Code of Conduct

Foundational policy defining the ethical, professional, and behavioral standards expected of every employee. Used as the umbrella reference for all other HR policies and the basis for disciplinary action when standards are violated.

Purpose

• This Code of Conduct establishes the ethical, professional, and behavioral standards expected of all employees, managers, supervisors, and covered contractors. It serves as the umbrella policy for related HR policies and provides a consistent basis for coaching, documented warnings, corrective action, and disciplinary decisions when standards are violated. This policy is intended to promote a respectful, lawful, safe, and productive workplace while preserving employee rights under applicable law, including protected concerted activity under the **NLRA Section 7**, equal employment protections under **Title VII of the Civil Rights Act of 1964**, reasonable accommodation rights under the **ADA**, leave rights under the **FMLA**, wage-and-hour compliance under the **FLSA**, and workplace safety obligations under the **OSHA General Duty Clause**.

Scope

• This policy applies to all employees, including full-time, part-time, temporary, and probationary employees, as well as managers, supervisors, interns, and contractors who represent the company or use company systems, facilities, or information. **Applicable jurisdictions:** This policy applies across the United States unless a state or local law provides greater protection or a different requirement. Where state-specific rules apply, the company will follow the more protective or specific legal requirement. **California employees:** Training, harassment prevention, and disciplinary procedures must be administered consistently with **California AB 1825** and related California workplace requirements. **New York employees:** Reports of retaliation or whistleblower concerns will be handled consistently with **New York Labor Law Section 740**. **Illinois employees:** Scheduling, rest, and meal-period practices must comply with the **Illinois One Day Rest in Seven Act** where applicable. **Washington employees:** Paid sick leave and related leave administration must comply with Washington paid sick leave requirements. **Data handling:** Any personal data collected under this policy must be handled in accordance with **GDPR** where applicable and **CCPA** for California residents.

Definitions

• The following terms apply throughout this policy: - **Policy holder**: The company entity responsible for this policy. - **Good-faith**: Honest, reasonable conduct or reporting without intent to deceive or retaliate. - **Interactive process**: A timely, good-faith dialogue between the company and an employee to identify possible reasonable accommodations. - **Reasonable accommodation**: A workplace adjustment that enables performance of an essential function unless it creates undue hardship. - **Essential function**: A core duty of the role. - **Documented warning**: A written notice identifying misconduct or a policy breach and the expected correction. - **PIP**: A documented performance improvement plan with measurable expectations and deadlines. - **Protected activity**: Conduct protected by law, including complaints about wages, safety, discrimination, harassment, leave, or working conditions.

Policy Statement

• Employees are expected to act with honesty, professionalism, respect, and accountability at all times while performing work for the company or representing the company to customers, vendors, partners, or the public. Employees must: 1. Treat coworkers, customers, vendors, and visitors with respect and professionalism. 2. Follow lawful instructions, company policies, and applicable laws. 3. Protect company property, confidential information, and personal data. 4. Report safety hazards, misconduct, harassment, discrimination, fraud, or other concerns in good faith. 5. Cooperate honestly in investigations, audits, and corrective action processes. 6. Avoid conflicts of interest or disclose them promptly when they arise. 7. Refrain from retaliation against anyone who makes a good-faith report or participates in a protected investigation. Employees must not: - Engage in discrimination, harassment, bullying, threats, violence, intimidation, or abusive conduct. - Falsify records, time entries, expense reports, or other business documents. - Misuse company systems, property, funds, or confidential information. - Work off the clock or instruct others to do so in violation of the **FLSA**. - Interfere with, discourage, or retaliate against protected activity under the **NLRA** or other applicable laws. - Refuse a lawful safety requirement or bypass required safety procedures. - Disclose personal data or confidential information without authorization. Nothing in this policy is intended to restrict rights protected by law, including the right to discuss wages, hours, or working conditions, report unlawful conduct, request accommodation, or engage in other protected concerted activity.

Procedure

• When a concern, complaint, or suspected violation arises, the company will follow a fair and documented process: 1. **Report the concern** through a manager, HR, compliance, ethics hotline, or other designated channel. 2. **Acknowledge and triage** the report promptly to determine whether the issue involves safety, harassment, discrimination, retaliation, wage-and-hour concerns, leave, privacy, or other urgent risk. 3. **Preserve evidence** such as emails, messages, time records, access logs, or witness statements as appropriate. 4. **Investigate in good faith** using a neutral, need-to-know approach. 5. **Assess findings** against the policy, applicable law, and any prior documented warnings or PIP requirements. 6. **Implement corrective action** that may include coaching, retraining, written warning, final warning, suspension, reassignment, removal of access, or termination, depending on severity and history. 7. **Document outcomes** in the employee file and maintain confidentiality to the extent practicable. 8. **Escalate legal or protected matters** to HR, legal, or compliance when the issue involves discrimination, harassment, retaliation, wage-hour concerns, safety, leave, or accommodation requests. **Interactive process:** If a conduct issue may be related to a disability or medical condition, HR must engage in the interactive process before imposing discipline where required by law, unless immediate action is necessary for safety or serious misconduct. **Manager responsibilities:** Managers must not promise outcomes, conduct retaliatory action, or ignore reports. They must escalate concerns promptly and avoid making unilateral legal determinations.

Roles & Responsibilities

• **Employees** must follow this policy, complete required training, report concerns in good faith, and cooperate in investigations. **Managers and supervisors** must model professional conduct, enforce standards consistently, address issues early, document performance or conduct concerns, and escalate potential legal or policy violations to HR. **HR** must maintain the policy, coordinate investigations, manage the interactive process where needed, ensure consistent discipline, and retain records according to the company’s retention schedule. **Compliance / Legal** must review high-risk matters, advise on jurisdiction-specific requirements, and confirm that disciplinary actions do not interfere with protected rights. **Policy holder / leadership** must support enforcement, allocate resources for training, and approve material policy updates.

Compliance, Discipline, and Non-Retaliation

• Violations of this policy may result in corrective action up to and including termination of employment, depending on the nature, severity, frequency, intent, and impact of the conduct. The company may use progressive discipline, but it reserves the right to skip steps when warranted by the facts, including for serious misconduct, violence, theft, harassment, falsification, severe safety breaches, or unlawful retaliation. Disciplinary actions may include: - Coaching or verbal counseling - Documented warning - Final written warning - PIP with measurable expectations and deadlines - Suspension or removal of access - Demotion or reassignment where lawful and appropriate - Termination of employment **Non-retaliation:** No employee will be disciplined for making a good-faith report, participating in an investigation, requesting a reasonable accommodation, taking protected leave, or engaging in protected concerted activity. Any alleged retaliation will be investigated promptly and may result in separate discipline. **State-specific notes:** - **California employees:** Discipline and training must be applied consistently and in a manner that does not conflict with California anti-discrimination, anti-harassment, and wage-and-hour requirements. - **New York employees:** Retaliation concerns tied to whistleblowing must be reviewed under **NY Labor Law Section 740**. - **Illinois employees:** Scheduling-related discipline must not violate rest-day requirements under the **One Day Rest in Seven Act**. - **Washington employees:** Attendance or leave-related discipline must account for protected paid sick leave use.

Review & Revision

• This policy will be reviewed at least annually and updated as needed to reflect changes in law, operations, risk, or company practice. Revisions must be approved by the policy holder or designated leadership and communicated to affected employees. Material changes may require retraining and renewed acknowledgement.