New York Lactation Accommodation Addendum

NY Labor Law §206-c lactation accommodation — written policy, paid break time, private lactation room (not a bathroom).

Purpose

• This addendum establishes the Company's New York lactation accommodation requirements under **New York Labor Law §206-c**. It describes employee rights to paid break time, access to a private lactation room, and the process for requesting support in a timely, respectful, and non-retaliatory manner.

Scope

• This addendum applies to all employees working in New York, including full-time, part-time, temporary, and remote employees whose work location is in New York. Where a local, state, or federal requirement provides greater protection, the Company will follow the more protective rule.

Policy Requirements

• The Company will provide lactation accommodations consistent with New York law, including: - **Paid break time:** Employees will be provided reasonable paid break time to express breast milk or address lactation needs. - **Private lactation room:** The Company will provide access to a private space that is shielded from view, free from intrusion, and **not a bathroom**. - **No retaliation:** Employees will not be disciplined, penalized, or treated adversely for requesting or using lactation accommodations. - **Confidential handling:** Requests will be handled discreetly and shared only with personnel who have a business need to know. Employees may use existing paid break periods where available, and additional paid time will be provided when needed to comply with applicable law.

Procedure for Requesting Lactation Accommodation

• 1. The employee should notify HR, their manager, or another designated contact as soon as practicable. 2. HR will confirm the request and discuss the employee's scheduling needs, expected frequency, and preferred location. 3. The Company will identify a suitable private lactation room and confirm access instructions. 4. If the employee needs a schedule adjustment, HR and the manager will coordinate coverage using a good-faith, interactive process. 5. If a designated room is temporarily unavailable, the Company will provide an alternative private space that meets legal requirements and is not a bathroom. 6. Any denial, delay, or limitation must be escalated to HR and documented with the reason and the alternative provided.

Private Lactation Room Standards

• The designated lactation space must, at a minimum: - Be shielded from view and free from intrusion. - Be available when needed during the employee's work time. - Be clean, sanitary, and reasonably close to the employee's work area. - Include a chair, flat surface, and access to electrical outlet where feasible. - **Not be a bathroom or toilet stall.** - Provide reasonable privacy controls such as a lock, sign, or reservation process. The Company may use a multi-purpose room if it is made available for lactation during the relevant time and meets the privacy requirements above.

Roles & Responsibilities

• **HR / Policy Holder:** Maintain the written policy, coordinate requests, document accommodations, and ensure managers are trained. **Managers:** Respond promptly, avoid discouraging requests, and coordinate coverage in good faith. **Employees:** Provide notice when possible, follow room-use rules, and report access issues promptly. **Facilities / Operations:** Maintain the room, signage, access controls, and any refrigeration or storage arrangements if provided.

Compliance, Escalation, and Discipline

• Failure to follow this addendum may result in corrective action, up to and including documented warning, retraining, or other discipline consistent with Company policy and applicable law. Any complaint of interference, denial, or retaliation will be investigated promptly. Employees may raise concerns to HR, Compliance, or senior management without fear of retaliation. This addendum does not limit rights under the FLSA, FMLA, ADA interactive process requirements, Title VII, or any other applicable law.

Review & Revision

• This addendum will be reviewed at least annually and whenever New York, federal, or local law changes. The policy holder is responsible for updating the written policy, training materials, and room designation practices as needed.