Run: California Lactation Accommodation Addendum (AB 1976)

This addendum explains the Company's lactation accommodation requirements for California employees. It is intended to ensure that employees who are nursing or expressing milk have access to a compliant, private space, reasonable break time, and refrigeration access as required by California law.

This policy applies to all California employees, including full-time, part-time, exempt, non-exempt, temporary, and seasonal employees, as well as managers and supervisors responsible for implementing accommodations. If a local ordinance provides greater protection, the Company will follow the more protective requirement.

**Lactation accommodation:** The workplace arrangements provided to support an employee who needs to express milk. **Private space:** A location that is shielded from view and free from intrusion, and that is not a bathroom. **Reasonable break time:** Time provided to an employee to express milk as needed, which may run concurrently with other break periods when feasible. **Policy holder:** The HR leader or designated manager responsible for maintaining this addendum and coordinating compliance.

The Company will provide California employees with the following, as required by law: 1. **Private lactation space.** A private location close to the employee's work area, shielded from view and free from intrusion, that is not a bathroom. 2. **Reasonable break time.** Reasonable break time for an employee to express milk each time the employee has a need to do so. 3. **Refrigeration access.** Access to a refrigerator or other appropriate cooling device for storing expressed milk, where available and consistent with workplace operations. 4. **No retaliation.** Employees will not be disciplined, penalized, or retaliated against for requesting or using lactation accommodations. California employees: if the standard workplace configuration does not provide a compliant room, the Company will identify a temporary or alternative compliant space that meets the privacy and non-bathroom requirements.

1. The employee should notify HR, their manager, or another designated contact as soon as practicable. 2. HR will confirm the request and coordinate with the employee to identify a compliant space and schedule. 3. The Company will engage in a good-faith, interactive process if any barrier or workplace constraint affects implementation. 4. The employee may request adjustments if the assigned space is not sufficiently private, is a bathroom, or is otherwise unavailable. 5. Managers must escalate unresolved issues to HR immediately and may not deny a request without HR review.

The designated lactation space must: - Be shielded from view and free from intrusion. - Be available when needed for lactation use. - Be located as close as practicable to the employee's work area. - Not be a bathroom. - Include a place to sit and a surface or area for a pump and related items. - Be maintained in a clean and sanitary condition. If a permanent room is not available, the Company may use a temporary space only if it remains compliant with privacy, non-bathroom, and intrusion-free requirements during use.

Employees will be provided reasonable break time to express milk. The timing and frequency of breaks may vary based on individual need. Where operationally feasible, lactation breaks should be coordinated with existing rest and meal periods, but employees will not be required to delay or shorten needed lactation time to fit a standard schedule. Non-exempt employees must record time worked in accordance with Company timekeeping procedures. Any pay treatment for break time will be administered in compliance with applicable wage and hour law.

Employees will have access to refrigeration for storing expressed milk. Employees are responsible for labeling and securing their own containers. The Company may establish reasonable storage and sanitation rules, provided those rules do not interfere with the employee's right to store expressed milk. If refrigeration is unavailable at a site, HR will identify an alternative compliant storage solution where required.

**Employees:** Notify HR or management of the need for lactation accommodation and follow reasonable storage and room-use rules. **Managers and supervisors:** Respond promptly, preserve confidentiality, and escalate issues to HR without delay. **HR / policy holder:** Coordinate the interactive process, identify compliant space and break arrangements, maintain records, and ensure the policy is applied consistently. **Facilities / operations:** Support room setup, signage, access control, cleanliness, and refrigeration availability.

Any denial, delay, or interference with a lawful lactation accommodation must be escalated to HR and reviewed promptly. Employees who believe their request was mishandled may raise concerns through the Company's complaint process without fear of retaliation. Managers or supervisors who fail to follow this policy may receive documented warning, retraining, a PIP, or other corrective action up to and including termination, depending on the severity of the violation. Retaliation against an employee for requesting or using lactation accommodations is prohibited.

This addendum will be reviewed at least annually and whenever California lactation accommodation requirements change. The policy holder is responsible for updating the addendum, coordinating legal review as needed, and communicating material changes to affected employees.