Workplace Violence Prevention Policy

Zero-tolerance workplace violence prevention policy aligned with OSHA General Duty Clause and emerging state requirements (CA SB 553 effective 2024, NY S5512). Covers threat assessment, reporting, and emergency response.

Purpose

• This policy establishes a **zero-tolerance** standard for workplace violence and sets out the procedures for prevention, reporting, threat assessment, emergency response, investigation, and corrective action. The policy is intended to help the Company maintain a safe workplace and to support compliance with the **OSHA General Duty Clause (Section 5(a)(1))** and applicable state workplace violence prevention requirements, including **California SB 553** and **New York S5512**, as applicable.

Scope

• This policy applies to all employees, supervisors, managers, officers, temporary workers, interns, contractors, vendors, and visitors while on Company premises, at off-site work locations, during business travel, at Company-sponsored events, and in any work-related communication or interaction. **California employees:** Where required by law, the Company will maintain a workplace violence prevention plan, training, incident log, and related records in accordance with California requirements. **New York employees:** Where required by law, the Company will implement and maintain workplace violence prevention measures consistent with New York law and any applicable industry-specific obligations.

Definitions

• - **Workplace violence:** Any act or threat of physical violence, intimidation, harassment, or other threatening disruptive behavior that occurs at the worksite or in connection with work. - **Threat assessment:** A good-faith review of reported conduct, context, history, and available facts to determine risk level and appropriate intervention. - **Essential function:** A fundamental job duty that is necessary to the position. - **Reasonable accommodation:** A workplace adjustment considered through the interactive process for an employee with a disability, unless it would create undue hardship. - **Interactive process:** The good-faith, individualized dialogue used to evaluate accommodation requests under the ADA. - **Policy holder:** The HR or Compliance leader responsible for maintaining this policy and coordinating updates.

Policy Statement

• The Company prohibits workplace violence in all forms, including threats, intimidation, stalking, physical assault, property damage, and possession or use of weapons on Company property or during work-related activities, except where expressly authorized by law and approved in writing by the Company. No employee may engage in conduct that creates a hostile, unsafe, or coercive work environment. All reports will be handled promptly, discreetly, and in good faith. The Company will take appropriate corrective action, up to and including termination of employment, removal from the premises, and notification of law enforcement when warranted.

Procedure

• 1. **Immediate reporting:** Employees must report any threat, violent act, suspicious behavior, or safety concern immediately to their supervisor, HR, Security, or emergency services if there is imminent danger. 2. **Emergency response:** If there is an immediate threat, call 911 or local emergency services, follow evacuation or shelter-in-place instructions, and notify Security/HR as soon as it is safe to do so. 3. **Initial review:** HR, Security, and the policy holder will document the report, preserve evidence, and conduct a good-faith initial assessment of risk. 4. **Threat assessment:** The Company may interview witnesses, review messages or recordings, assess prior incidents, and determine whether temporary separation, leave, schedule changes, escort support, or other controls are needed. 5. **Interim measures:** The Company may place an employee on administrative leave, restrict access, modify reporting lines, or implement other safety measures while the matter is investigated. 6. **Investigation and resolution:** The Company will investigate promptly, maintain confidentiality to the extent possible, and determine appropriate corrective action based on the facts. 7. **Follow-up:** HR or Security will monitor the situation, document outcomes, and update controls or training as needed.

Roles & Responsibilities

• - **Employees:** Refrain from violent or threatening conduct, report concerns promptly, cooperate with investigations, and comply with safety instructions. - **Supervisors/Managers:** Escalate reports immediately, preserve evidence, separate involved parties when appropriate, and avoid retaliation. - **HR/Compliance:** Maintain the policy, coordinate investigations, document incidents, manage records, and ensure training and acknowledgment tracking. - **Security/Facilities:** Support emergency response, access control, incident response, and environmental safety measures. - **Policy holder:** Review incidents, approve corrective actions, and ensure jurisdiction-specific requirements are implemented.

Compliance / Discipline

• Violations of this policy may result in disciplinary action up to and including termination of employment, removal from the worksite, suspension of access privileges, and referral to law enforcement. The Company will not retaliate against any person who makes a report in good faith, participates in an investigation, or exercises rights protected by law, including protected concerted activity under the **NLRA Section 7**. Where applicable, the Company will also consider obligations under the **ADA interactive process**, **FMLA**, **FLSA**, and **EEOC** requirements when determining leave, accommodations, scheduling, or discipline.

Review & Revision

• This policy will be reviewed at least annually and whenever there is a material change in law, operations, workplace layout, incident trends, or regulatory guidance. The policy holder is responsible for coordinating updates, training refreshers, and any required jurisdiction-specific addenda. Records, incident logs, and related reports will be retained and handled in accordance with applicable recordkeeping and privacy requirements, including **CCPA/CPRA** and **GDPR** where applicable.