shall indemnify, defend, and hold harmless the Company and its members, managers, employees, and agents from and against every claim, demand, action, loss, liability, judgment, settlement, cost, and expense (including reasonable attorneys' fees) arising out of or relating to: (a) the Veterinarian's breach of this Policy; (b) the Veterinarian's Services, Prescriptions, or content; (c) the Veterinarian's violation of any law or of the rights of any person; and (d) taxes for which the Veterinarian is responsible under the Company's documents.

8.2 Procedure. The Company shall give prompt written notice of a claim under this Article. The Veterinarian shall control the defense with counsel reasonably acceptable to the Company. The Company may participate in the defense at its own expense. The Veterinarian shall not settle a claim in a manner that imposes any obligation or restriction on the Company, or that does not release the Company fully, without the Company's prior written consent.

8.3 Survival. This Article survives the termination of this Policy.

Article 9: Enforcement and Appeals

9.1 Investigation. The Company may investigate any suspected violation of this Policy. The Veterinarian shall cooperate with an investigation and shall produce the records this Policy requires the Veterinarian to keep.

9.2 Notice. If the Company determines that the Veterinarian has violated this Policy, 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 Company may suspend the Veterinarian's prescribing and participation immediately where a license has lapsed or a safety risk arises.

9.3 Opportunity to cure. Where a violation is capable of cure, the Veterinarian has ten (10) business days from notice to cure it and to confirm the cure in writing. No cure period applies to fraud, a risk to the safety of a person or an animal, unlawful conduct, a violation of Article 3 or Article 6, or a violation that by its nature cannot be cured.

9.4 Measures. If a violation is established and is not cured within the period allowed, the Company may, proportionate to the violation: (a) issue a written warning; (b) suspend prescribing authority through the Platform; (c) suspend the Account or program participation, in whole or in part; (d) terminate this Policy and the Account; and (e) exercise any other right or remedy available under the Company's documents or at law.

9.5 Appeal. The Veterinarian may appeal a measure under this Article by written notice 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. The Company's decision on appeal is final. A measure remains in effect during an appeal unless the Company directs otherwise in writing.

9.6 No waiver by delay. 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 Term. This Policy takes effect when the Veterinarian is accepted to provide veterinary services through the Platform and continues until terminated under this Article.

10.2 Termination by the Company. The Company may terminate this Policy and the Account on thirty (30) days' written notice for any reason, and immediately on written notice if the Veterinarian materially breaches this Policy, engages in fraud, or becomes ineligible to participate.

10.3 Termination by the Veterinarian. The Veterinarian may terminate this Policy on thirty (30) days' written notice to support@aapawz.com, provided the Veterinarian has no booking or investigation outstanding.

10.4 Effect of termination. On termination: (a) the rights granted under this Policy end; (b) obligations that arose before termination: including payment, refund, record-keeping, and indemnification obligations: survive until satisfied; and (c) the Company shall disburse amounts owed, less amounts the Company may set off under the Company's documents, within thirty (30) days, except amounts held in connection with an open investigation or dispute.

10.5 Survival. The Definitions, Liability, Indemnification, Enforcement and Appeals (for measures taken before termination), Dispute Resolution, and General Provisions Articles survive termination.

Article 11: Dispute Resolution

11.1 Any dispute arising out of or relating to this Policy, or to the relationship it governs, is governed by the Dispute Resolution Policy, which is incorporated into this Policy by reference.

Article 12: General Provisions

12.1 Amendments. The Company may amend this Policy by posting the amended Policy in the Document Center and giving notice to the Veterinarian at the email address in the Account. An amendment that materially increases the Veterinarian's fees or obligations takes effect thirty (30) days after notice; other amendments take effect on posting. An enabling of a state or category under Article 4 is an amendment to this Policy and takes effect only as Article 4 provides. Continued use of the Platform after the effective date of an amendment is acceptance of it. If the Veterinarian does not accept an amendment, the Veterinarian's remedy is to terminate under Article 10 before the amendment takes effect.

12.2 Notices. Legal notices under this Policy 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 Veterinarian are effective when sent to the email address in the Account or posted to the Account's notice facility in the portal, whichever occurs first. The Veterinarian shall keep the email address in the Account current.

12.3 Governing law. This Policy 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 Policy shall be brought in the state or federal courts located in Shelby County, Tennessee, and the parties consent to personal jurisdiction there. The practice of veterinary medicine under this Policy is governed by the law of the state in which the patient is located.

12.4 Severability. If any provision of this Policy is held unenforceable, the provision shall be enforced to the fullest extent permitted, and the remaining provisions continue in full effect.

12.5 Entire agreement. This Policy, together with the documents it incorporates by reference, is the entire agreement between the Company and the Veterinarian for the subject it governs and supersedes every prior or contemporaneous statement, communication, or agreement on that subject, whether written or oral.

12.6 Assignment. The Veterinarian shall not assign this Policy or any right or obligation under it without the Company's prior written consent, and an assignment without consent is void. The Company may assign this Policy to an affiliate or in connection with a sale of all or part of its business, on notice to the Veterinarian.

12.7 Waiver. A waiver of any provision of this Policy is effective only in writing and only for the instance stated. No waiver is a waiver of any other provision or instance.

12.8 Interpretation. Headings are for convenience only. "Including" means "including without limitation." This Policy shall not be construed against a party as its drafter. The English-language text controls over any translation.

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