Run: 401(k) and Retirement Savings Policy

This policy establishes the rules and administrative procedures for the company's retirement savings plan, including eligibility, employee deferrals, employer matching contributions, vesting, automatic enrollment, rollovers, and participant communications. The policy is intended to support consistent administration and compliance with applicable federal law, including ERISA and the Internal Revenue Code.

This policy applies to all employees of the company in the United States, subject to the eligibility rules described below and any plan document terms that differ by job classification, location, or service status. Where the plan document, summary plan description, or applicable law provides different rules, the plan document and law control. **California employees:** Any state-specific payroll, notice, or wage statement requirements must be administered in a manner consistent with California law and the plan document. **Part-time employees:** The plan may permit participation for long-term part-time employees consistent with federal law, including the SECURE Act and SECURE 2.0 Act provisions applicable to employees who complete the required hours of service over the applicable measurement period.

For purposes of this policy: - **Eligible compensation** means compensation defined by the plan document for contribution and matching purposes. - **Contribution limit** means the annual elective deferral limit established under the Internal Revenue Code and adjusted periodically by the IRS. - **Catch-up contribution** means an additional elective deferral amount permitted for employees age 50 or older, or other amounts permitted by law. - **Good-faith administration** means plan administration based on accurate payroll data, timely enrollment processing, and consistent application of the plan document. - **Plan administrator** means the person or team responsible for day-to-day plan operations, notices, and recordkeeping.

The company offers a retirement savings plan to help eligible employees save for retirement. Participation is voluntary unless automatic enrollment applies under the plan. Contributions, employer matching, vesting, and rollover rules are governed by the plan document and applicable law. The company will administer the plan in a nondiscriminatory manner consistent with EEOC requirements, and will not use protected characteristics in eligibility, enrollment, or contribution administration decisions. The company will not interfere with employees' rights under the National Labor Relations Act (NLRA) to discuss wages, benefits, or working conditions, including retirement plan terms, in protected concerted activity.

1. **Eligibility criteria.** HR and Payroll will determine eligibility based on the plan document, which may include age, service, employment classification, and hours-of-service requirements. 2. **Enrollment notice.** Eligible employees will receive plan information, investment notices, and enrollment instructions before or at the time they become eligible. 3. **Employee elections.** Employees may elect a contribution percentage, choose pre-tax and/or Roth deferrals if offered, and update elections through the designated benefits platform. 4. **Auto-enrollment.** If the plan uses auto-enrollment, eligible employees will be enrolled at the default rate after the notice period unless they opt out or change their election. 5. **Change requests.** Contribution changes will be processed prospectively according to payroll cutoffs and plan rules. 6. **Rehire handling.** Rehired employees will be treated according to the plan document and prior vesting/service records.

1. **Employee contributions.** Employee deferrals are limited to the annual IRS elective deferral limit, plus any permitted catch-up contributions. 2. **Employer match.** The company may make matching contributions based on a formula stated in the plan document, such as a percentage of employee deferrals up to a specified compensation cap. 3. **Vesting schedule.** Employer contributions vest according to the plan's vesting schedule, which may be immediate or graded/cliff vesting as permitted by law. 4. **Payroll administration.** Payroll will apply contribution elections to eligible compensation in a timely manner and will coordinate corrections if payroll errors occur. 5. **Non-discrimination.** The company will monitor plan operations to support compliance with applicable nondiscrimination testing and related tax qualification requirements.

1. **Incoming rollovers.** The plan may accept rollovers from eligible qualified plans or IRAs if permitted by the plan document and recordkeeper rules. 2. **Verification.** Participants must provide required documentation showing the source, tax status, and eligibility of rollover funds. 3. **Processing.** HR, Payroll, or the recordkeeper will process approved rollovers after verification and within normal administrative timelines. 4. **Distributions.** Distributions, hardship withdrawals, loans, and required minimum distributions will be handled only as allowed by the plan document and applicable law. 5. **Tax reporting.** The company will issue or coordinate required tax forms and notices as required by law.

**HR / Benefits Team:** Maintain the plan summary, coordinate employee communications, and escalate policy questions to the plan administrator. **Payroll:** Apply contribution elections, employer match calculations, and corrections based on approved plan rules and payroll deadlines. **Plan Administrator:** Interpret the plan document, coordinate with the recordkeeper, manage notices, and oversee compliance testing and corrections. **Employees:** Review plan materials, make timely elections, keep beneficiary information current, and notify HR of changes affecting eligibility or payroll deductions.

The company will administer this policy in good faith and in accordance with ERISA, the Internal Revenue Code, FLSA wage and hour rules, and applicable EEOC requirements. If a conflict exists between this policy and the plan document, the plan document controls. Requests for exceptions must be reviewed by HR and the plan administrator and approved only if consistent with the plan document and applicable law. Any exception must be documented in writing. Failure to follow this policy, including misrepresentation of eligibility, unauthorized changes to elections, or misuse of plan assets, may result in corrective action up to and including termination of employment, subject to applicable law and any required due process. This policy does not limit employees' rights to engage in protected concerted activity under the NLRA.

This policy will be reviewed at least annually and whenever there are material changes to the plan document, IRS limits, SECURE Act requirements, recordkeeper processes, or applicable law. Revisions must be approved by the policy holder and communicated to affected employees as needed.