Run: Gender Transition at Work Policy

This policy establishes a respectful, consistent, and confidential process for supporting employees who are undergoing gender transition at work. It is intended to promote equal employment opportunity, prevent discrimination and harassment, and provide clear procedures for planning, facilities access, records updates, timing, and confidentiality. This policy should be applied in a manner consistent with **Title VII of the Civil Rights Act of 1964**, EEOC guidance on sex discrimination and gender identity, the **FLSA**, the **ADA** where accommodation issues arise, the **FMLA** where leave is requested and eligible, and the **NLRA** where protected concerted activity may be involved.

This policy applies to all employees, applicants, interns, temporary workers, contractors working on company premises, managers, supervisors, and HR personnel. It covers workplace transition planning, communication preferences, name and pronoun use, email and system records, dress and appearance standards, restroom and other facility access, leave coordination, confidentiality, and anti-retaliation protections. **California employees:** apply this policy consistently with California Fair Employment and Housing Act (FEHA) protections and any applicable local ordinances. **New York employees:** apply this policy consistently with the New York State Human Rights Law and any applicable local human rights requirements.

For purposes of this policy: - **Gender transition** means the process by which an employee begins to live and work in a gender different from the sex assigned at birth. - **Chosen name** means the name an employee uses in the workplace, regardless of whether it has been legally changed. - **Pronouns** means the words an employee uses to be referred to in the third person. - **Legal name** means the name reflected on government-issued or legal records. - **Essential function** means a fundamental job duty that the employee must be able to perform, with or without reasonable accommodation. - **Good-faith** means honest, timely, and cooperative participation in the interactive process. - **Documented warning** means a written record of a policy or performance concern communicated to the employee. - **PIP** means a performance improvement plan used to address performance concerns through defined expectations and timelines.

The company prohibits discrimination, harassment, and retaliation based on gender identity, gender expression, transgender status, or any other protected characteristic under applicable law. Employees may transition in the workplace at a time and pace that is appropriate for them. The company will support a transition plan developed through a good-faith, interactive process with the employee and HR, with the goal of minimizing disruption and protecting confidentiality. Managers must use the employee's chosen name and pronouns in day-to-day workplace interactions once notified, unless a legal or operational requirement requires use of a legal name in a specific record or system. No employee will be required to provide medical documentation, undergo medical treatment, or complete a legal name change as a condition of receiving workplace support, unless such documentation is specifically required by law for a particular administrative purpose.

1. **Transition planning and timing** - The employee may notify HR, a manager, or another designated contact of their transition plans. - HR will offer a confidential planning meeting to discuss timing, communication preferences, workplace support needs, and any anticipated changes to records, systems, or facilities access. - The employee controls the timing of workplace disclosure unless disclosure is required by law. 2. **Communication plan** - HR and the employee should agree on who will be informed, what information will be shared, when it will be shared, and who will communicate it. - Only personnel with a legitimate business need to know should receive transition-related information. - Managers must not disclose an employee's transition status without authorization, except as required by law. 3. **Name, pronoun, and records updates** - HR will update internal records, email display names, directory listings, badges, and other systems as soon as practicable after receiving the employee's request and any required supporting information. - Legal-name records will be maintained only where required for payroll, tax, benefits, background checks, or other legal compliance purposes. - Where a legal name must remain in a system, access should be restricted to authorized personnel and the employee's chosen name should be used in day-to-day workplace contexts. 4. **Facilities access** - Employees may use restrooms, locker rooms, and other sex-segregated facilities consistent with their gender identity, subject to applicable law. - The company will not require an employee to use a single-user facility unless requested by the employee or required by law. - If privacy concerns arise, the company may offer optional alternatives, but may not force a transgender employee to use a separate facility. 5. **Dress and appearance** - Dress code and grooming standards must be applied consistently and in a nondiscriminatory manner. - Employees may dress in accordance with the company's dress code as applied to their gender identity, unless a specific safety or job-related requirement applies. 6. **Leave and scheduling** - If an employee requests time off for medical appointments, recovery, or related needs, HR will evaluate eligibility under applicable leave laws, including the FMLA where applicable. - Scheduling adjustments may be considered through the interactive process when they do not prevent the employee from performing the essential function of the job. 7. **Confidentiality and data handling** - Transition-related information must be treated as confidential personnel information and shared only on a need-to-know basis. - HR must limit access to records containing legal names, prior names, or sensitive personal information. - Any collection, storage, or transfer of personal data must follow applicable privacy requirements, including GDPR or CCPA where applicable.

**Employee** - Communicate transition-related needs to HR or management as early as practicable if workplace support is requested. - Identify preferred name, pronouns, timing, and communication preferences. - Participate in the interactive process in good faith. **Manager / Supervisor** - Use the employee's chosen name and pronouns. - Maintain confidentiality and escalate requests to HR. - Avoid speculation, gossip, or unauthorized disclosure. **HR / People Operations** - Coordinate the transition plan and records updates. - Ensure facilities access, leave coordination, and policy application are consistent and lawful. - Maintain confidential records and limit access to authorized personnel only. **Legal / Compliance** - Review jurisdiction-specific requirements, including state or local protections. - Advise on any legal-name, payroll, tax, or benefits documentation constraints. **All Employees** - Treat coworkers with respect and refrain from harassment, misgendering, or retaliation.

Violations of this policy, including harassment, intentional misgendering, outing an employee without authorization, retaliation, or refusal to follow approved procedures, may result in corrective action up to and including termination. Performance concerns must be handled separately from transition status and based on documented, job-related criteria. Managers must not use a transition, request for accommodation, or protected complaint as a basis for a **documented warning** or **PIP** unless the performance issue is independently supported by objective evidence. Employees are encouraged to report concerns promptly to HR, Legal, or another designated reporting channel. Reports will be investigated in a timely and impartial manner. **California employees:** retaliation protections may also apply under FEHA and related state law. **New York employees:** whistleblower protections may apply where an employee reports unlawful conduct in good faith.

This policy will be reviewed at least annually and updated as needed to reflect changes in applicable law, operational requirements, and best practices. The policy holder is responsible for ensuring that revisions are approved by HR and Legal before publication. Any revised version should include a new version number and effective date.