Run: Americans with Disabilities Act Accommodation Policy

This policy establishes a consistent process for requesting, evaluating, approving, implementing, and reviewing **reasonable accommodations** for qualified individuals with disabilities, in accordance with the **Americans with Disabilities Act (ADA)** and applicable EEOC guidance. The company is committed to engaging in a **good-faith interactive process** to determine whether an effective accommodation can be provided without causing undue hardship. This policy is intended to support equal employment opportunity, access to the workplace, and compliance with federal and applicable state or local laws.

This policy applies to: - All employees, including full-time, part-time, temporary, and seasonal employees - Job applicants requesting accommodation during the hiring process - Managers, supervisors, HR personnel, and other individuals involved in evaluating or implementing accommodations This policy covers accommodations related to job application, hiring, essential job functions, workplace access, schedules, equipment, communication, leave, and other employment-related conditions. It does not limit rights available under other laws, including the **Family and Medical Leave Act (FMLA)**, state leave laws, workers' compensation laws, or collective bargaining agreements.

**Disability:** A physical or mental impairment that substantially limits one or more major life activities, a record of such an impairment, or being regarded as having such an impairment, as defined by the ADA. **Qualified individual:** An individual who satisfies the skill, experience, education, and other job-related requirements of the position and can perform the **essential function** of the job with or without reasonable accommodation. **Reasonable accommodation:** A modification or adjustment to a job, work environment, or employment practice that enables a qualified individual with a disability to perform essential job functions or enjoy equal employment opportunities. **Interactive process:** A timely, collaborative, and individualized dialogue between the company and the requestor to identify potential accommodations. **Undue hardship:** Significant difficulty or expense when considered in light of the company’s size, resources, operations, and business needs. **Essential function:** A fundamental job duty, not a marginal task.

The company will consider requests for reasonable accommodation on an individualized basis and will not discriminate against any applicant or employee because of a disability, a request for accommodation, or participation in the accommodation process. The company will: - Promptly review accommodation requests - Engage in the interactive process in good faith - Request only documentation that is job-related and consistent with business necessity when medical information is needed - Consider effective accommodations that do not create undue hardship - Maintain confidentiality of disability-related information to the extent required by law - Implement approved accommodations in a timely manner and monitor effectiveness The company may choose among effective accommodations and is not required to provide the requestor’s preferred accommodation if another effective option is available.

### 1. How to Request an Accommodation An employee or applicant may request an accommodation verbally or in writing from HR, a supervisor, or another designated company contact. Requests should identify the limitation or barrier and the type of accommodation needed, if known. ### 2. Initial Review HR will acknowledge the request, gather relevant information, and determine whether the individual is a qualified individual with a disability and whether the requested accommodation is job-related and reasonable. ### 3. Interactive Process HR or a designated representative will discuss the request with the individual to understand the limitation, essential job functions, potential accommodations, and any alternative options. The company may request medical documentation when the disability or need for accommodation is not obvious. ### 4. Evaluation and Decision The company will evaluate whether the requested accommodation is effective and whether it would create undue hardship. The company may consult with the employee’s manager, IT, facilities, safety, or other stakeholders as needed, while limiting disclosure to those with a business need to know. ### 5. Implementation Approved accommodations will be documented, assigned an owner, and implemented as soon as practicable. HR will communicate any necessary instructions to the employee and relevant personnel without disclosing confidential medical details. ### 6. Monitoring and Reassessment The company may review accommodations periodically or when job duties, work conditions, or the employee’s needs change. If an accommodation is ineffective, the company will re-enter the interactive process. ### 7. Denials and Alternatives If a request is denied, HR will document the reason, including any undue hardship or inability to provide an effective accommodation, and will consider alternative accommodations when available.

**Employees / Applicants** - Request accommodations when needed - Provide information reasonably necessary to evaluate the request - Participate in the interactive process in good faith - Notify HR if an approved accommodation is not effective **Managers / Supervisors** - Refer accommodation requests to HR promptly - Avoid making unilateral decisions about disability-related requests - Maintain confidentiality and only share information on a need-to-know basis - Support implementation of approved accommodations **Human Resources** - Coordinate the interactive process - Evaluate documentation and consult with stakeholders - Maintain accommodation records separately from personnel files where required - Communicate decisions and follow-up actions **Compliance / Legal** - Advise on complex requests, undue hardship analysis, and jurisdiction-specific requirements - Review denials, exceptions, and litigation-sensitive matters

Failure to follow this policy may delay or impair the company’s ability to evaluate accommodation requests and may result in corrective action, up to and including discipline, for employees or managers who intentionally fail to cooperate, disclose confidential information improperly, retaliate, or otherwise violate company policy. Nothing in this policy limits an employee’s rights to request accommodation, file a charge with the EEOC or a state agency, or pursue rights under applicable law. Retaliation for requesting an accommodation or participating in the interactive process is prohibited.

This policy will be reviewed at least annually and updated as needed to reflect changes in federal, state, or local law, EEOC guidance, operational requirements, or company practices. California employees: additional leave, disability-discrimination, and privacy requirements may apply under the California Fair Employment and Housing Act (FEHA) and related regulations. All accommodation records will be handled in accordance with applicable confidentiality and privacy requirements, including any state privacy laws that apply to disability-related information.