Run: Diversity, Equity, and Inclusion Policy

The purpose of this policy is to establish the organization's commitment to diversity, equity, and inclusion in employment practices, workplace culture, compensation practices, and supplier relationships. The organization seeks to provide equal employment opportunity and to make decisions based on merit, business need, and lawful, job-related criteria. This policy is intended to support compliance with applicable federal, state, and local laws, including **Title VII of the Civil Rights Act of 1964**, the **Equal Pay Act of 1963**, the **Americans with Disabilities Act (ADA)**, the **Age Discrimination in Employment Act (ADEA)**, and other applicable anti-discrimination laws.

This policy applies to all employees, applicants, interns, temporary workers, contractors where applicable, managers, supervisors, and leaders. It also applies to employment-related decisions, including recruitment, hiring, onboarding, training, promotion, compensation, performance management, discipline, termination, and supplier selection. **Applicable jurisdictions:** United States. Where state or local law provides greater protection than this policy, the more protective law will apply. **California employees:** Requests for reasonable accommodation, leave coordination, and harassment or discrimination complaints must be handled consistent with California law and any applicable company procedures. **New York employees:** Reports of retaliation or whistleblower concerns will be handled consistent with applicable New York law, including New York Labor Law Section 740 where relevant.

For purposes of this policy: - **Protected characteristic** means a characteristic protected by applicable law, including race, color, religion, sex, pregnancy, sexual orientation, gender identity, national origin, age, disability, veteran status, and any other category protected by law. - **Interactive process** means a timely, good-faith dialogue between the organization and the employee or applicant to evaluate a request for reasonable accommodation. - **Essential function** means a fundamental job duty of the position, not a marginal task. - **Good-faith** means honest, timely, and cooperative participation in a process or investigation. - **Documented warning** means a written record of a policy violation, performance issue, or corrective action. - **PIP** means a performance improvement plan with measurable expectations, timelines, and follow-up.

The organization prohibits discrimination, harassment, and retaliation based on any protected characteristic or any other status protected by law. Employment decisions must be based on job-related qualifications, performance, business needs, and lawful criteria. The organization is committed to: 1. Recruiting from broad and diverse candidate pools. 2. Using structured, job-related selection criteria. 3. Providing equitable access to training, mentoring, and advancement opportunities. 4. Reviewing compensation practices for pay equity. 5. Supporting an inclusive workplace where employees can contribute without fear of bias or retaliation. 6. Expanding supplier diversity where consistent with business needs, quality, and legal requirements. 7. Holding leaders accountable for compliance and measurable progress.

### 1) Recruitment and Hiring - Job descriptions must identify essential functions and required qualifications. - Interview questions must be job-related and applied consistently. - Hiring panels should include trained interviewers where practical. - Recruiting efforts should seek qualified candidates from diverse sources. - Selection decisions must be documented using lawful, objective criteria. ### 2) Development and Advancement - Employees should have equitable access to training, stretch assignments, mentoring, and promotion opportunities. - Managers must use documented criteria for performance reviews and promotion recommendations. - Development opportunities should not be limited based on protected characteristics or assumptions. ### 3) Pay Equity Review - Compensation decisions must be based on legitimate factors such as role, experience, skills, performance, market data, and location. - HR or Compensation will periodically review pay practices for unexplained disparities. - Any identified disparities will be evaluated and addressed through a documented, good-faith review process. - Employees may raise pay equity concerns without retaliation. ### 4) Supplier Diversity - Procurement teams should consider qualified diverse-owned suppliers when appropriate. - Supplier selection must remain based on business needs, quality, price, service, risk, and legal requirements. - Where feasible, sourcing teams should track diverse supplier participation and report results to leadership. ### 5) Reporting and Investigation - Employees may report concerns to their manager, HR, Compliance, or any designated reporting channel. - Reports will be reviewed promptly, confidentially to the extent practicable, and without retaliation. - Investigations will be conducted in good faith, and corrective action will be taken when warranted. ### 6) Reasonable Accommodation - Requests for accommodation will be handled through the interactive process. - HR and the manager will evaluate the request, identify the essential function at issue, and determine whether a reasonable accommodation can be provided without undue hardship.

**Leadership:** Set expectations, allocate resources, and review DEI metrics and action plans. **Managers:** Apply fair hiring, development, and performance practices; escalate concerns promptly; support the interactive process when accommodation requests arise. **HR:** Maintain policy guidance, support investigations, track training and pay equity reviews, and coordinate corrective action. **Procurement:** Support supplier diversity efforts and maintain documentation of sourcing decisions. **Employees:** Treat others respectfully, participate in training as required, and report concerns in good faith.

Violations of this policy may result in corrective action, up to and including termination of employment, depending on the severity and circumstances. Corrective action may include coaching, a documented warning, retraining, reassignment, a PIP, or other appropriate measures. Retaliation against any person who raises a concern, participates in an investigation, requests accommodation, or engages in protected concerted activity under the **NLRA Section 7** is prohibited. Nothing in this policy is intended to interfere with rights protected by law, including the right to discuss wages, working conditions, or other protected concerted activity.

This policy will be reviewed at least annually and updated as needed to reflect changes in law, business practices, or organizational priorities. Any revisions must be approved by HR and leadership before publication. The policy holder is responsible for maintaining the current version, communicating material changes, and ensuring employees can access the policy.