Run: Inclement Weather and Office Closure Policy

This policy establishes the procedures the company uses when severe weather, unsafe travel conditions, utility outages, or other weather-related events affect operations. It explains how closure decisions are made, how employees are notified, what is expected of essential staff, when remote work may be required or permitted, and how pay and timekeeping are handled. This policy is intended to support workplace safety, operational continuity, and consistent treatment of employees while complying with the Fair Labor Standards Act (FLSA), the National Labor Relations Act (NLRA), the Americans with Disabilities Act (ADA), the Family and Medical Leave Act (FMLA), Title VII of the Civil Rights Act of 1964, OSHA's General Duty Clause, and applicable state and local laws.

This policy applies to all employees, including full-time, part-time, temporary, and seasonal employees, unless a specific collective bargaining agreement, state law, or written employment agreement provides otherwise. It applies to all company worksites and to employees working remotely when weather conditions or emergency closures affect business operations. **California employees:** reporting-time pay, meal and rest period rules, and any applicable state wage order requirements may apply. **New York employees:** wage payment and leave obligations must be administered consistently with New York Labor Law and any applicable local rules. **Illinois employees:** scheduling and rest-period obligations must be administered consistently with the One Day Rest in Seven Act where applicable. **Washington employees:** paid sick leave and related protections must be administered consistently with Washington law when employees use protected leave during weather-related disruptions.

- **Inclement weather:** Severe or hazardous weather conditions that make travel, commuting, or on-site work unsafe or impractical. - **Office closure:** A temporary suspension of normal operations at one or more company locations. - **Essential staff:** Employees whose presence or availability is necessary to maintain critical operations, protect property, support customers, or address urgent business needs. - **Remote work:** Work performed away from a company worksite using approved company systems and tools. - **Good-faith effort:** A reasonable, honest attempt to comply with this policy, including timely communication and accurate time reporting. - **Interactive process:** The ADA-required dialogue used to evaluate whether a reasonable accommodation is needed for a disability-related weather or travel limitation. - **Reasonable accommodation:** A workplace adjustment that enables an employee with a disability to perform the essential function of the job, unless doing so would create undue hardship.

The company may modify operating hours, delay opening, close one or more offices, or shift employees to remote work when weather or other emergency conditions create safety, access, or operational concerns. Closure decisions are based on factors such as road conditions, public transit availability, local emergency declarations, utility outages, building access, and guidance from public authorities. Employees are expected to monitor company communications and follow instructions from their manager, HR, or designated emergency contact. The company will apply this policy in a manner that does not interfere with employees' rights under the NLRA to engage in protected concerted activity, and will consider reasonable accommodation requests through the ADA interactive process when weather conditions affect an employee's ability to report to work.

1. **Closure decision and notification** - HR, Facilities, and senior leadership will assess conditions and determine whether the office will open, open late, close early, or close for the day. - Notification will be issued through at least two channels whenever practicable, such as email, text message, phone tree, company intranet, or mass notification system. - Employees should not assume the office is open unless they receive an official notice. 2. **Employee reporting expectations** - Employees who can safely work remotely should be prepared to do so when directed. - Employees who cannot work remotely must follow manager instructions regarding delayed arrival, early departure, or use of available paid or unpaid time off. - If an employee cannot report to work due to unsafe conditions, the employee must notify their manager as soon as practicable. 3. **Essential staff expectations** - Essential staff may be required to report on-site or remain available during a closure. - Managers should identify essential staff in advance and communicate expectations, backup coverage, and escalation contacts. - Essential staff who are directed to report must use good-faith efforts to arrive safely and promptly; if conditions prevent safe travel, they must notify their manager immediately. 4. **Remote work during closures** - When business needs allow, employees may be assigned remote work during a closure. - Remote work expectations include maintaining availability during scheduled work hours, responding to messages within a reasonable time, and recording all hours worked accurately. - Nonexempt employees must obtain approval for overtime in advance, even during closures, unless an emergency makes prior approval impracticable. 5. **Timekeeping and pay treatment** - Nonexempt employees must record all hours worked, including remote work and any time spent responding to urgent work requests. - Exempt employees will generally be paid on a salary basis in accordance with the FLSA, subject to lawful deductions and any applicable exceptions. - If the office is closed and an employee performs no work, pay treatment will depend on exempt/nonexempt status, available paid time off, state law, and any applicable company leave policy. - If an employee works part of the day, pay will be administered consistent with FLSA and applicable state law. - Employees may be required to use available PTO, vacation, or other paid leave during a closure, except where prohibited by law. 6. **Leave and accommodation requests** - Employees who need time off due to a disability-related travel limitation, caregiving issue, or other qualifying condition should notify HR promptly. - HR will evaluate requests under the ADA interactive process, FMLA, applicable state leave laws, and any other applicable policy. - Employees should not be disciplined for requesting protected leave or a reasonable accommodation in good faith.

- **HR:** Maintains this policy, coordinates closure communications, tracks acknowledgements, and reviews pay and leave issues for compliance. - **Managers:** Identify essential staff, communicate work expectations, approve remote work when appropriate, and ensure accurate timekeeping. - **Employees:** Monitor alerts, follow instructions, report availability, work safely, and record time accurately. - **Facilities / Operations:** Assess building conditions, coordinate with vendors and emergency services, and advise leadership on site safety. - **Payroll:** Administers pay in accordance with FLSA and applicable state law. - **Legal / Compliance:** Reviews unusual closure scenarios, jurisdiction-specific wage issues, and accommodation or leave disputes.

Employees who fail to follow closure instructions, ignore safety directives, misreport time, or refuse lawful work assignments without approval may be subject to corrective action, up to and including termination, consistent with company policy and applicable law. Discipline will be based on the circumstances, including whether the employee made a good-faith effort to comply, whether the employee was protected by law, and whether the issue involved a safety concern, accommodation request, or protected concerted activity under the NLRA. Any adverse action must be reviewed by HR before implementation when the situation involves a weather-related absence, leave request, accommodation request, or wage-and-hour concern.

This policy will be reviewed at least annually and updated as needed to reflect changes in business operations, weather-response procedures, and applicable federal, state, and local laws. Revisions must be approved by HR and Legal before publication. Employees will be notified of material changes and may be required to re-acknowledge the policy.