California Pay Transparency Addendum (SB 1162)

This addendum establishes the company’s procedures for complying with California pay transparency requirements, including pay-scale disclosure in covered job postings, disclosure of pay-scale information to current employees upon request, and pay-data reporting obligations for covered employers.

This policy is intended to support lawful, consistent, and documented compensation communications and reporting practices.

This addendum applies to California employees, California-based roles, and any recruiting, compensation, or HR personnel involved in posting jobs, making offers, responding to compensation inquiries, or preparing pay-data reports.

California employees: if a position can be performed in California, or if the role is tied to a California work location, the pay transparency requirements in this addendum may apply.

This addendum should be read together with the company’s equal opportunity, compensation, recruiting, and recordkeeping policies.

Pay scale means the salary or hourly wage range that the company reasonably expects to pay for the position at the time of posting or disclosure.

Covered employer means an employer subject to California pay transparency requirements, including employers with 15 or more employees for job posting disclosure and employers with 100 or more employees for pay-data reporting.

Job posting means any public or internal posting used to recruit applicants for a position.

Pay data report means the annual report of employee pay and demographic data required by California law for covered employers.

Current employee means an individual actively employed by the company at the time a pay-scale request is made.

The company will disclose the pay scale for covered positions in job postings as required by California law.

The company will provide pay-scale information to current employees upon request for their current position or a position to which they are being considered, consistent with applicable law.

The company will prepare and submit required pay-data reports for covered California employees and maintain records supporting those reports.

The company prohibits retaliation against any employee or applicant who requests pay-scale information, raises a concern about pay transparency, or participates in a lawful investigation or reporting process.

1. Job Posting Pay-Scale Disclosure
   • For covered California positions, the recruiter or hiring manager must include the pay scale in the job posting before the posting is published.
   • The pay scale must be reviewed by HR or Compensation for consistency with internal pay bands and the role’s essential function requirements.
   • If the role is remote or hybrid and may be performed by California applicants, HR must determine whether California disclosure rules apply before posting.
2. Current Employee Pay-Scale Requests
   • Current employees may request the pay scale for their current position or a position they are being considered for.
   • HR must respond in good faith and without retaliation.
   • Responses should be documented and retained in accordance with the company’s recordkeeping practices.
3. Pay-Data Reporting
   • For employers subject to California pay-data reporting, HR or People Operations must collect the required employee data, validate the report, and submit it by the applicable deadline.
   • Data should be reviewed for completeness, accuracy, and consistency before submission.
   • Any corrections identified after submission must be documented and escalated to Compliance.
4. Recordkeeping
   • Maintain copies of job postings, pay-scale disclosures, employee requests, responses, and submitted pay-data reports for the period required by law and company policy.
   • Access to compensation and reporting records must be limited to authorized personnel only.

HR / People Operations: Owns policy administration, employee request handling, and pay-data reporting preparation.

Recruiting / Hiring Managers: Ensure job postings include approved pay-scale information before publication.

Compensation: Maintains pay bands, validates salary ranges, and supports consistency reviews.

Compliance / Legal: Interprets legal requirements, reviews exceptions, and approves corrective actions.

Policy holder: Each manager and HR representative responsible for a covered posting or request must follow this addendum and escalate questions promptly.

Failure to follow this addendum may result in corrective action, up to and including removal of posting authority, documented warning, retraining, a PIP where appropriate, or other disciplinary action consistent with company policy and applicable law.

If a disclosure error, late report, or incomplete response is identified, HR must investigate promptly, correct the issue where possible, and document the remediation steps.

Nothing in this addendum limits employee rights under the NLRA, EEOC-enforced laws, FLSA, or other applicable employment laws.

Any exception to this addendum must be approved in writing by HR and Legal.

California employees: no exception may be used to avoid a legally required pay-scale disclosure or pay-data reporting obligation.

If a conflict exists between this addendum and applicable law, the law controls.

This addendum will be reviewed at least annually and whenever California pay transparency laws, reporting obligations, or related guidance change.

Revisions must be approved by HR, Compliance, and Legal before being issued to employees or used in recruiting workflows.