Run: Anti-Nepotism Policy

This policy establishes standards for identifying, disclosing, and managing family, romantic, and close personal relationships in the workplace to reduce conflicts of interest, favoritism, and the appearance of impropriety. The policy is intended to support fair employment decisions and consistent management practices, while respecting applicable legal requirements, including EEOC guidance under Title VII of the Civil Rights Act of 1964. This policy is not intended to restrict protected concerted activity under Section 7 of the NLRA or otherwise interfere with rights protected by law.

This policy applies to all employees, applicants, interns, temporary workers, contractors where contract terms permit, managers, supervisors, and executives. It applies to relationships that exist at the time of hire or develop during employment. California employees: any reassignment, discipline, or employment action under this policy will be applied consistently and in a manner that does not discriminate on the basis of a protected characteristic under applicable law. Additional local or state law requirements will be followed where they apply.

For purposes of this policy: - **Family member** means a spouse, domestic partner, parent, child, sibling, grandparent, grandchild, in-law, or other relative recognized by applicable law or company policy. - **Close personal relationship** means a relationship that could reasonably create favoritism, bias, or a conflict of interest. - **Reporting line** means any direct or indirect supervisory relationship, including authority over hiring, pay, scheduling, performance evaluation, discipline, promotion, or termination. - **Conflict of interest** means a situation where a personal relationship may affect, or appear to affect, objective business judgment. - **Disclosure** means prompt written notice to HR or another designated contact about a relationship that may create a conflict. Where a state or local law defines covered relationships more broadly, the broader definition will apply.

The company prohibits employment decisions that create an actual or perceived conflict of interest based on family or close personal relationships. The company will not knowingly place one employee in a direct reporting relationship over a family member or close personal contact. The company may also restrict indirect reporting relationships, shared decision-making authority, or access to confidential personnel information when necessary to prevent bias, favoritism, or the appearance of favoritism. The company will make employment decisions based on legitimate business needs, qualifications, performance, and operational requirements, consistent with applicable law, including Title VII, the ADA interactive process where accommodation issues arise, and the FLSA where classification or overtime decisions are implicated.

1. **Disclosure requirement.** Employees must promptly disclose any family or close personal relationship that could create a conflict of interest, especially if the relationship involves the same department, work location, project, vendor relationship, or reporting chain. 2. **Hiring and transfer review.** Before hiring, transferring, or promoting an employee into a role that may create a conflict, HR and the hiring manager must review the reporting structure and decision-making authority. 3. **Restriction on supervision.** No employee may directly supervise, evaluate, discipline, approve pay for, or have final authority over the employment status of a family member or close personal contact. 4. **Conflict management.** If a conflict exists or may reasonably be perceived, the company may implement one or more good-faith measures, including reassignment, reporting-line changes, recusal from decisions, removal of access to confidential records, or other operational controls. 5. **Documentation.** HR will document the disclosure, review, decision, and any corrective action in a confidential file with access limited to a need-to-know basis. 6. **Ongoing duty.** Employees must update their disclosure if a relationship changes or if a new reporting or business relationship creates a potential conflict. Employees should not wait until a conflict becomes unavoidable; disclosure must be made as soon as the employee becomes aware of the issue.

**Employees** must disclose covered relationships promptly and cooperate in good-faith resolution efforts. **Managers and supervisors** must avoid participating in decisions where a family or close personal relationship could affect objectivity and must notify HR immediately when a potential conflict is identified. **HR** will review disclosures, coordinate any reassignment or reporting-line changes, maintain records, and ensure consistent application of the policy. **Executives** must support enforcement of this policy and ensure that business needs are balanced with fairness, confidentiality, and legal compliance. **Legal/Compliance** should be consulted when a proposed action may implicate protected activity, discrimination risk, wage-and-hour issues, or state-specific requirements.

Failure to disclose a covered relationship, refusal to cooperate with a conflict review, or intentional concealment of relevant information may result in corrective action, up to and including a documented warning, removal from decision-making authority, reassignment, demotion, or termination, consistent with applicable law and company practice. The company may approve a limited exception only when HR and management determine in good faith that the relationship does not create an actual or perceived conflict, or when a conflict can be effectively managed through controls. Nothing in this policy will be applied in a way that interferes with rights protected by the NLRA, FMLA leave rights, ADA reasonable accommodation obligations, or other applicable law.

This policy will be reviewed at least annually and updated as needed to reflect operational changes, legal developments, and jurisdiction-specific requirements. California employees and other state-specific populations will be reviewed for any applicable local overlay before implementation. Any revisions must be approved by HR and, where appropriate, Legal or Compliance before publication.