Pregnancy Workers Fairness Act Policy

Policy outlining accommodation eligibility, the interactive process, and workplace protections for pregnant and related medical conditions under the Pregnancy Workers Fairness Act.

Purpose

• This policy establishes the Company's process for providing reasonable accommodations to qualified employees and applicants affected by pregnancy, childbirth, or related medical conditions, in compliance with the **Pregnant Workers Fairness Act (PWFA), 42 U.S.C. § 2000gg et seq.**, and applicable EEOC guidance. It also explains workplace protections, confidentiality expectations, and how to request assistance.

Scope

• This policy applies to all U.S. employees and applicants of the Company, including full-time, part-time, temporary, seasonal, and probationary workers, where covered by the PWFA. It applies to requests for accommodation related to pregnancy, childbirth, lactation, recovery from childbirth, and other related medical conditions. **California employees:** this policy is administered in a manner consistent with any more protective state or local pregnancy accommodation, leave, or anti-discrimination requirements. **Other state/local requirements:** where state or local law provides greater protection, the more protective rule will apply.

Definitions

• For purposes of this policy: - **Policy holder** means the Company and the HR or management representative responsible for administering this policy. - **Interactive process** means a timely, good-faith exchange of information to identify an effective accommodation. - **Reasonable accommodation** means a change to the work environment, schedule, duties, or equipment that enables the employee or applicant to perform the essential functions of the job or access equal employment opportunities. - **Essential function** means a core duty of the position, not a marginal task. - **Undue hardship** means a significant difficulty or expense based on the Company’s resources and operational needs. - **Related medical conditions** include conditions affected by pregnancy or childbirth, as recognized under the PWFA and EEOC guidance.

Policy Statement

• The Company will not discriminate against, refuse to hire, discipline, or otherwise treat an employee or applicant unfavorably because of pregnancy, childbirth, or related medical conditions. The Company will provide reasonable accommodations when requested or when the need is known, unless doing so would impose an undue hardship. The Company will engage in a good-faith interactive process promptly and will not require an employee to accept an accommodation that is not effective. The Company prohibits retaliation, interference, or coercion related to the exercise of rights under this policy.

Accommodation Eligibility

• An employee or applicant may request an accommodation if they have a limitation related to pregnancy, childbirth, or a related medical condition. A request may be made verbally or in writing and does not require use of special words. Examples of accommodations may include, as appropriate: more frequent breaks, seating, water access, modified lifting requirements, temporary schedule changes, light duty, remote work, leave, or temporary reassignment of non-essential tasks. The Company may request reasonable documentation only when needed to evaluate the request and only to the extent permitted by law.

Interactive Process

• 1. The employee or applicant should notify HR, a manager, or another designated contact as soon as an accommodation is needed. 2. HR will acknowledge the request and begin a good-faith interactive process promptly. 3. HR may discuss the limitation, the essential functions of the role, possible accommodations, and any operational impacts. 4. The Company will evaluate options and, where possible, implement an effective accommodation. 5. If multiple accommodations are effective, the Company may choose among effective options, provided the selected accommodation is reasonable and responsive to the need. 6. If an accommodation is denied, HR will document the reason, including any undue hardship determination, and consider alternative options.

Workplace Protections

• Employees and applicants are protected from discrimination, retaliation, and interference for requesting or using accommodations, reporting concerns, participating in the interactive process, or supporting another person's rights under this policy. The Company will maintain confidentiality of medical information to the extent required by law and will limit access to those with a business need to know. No employee will be penalized for taking protected leave, using approved accommodations, or raising a good-faith concern.

Procedure

• The Company will handle PWFA requests using the following process: - **Request intake:** HR logs the request, date received, and the accommodation sought. - **Assessment:** HR reviews job duties, limitations, and available accommodations. - **Documentation:** HR may request supporting information only when necessary and permitted. - **Decision:** HR issues a written response approving, modifying, or denying the request. - **Implementation:** The manager and HR coordinate the approved accommodation and monitor effectiveness. - **Follow-up:** The employee or applicant may request a reassessment if the accommodation is not effective or circumstances change.

Roles & Responsibilities

• - **Employees/applicants:** Notify the Company of a need for accommodation and participate in the interactive process in good faith. - **Managers:** Recognize requests, avoid making medical judgments, and route requests promptly to HR. - **HR:** Administer the policy, coordinate the interactive process, maintain records, and ensure consistent application. - **Compliance Officer:** Review escalated denials, retaliation concerns, and legal updates. - **Policy holder:** Ensure resources, training, and oversight are in place to support compliance.

Compliance, Escalation, and Discipline

• Failure to follow this policy, including failure to route requests, retaliation, interference, or unauthorized disclosure of medical information, may result in corrective action up to and including termination of employment. Employees who believe they have been denied rights under this policy may escalate concerns to HR, the Compliance Officer, or senior leadership. The Company will investigate complaints promptly and take appropriate remedial action. Nothing in this policy limits rights under the FLSA, FMLA, ADA, Title VII, or any applicable state or local law.

Review & Revision

• This policy will be reviewed at least annually and updated as needed to reflect changes in the PWFA, EEOC guidance, and applicable federal, state, and local law. Any revisions must be approved by the policy holder and communicated to affected employees and managers.