California Anti-Harassment Training Addendum (AB 1825 / SB 1343)

California-specific addendum to the Anti-Harassment Policy, codifying AB 1825 / SB 1343 training obligations: 2 hours for supervisors and 1 hour for non-supervisors every 2 years for employers with 5+ employees.

Purpose

• This addendum supplements the Company's Anti-Harassment Policy for California employees and establishes the minimum sexual harassment prevention training requirements applicable to covered employers under **California Government Code § 12950.1**. The policy holder must ensure training is assigned, completed, and documented in accordance with California law.

Scope

• This addendum applies to all employees working in California, including supervisors and non-supervisors, where the employer is covered by California training requirements. **California employees:** the training cadence and duration below apply to covered workers in California. This addendum does not replace the Company's broader anti-harassment, anti-discrimination, reporting, investigation, or anti-retaliation policies.

Definitions

• For purposes of this addendum: - **Supervisor:** An employee with authority to hire, transfer, suspend, lay off, recall, promote, discharge, assign, reward, or discipline other employees, or to direct their work, or to adjust grievances, or to effectively recommend such action. - **Non-supervisor:** An employee who does not meet the definition of supervisor. - **Covered employer:** An employer subject to California sexual harassment prevention training requirements. - **Training cycle:** The 2-year period used to measure recurring training completion.

Training Requirements

• The Company will provide or arrange sexual harassment prevention training as follows: 1. **Supervisors:** At least **2 hours** of training every **2 years**. 2. **Non-supervisors:** At least **1 hour** of training every **2 years**. 3. **New hires and newly promoted supervisors:** Training must be assigned within the applicable onboarding or role-change timeframe required by California law and internal compliance procedures. 4. **Covered threshold:** This addendum applies to employers with **5 or more employees**. 5. **Training content:** Training must cover harassment prevention topics required by California law, including prohibited conduct, complaint procedures, anti-retaliation, and supervisor responsibilities.

Procedure

• The policy holder, with support from HR, will: 1. Identify California employees and classify them as supervisors or non-supervisors. 2. Assign the correct training module based on role. 3. Track completion dates to ensure the 2-year training cycle is maintained. 4. Notify employees of upcoming or overdue training assignments. 5. Escalate missed training to the employee's manager and HR for follow-up. 6. Maintain training records, including completion date, course title, duration, and attendee name, in accordance with retention requirements. 7. Document any exceptions, delays, or remediation steps in a good-faith compliance record.

Roles & Responsibilities

• **HR / Compliance:** Administer training assignments, maintain records, and monitor due dates. **Managers / Supervisors:** Ensure direct reports complete assigned training on time and support attendance during work hours. **Employees:** Complete assigned training by the due date and promptly report any access or scheduling issues. **Policy holder:** Approve resources, review compliance status, and ensure the organization maintains a documented training program for California employees.

Compliance, Escalation, and Discipline

• Failure to complete required training may result in corrective action, which may include a documented warning, removal from supervisory duties pending completion, or inclusion in a performance improvement plan (PIP), subject to applicable law and company practice. The Company will not retaliate against any employee for raising concerns about training access, scheduling, or compliance. Any disciplinary action must be applied consistently and in a good-faith manner.

Review and Revision

• This addendum will be reviewed at least annually and updated as needed to reflect changes in California law, regulatory guidance, or internal training practices. The policy holder is responsible for approving revisions and ensuring the addendum remains aligned with **California Government Code § 12950.1** and related California harassment prevention obligations.