Run: Anti-Retaliation Policy

The purpose of this policy is to prohibit retaliation against any employee, applicant, contractor, or other covered individual who in good faith reports a concern, participates in an investigation, requests a workplace accommodation, or otherwise exercises a protected right under applicable law. This policy is intended to support compliance with federal and state anti-retaliation protections, including the EEOC's retaliation guidance and the Fair Labor Standards Act (FLSA) retaliation provisions enforced by the U.S. Department of Labor.

This policy applies to all employees, managers, supervisors, officers, and any third party acting on behalf of the company. It applies to conduct occurring in the workplace, during work-related travel, at company-sponsored events, in remote work settings, and in any employment-related communication or decision-making process. California employees: this policy is applied consistently with California Labor Code protections and any applicable local whistleblower or retaliation rules. Other state-specific protections may apply where required by law.

**Retaliation** means any adverse action or threat of adverse action taken because an individual engaged in protected activity. **Protected activity** includes, without limitation, reporting discrimination, harassment, wage-and-hour concerns, safety issues, fraud, policy violations, or other unlawful conduct; participating in an investigation; requesting a reasonable accommodation through the interactive process; taking protected leave; or engaging in concerted activity protected by Section 7 of the NLRA. **Good-faith report** means a report made honestly, even if the concern is later found to be unsubstantiated. **Adverse action** includes termination, demotion, reduced hours, undesirable reassignment, exclusion from opportunities, negative scheduling changes, threats, intimidation, discipline without a documented warning basis, or interference with pay, benefits, or working conditions.

The company strictly prohibits retaliation in any form. No policy holder, manager, supervisor, or employee may retaliate against an individual for: - Making a good-faith report or complaint; - Participating in or cooperating with an investigation; - Opposing conduct believed in good faith to violate law or company policy; - Requesting a reasonable accommodation or leave protected by law; - Reporting wage, hour, safety, discrimination, harassment, or whistleblower concerns; or - Exercising any other protected right under applicable law. Retaliation is a serious violation of this policy and may result in disciplinary action up to and including termination.

Examples of retaliation include, but are not limited to: - Firing, suspending, or demoting an employee after a complaint is made; - Cutting hours, pay, or shifts because an employee reported a concern; - Giving a negative performance review that is not supported by documented performance issues; - Excluding an employee from meetings, training, or assignments because they participated in an investigation; - Threatening immigration, immigration-status, or job-related consequences for reporting concerns; - Increasing scrutiny, micromanagement, or discipline in response to protected activity; - Creating a hostile work environment or spreading rumors because an employee raised a complaint. Legitimate, non-retaliatory employment actions based on documented performance, attendance, conduct, or business needs are permitted when applied consistently and in good faith.

Employees are encouraged to report retaliation concerns promptly using any of the following channels: - Their manager, if the manager is not involved in the concern; - Human Resources; - A designated compliance or ethics contact; - A confidential hotline or reporting portal, if available. Reports should include, when possible, the date, persons involved, witnesses, and a description of the conduct. Reports may be made verbally or in writing. Employees are not required to prove retaliation before reporting a concern. If the concern involves the employee's manager, the employee may report directly to HR or another designated reporting channel.

The company will review retaliation complaints promptly, fairly, and as confidentially as practicable. The investigation process may include: - Initial intake and risk assessment; - Interviews with the reporting employee, witnesses, and relevant managers; - Review of documents, schedules, messages, performance records, and other relevant information; - Interim measures to protect the reporting individual when appropriate; - Findings and determination based on the available facts. If retaliation is found, the company will take prompt corrective action, which may include discipline, reversal of adverse actions where feasible, training, coaching, or other remedial measures. The company will also take steps to prevent recurrence and may monitor the workplace for follow-up concerns.

**Employees** must report retaliation concerns in good faith and cooperate truthfully in investigations. **Managers and supervisors** must not discourage reports, must escalate concerns promptly, and must avoid any action that could reasonably be perceived as retaliatory. **Human Resources / Compliance** must document complaints, coordinate investigations, maintain confidentiality to the extent possible, and ensure corrective action is implemented when warranted. **Policy holders** are responsible for modeling non-retaliatory conduct and ensuring decisions are based on legitimate, documented business reasons.

Violations of this policy may result in disciplinary action up to and including termination of employment, removal from supervisory duties, contract termination, or other corrective action appropriate to the circumstances. False or malicious reports made knowingly in bad faith are also prohibited and may result in discipline. However, a report made in good faith will not be treated as a violation simply because it is not substantiated. Nothing in this policy is intended to interfere with rights protected by the NLRA, FLSA, FMLA, ADA, Title VII, or any other applicable law.

This policy will be reviewed at least annually and updated as needed to reflect changes in law, regulatory guidance, and company practices. Jurisdiction-specific carve-outs or additional protections will be applied where required, including state whistleblower, wage-and-hour, leave, and anti-discrimination laws.