Run: Employee Resource Group Policy

This policy establishes the standards for creating, governing, funding, and operating Employee Resource Groups (ERGs) in a way that supports company values, employee belonging, leadership development, and DEI goals. The policy is intended to: - Provide a consistent approval and governance framework for ERGs. - Support voluntary employee participation and inclusive engagement. - Define funding, event, and communication expectations. - Protect employee rights under applicable law, including NLRA Section 7, Title VII, ADA, FMLA, and FLSA. - Ensure ERG activities remain aligned with business objectives and respectful workplace standards.

This policy applies to all employees, managers, HR, DEI personnel, executives, and any employee-led group seeking ERG recognition, funding, or company support. This policy applies to ERGs operating in the United States and may be supplemented by state-specific requirements or local legal review. California employees: ERG-related training, event access, and participation practices must be reviewed for compliance with applicable California anti-discrimination and wage-and-hour rules. New York employees: ERG communications and reporting must be managed consistently with applicable privacy and whistleblower protections. Washington employees: paid sick leave and leave-related scheduling must be respected when ERG activities intersect with time off.

For purposes of this policy, the following terms apply: - **ERG**: A voluntary, employee-led group formed to foster inclusion, community, development, and advocacy. - **ERG sponsor**: A leader who supports the ERG, helps remove barriers, and escalates issues as needed. - **ERG charter**: The approved document that defines the ERG's mission, leadership, membership, activities, and budget request. - **ERG leadership team**: Employees designated to coordinate meetings, events, communications, and reporting. - **Company resources**: Budget, meeting space, collaboration tools, branding assets, and administrative support approved for ERG use. - **Protected activity**: Activity protected by law, including concerted activity under NLRA Section 7 and requests for reasonable accommodation under the ADA interactive process.

The company may recognize ERGs that support inclusion, employee engagement, and business objectives, provided the ERG: 1. Is voluntary and open in a manner consistent with this policy and applicable law. 2. Operates under an approved charter and designated leadership structure. 3. Maintains respectful, non-discriminatory, and professional conduct. 4. Uses company funds and resources only for approved purposes. 5. Does not interfere with work performance, essential functions, or business operations. 6. Does not restrict protected employee speech or concerted activity under the NLRA. 7. Does not create unlawful employment preferences, exclusion, or retaliation. 8. Complies with all applicable laws, including Title VII, ADA, FLSA, FMLA, and any state-specific requirements.

## 1. ERG formation and approval - Employees proposing an ERG must submit an ERG charter to HR or the policy holder. - The charter must include the ERG's purpose, intended membership, leadership roles, sponsor, planned activities, and budget request. - HR, DEI, and Legal (as needed) will review the proposal for alignment with company values, business needs, and legal compliance. - Approval decisions must be documented in good faith and based on objective criteria. ## 2. Leadership and governance - Each ERG must have at least one employee lead and one executive or senior sponsor. - ERG leaders are responsible for scheduling meetings, maintaining records, coordinating events, and submitting required reports. - Sponsors may advise and advocate but may not control protected employee discussions or retaliate against concerns raised by members. ## 3. Funding and resource requests - ERGs may request annual or event-based funding subject to budget availability and approval. - Approved expenses may include meeting supplies, speaker fees, educational materials, and approved event costs. - ERG funds may not be used for personal gifts, political contributions, discriminatory activities, or unapproved reimbursements. - Any reimbursement must follow the company's expense policy and documentation requirements. ## 4. Meetings, events, and communications - ERG meetings and events must be scheduled in a way that minimizes disruption to work and respects essential functions. - Participation must be voluntary and may not be used as a condition of employment, promotion, or performance evaluation. - ERG communications must be professional, respectful, and consistent with company communication standards. - If an ERG event includes accessibility needs, the ERG must coordinate through the interactive process to determine reasonable accommodation. ## 5. Timekeeping and pay compliance - Non-exempt employees must accurately record all time worked, including any ERG-related work performed outside scheduled hours. - Managers and ERG leaders must not encourage off-the-clock work. - If ERG duties are assigned as part of an employee's job, HR must review whether the time is compensable under the FLSA. ## 6. Records and reporting - ERGs must maintain basic records of leadership, membership participation, approved budgets, events, and outcomes. - Reports should focus on participation trends, engagement, and business impact without collecting unnecessary sensitive personal data. - Any collection of demographic or other personal information must follow privacy, data minimization, and retention requirements.

- **Policy holder**: Owns the policy, approves standards, and coordinates periodic review. - **HR / People Operations**: Reviews ERG charters, monitors compliance, supports investigations, and maintains records. - **DEI team**: Advises on ERG strategy, inclusion goals, programming, and measurement. - **Legal / Compliance**: Reviews legal risk, protected activity concerns, and jurisdiction-specific requirements. - **Executives / Sponsors**: Provide visible support, remove barriers, and ensure ERGs have appropriate access to resources. - **ERG leaders**: Operate the ERG in accordance with the approved charter, budget, and conduct expectations. - **Managers**: Support participation when reasonable, avoid retaliation, and ensure work coverage for essential functions. - **Employees**: Participate voluntarily, follow conduct expectations, and report concerns through established channels.

Violations of this policy may result in corrective action, up to and including removal of ERG leadership privileges, revocation of funding, documented warning, PIP where performance issues are involved, or other disciplinary action consistent with company policy and applicable law. The company will not discipline employees for engaging in protected activity, requesting reasonable accommodation, or raising good-faith concerns about discrimination, harassment, retaliation, wages, hours, or working conditions. Exceptions to this policy must be approved in writing by HR and Legal, where appropriate. Any exception must be documented with the business reason, duration, and compliance review. If an ERG activity conflicts with safety, business continuity, confidentiality, or legal obligations, the company may modify, postpone, or cancel the activity after good-faith review.

This policy will be reviewed at least annually and updated as needed to reflect changes in business needs, DEI strategy, and applicable law. The policy holder is responsible for maintaining the current version, documenting revisions, and communicating material changes to affected employees and ERG leaders. Any changes affecting protected activity, compensation, privacy, or accessibility should be reviewed by Legal before implementation.