Attendance & Punctuality Policy

Standard policy on attendance expectations, tardiness, no-call/no-show, and progressive discipline. Distinguishes excused absences (illness, jury duty, FMLA) from unexcused.

Purpose

• This policy establishes attendance and punctuality expectations, reporting procedures, and the consequences for excessive tardiness, absenteeism, and no-call/no-show incidents. The policy is intended to support reliable operations while complying with applicable federal, state, and local laws, including the FMLA, ADA, Title VII, the FLSA, and the NLRA.

Scope

• This policy applies to all employees unless a written agreement, collective bargaining agreement, or applicable law provides a different standard. **Policy holder:** Human Resources is responsible for administering this policy consistently and in a nondiscriminatory manner. **California employees:** attendance-related leave and discipline must also be reviewed for compliance with California paid sick leave, CFRA, and any applicable local paid sick leave ordinances. **Washington employees:** paid sick leave accrual and use must comply with Washington law. **Illinois employees:** meal and rest break scheduling must account for the One Day Rest in Seven Act where applicable.

Policy Statement

• Employees are expected to: 1. Report to work on time and remain at work for the full scheduled shift. 2. Follow all call-in procedures when they will be late or absent. 3. Provide truthful, timely, and good-faith notice of attendance issues. 4. Maintain attendance that does not interfere with job performance or business operations. 5. Request leave or accommodation in advance when the need is foreseeable. Attendance decisions will be made without discrimination or retaliation based on protected characteristics or protected activity under Title VII and the NLRA. The company will not count protected leave, approved reasonable accommodations, or other legally protected absences as unexcused.

Definitions and Attendance Rules

• **Work schedule:** Employees must follow their assigned start and end times, meal periods, and break schedules. **Reporting late:** Employees must notify their supervisor or designated contact as soon as they know they will be late. **Excused absences may include:** - Personal illness or injury, when properly reported and supported if requested and permitted by law - Jury duty or subpoenaed court appearance - Approved vacation, personal time, or bereavement leave if offered by company policy - FMLA leave for a qualifying reason - ADA-related leave or schedule modification approved through the interactive process **Unexcused absences may include:** - Failure to report an absence in accordance with procedure - Absence without approval or legal protection - Leaving work early without authorization - Repeated tardiness that is not approved or protected The company may require reasonable documentation for absences where permitted by law, but will not request information that is prohibited or unnecessary under applicable leave, disability, privacy, or anti-discrimination laws.

Procedure

• **1. Reporting an absence or tardiness** - Notify your supervisor or designated reporting line before the start of your shift, or as soon as practicable if an emergency prevents advance notice. - Provide the expected duration of the absence or delay, if known. - Follow any department-specific call-in requirements. **2. Documentation** - For absences that may qualify as protected leave, HR may request documentation consistent with applicable law. - Employees requesting ADA-related schedule changes or leave must engage in the interactive process and may be asked to provide supporting medical information where permitted. **3. Scheduling adjustments** - Employees must obtain approval before swapping shifts, arriving late, leaving early, or extending breaks. - Managers may adjust schedules based on business needs, provided changes are applied consistently and lawfully. **4. Timekeeping** - Nonexempt employees must accurately record all hours worked, including any time worked before or after scheduled shifts, in accordance with the FLSA. - Working off the clock is prohibited.

No-Call/No-Show

• An employee who fails to report for work and does not notify the company within the required timeframe may be treated as a no-call/no-show. Unless prohibited by law or excused by extraordinary circumstances, the company may consider: - One missed shift without notice as a serious attendance violation - Two consecutive no-call/no-show incidents as job abandonment - Job abandonment as a voluntary resignation, subject to review by HR Before treating an absence as job abandonment, the company will make a good-faith effort to contact the employee using the information on file and will review whether the absence may be protected by law.

Tardiness

• Repeated tardiness disrupts operations and may result in corrective action. Tardiness includes arriving late, returning late from breaks, or leaving early without approval. Managers should document each incident and discuss the issue promptly with the employee. If tardiness is related to a medical condition, disability, pregnancy, or another protected reason, HR will evaluate whether the interactive process or another legal accommodation applies.

Progressive Discipline

• The company may use progressive discipline for attendance violations, depending on the severity, frequency, and circumstances of the conduct. Discipline may include: 1. Verbal coaching or counseling 2. Documented warning 3. Final written warning 4. Performance improvement plan (PIP) or attendance improvement plan 5. Suspension, if permitted by law and company practice 6. Termination of employment The company may skip steps or accelerate discipline for serious misconduct, repeated no-call/no-show events, falsification of attendance records, or continued violations after coaching. Protected leave, approved accommodations, and legally protected activity will not be counted as discipline triggers.

Roles & Responsibilities

• **Employees:** Arrive on time, report absences promptly, provide accurate information, and cooperate with documentation requests. **Managers:** Enforce the policy consistently, document attendance concerns, escalate repeated issues to HR, and avoid retaliatory or discriminatory treatment. **Human Resources:** Review leave and accommodation requests, determine whether absences are protected, maintain records, and ensure compliance with applicable law. **Policy holder:** HR leadership owns this policy and approves exceptions only when legally required or expressly authorized.

Compliance, Exceptions, and Legal Protections

• This policy must be applied in a manner consistent with the FMLA, ADA, Title VII, the FLSA, the NLRA, and any applicable state or local leave laws. The company will not discipline employees for: - Taking protected leave under the FMLA - Requesting or using a reasonable accommodation under the ADA - Engaging in protected concerted activity under Section 7 of the NLRA - Reporting workplace concerns protected by law If a conflict exists between this policy and applicable law, the law controls. HR must review any proposed discipline involving a medical condition, pregnancy, disability, protected leave, union activity, or other protected status before action is taken.

Review & Revision

• This policy will be reviewed at least annually and updated as needed to reflect operational changes, legal requirements, and jurisdiction-specific obligations. Revisions must be approved by HR leadership and legal counsel where appropriate.