Run: Holiday Pay Policy

This policy establishes the company’s rules for observed holidays, floating holidays, holiday pay eligibility, and premium pay for holiday work. The policy is intended to provide consistent administration, support workforce planning, and ensure compliance with applicable wage and hour and equal employment laws. **Legal note:** Federal law does not require private employers to provide paid holidays. Where holiday pay is offered, it must be administered consistently and in a manner that does not discriminate on the basis of a protected class under **Title VII of the Civil Rights Act of 1964** and related **EEOC** guidance.

This policy applies to all employees of the company unless a written exception is approved by Human Resources and the policy holder. **Applicable jurisdictions:** United States. State-specific requirements, if any, will be applied as carve-outs and will supersede this policy where required by law. **Applicable roles:** All employees, unless a role-specific exception is documented in an offer letter, collective bargaining agreement, or written employment agreement.

### Observed holidays The company will publish its annual list of observed holidays before the start of each calendar year. The list may include federal holidays, company-designated holidays, or both. ### Eligibility for holiday pay Holiday pay eligibility is based on the employee’s classification and status on the scheduled workday before and after the holiday, unless state law requires a different rule. Eligible employees generally include: - Full-time regular employees - Part-time employees, if specifically designated as eligible in the offer letter or local addendum - Non-exempt employees, subject to timekeeping and attendance requirements Ineligible employees generally include: - Temporary employees - Independent contractors - Interns, unless specifically stated otherwise - Employees on unpaid leave, unless required by law or approved in writing ### Floating holidays Floating holidays may be granted to eligible employees as a separate paid benefit. Unless otherwise stated, floating holidays must be used within the calendar year and are not paid out at separation, subject to applicable state law.

### 1. Company-observed holidays The company will designate the holidays it observes each year. Observed holidays may vary by location, business unit, or operational need. ### 2. Holiday pay eligibility requirements To receive holiday pay, an employee must generally: - Be actively employed on the day before and the day after the holiday - Be in good standing and not subject to a documented warning for attendance abuse related to holiday scheduling - Meet any minimum service requirement stated in the employee handbook or local addendum - Comply with timekeeping and attendance procedures ### 3. Floating holiday use Eligible employees may request floating holidays in advance through the company’s leave request process. Approval is subject to staffing needs, business continuity, and manager review. ### 4. Premium pay for holiday work If the company offers premium pay for working on a holiday, the amount and method of calculation will be stated in the annual holiday schedule or employee handbook addendum. Unless otherwise required by law or a written agreement, premium pay is discretionary and does not apply to all roles. ### 5. FLSA overtime treatment Holiday pay and premium pay will be administered in accordance with the **Fair Labor Standards Act (FLSA)**. For non-exempt employees, holiday hours that are not actually worked generally do not count as hours worked for overtime purposes unless required by law or company policy. Any premium pay that qualifies as overtime must be calculated using the employee’s regular rate of pay and applicable overtime rules. ### 6. Leave interactions Holiday pay may be affected by approved leave, including FMLA leave, unpaid leave, or other protected leave. The company will apply leave and holiday rules consistently and will not interfere with protected rights under the **FMLA**, **ADA**, or other applicable laws.

### Holiday schedule publication 1. HR will publish the annual holiday schedule before the start of the calendar year. 2. The schedule will identify observed holidays, any floating holiday allocation, and any premium pay rules. 3. Location-specific or state-specific exceptions will be documented separately. ### Requesting a floating holiday 1. The employee submits a request through the standard time-off system. 2. The manager reviews the request based on staffing and operational needs. 3. HR may deny or reschedule requests made during peak business periods, provided the decision is applied consistently. ### Holiday work approval 1. Managers must obtain approval before assigning holiday work when operationally feasible. 2. Non-exempt employees must accurately record all hours worked. 3. Any premium pay or overtime must be reviewed by Payroll before processing. ### Disputes and accommodations If an employee believes a holiday rule conflicts with a sincerely held religious practice or other protected need, the employee should contact HR to begin the interactive process. The company will consider reasonable accommodation unless doing so would create undue hardship.

### HR / Policy holder - Maintain the annual holiday schedule - Review eligibility rules and state-specific carve-outs - Coordinate with Payroll on premium pay and overtime treatment - Ensure consistent administration and recordkeeping ### Managers - Approve or deny floating holiday requests based on business needs - Ensure holiday staffing decisions are applied consistently - Escalate accommodation requests to HR promptly ### Payroll - Process holiday pay, floating holiday pay, and premium pay accurately - Confirm FLSA treatment for non-exempt employees - Retain payroll records in accordance with company retention requirements ### Employees - Review the holiday schedule and submit requests on time - Accurately report hours worked and leave taken - Notify HR of any request for religious accommodation or other protected leave interaction

### Compliance The company will administer this policy in a manner consistent with applicable federal, state, and local law, including the **FLSA**, **Title VII**, **EEOC** guidance, and any applicable leave or wage payment laws. ### State-specific carve-outs - **California employees:** Holiday pay, meal/rest break, wage statement, and final pay rules will be applied in accordance with California law where applicable. - **New York employees:** Any applicable wage payment or leave-related requirements will be applied in accordance with New York law. - **Illinois employees:** Scheduling and rest-period requirements will be applied in accordance with applicable Illinois law where relevant. - **Washington employees:** Holiday pay interactions with paid sick leave or other protected leave will be administered consistently with Washington law. ### Exceptions Any exception to this policy must be approved in writing by HR and the policy holder. ### Discipline Failure to follow holiday scheduling, timekeeping, or approval procedures may result in corrective action, up to and including a documented warning, a PIP, or termination, depending on the severity and frequency of the violation.

This policy will be reviewed at least annually and updated as needed to reflect changes in business operations, payroll practices, and applicable law. The policy holder is responsible for initiating review, documenting revisions, and communicating material changes to affected employees.