Run: Internal Transfer and Promotion Policy

This policy establishes a fair, transparent, and consistent process for internal transfers and promotions. It is intended to support employee development, fill open positions efficiently, and ensure compliance with applicable employment laws, including Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act (ADA), the Fair Labor Standards Act (FLSA), and applicable state and local pay transparency requirements.

This policy applies to all employees and all internal job opportunities, including transfers, lateral moves, acting assignments, temporary assignments, and promotions, unless a specific collective bargaining agreement, local law, or business necessity requires a different process. This policy does not limit employees' rights under the National Labor Relations Act (NLRA) to engage in protected concerted activity.

Employees may apply for internal opportunities when they meet the minimum qualifications listed in the posting and satisfy any additional eligibility criteria below: - The employee must be in good standing and not currently subject to a final documented warning or active PIP, unless HR approves an exception based on business need. - The employee must have completed any required minimum time in role, if stated in the posting. - The employee must meet attendance, performance, licensing, certification, and work authorization requirements for the new role. - The employee must be able to perform the essential functions of the position, with or without reasonable accommodation. Managers may not impose additional unpublished eligibility rules. Any exception must be approved by HR and documented.

Open internal positions should be posted in a manner reasonably accessible to eligible employees before a final selection is made, unless the role is filled through a documented business exception. Each posting should include, at minimum: - Job title, department, location, and work schedule - Key duties and essential functions - Minimum qualifications and preferred qualifications - Application deadline and submission method - Whether the role is temporary, acting, or permanent - Pay range or compensation information where required by applicable law - Any location-specific or jurisdiction-specific requirements California employees: pay scale information must be provided in job postings as required by California Labor Code § 432.3. New York employees: salary range disclosure must be provided where required by New York Labor Law § 194-b. Other state or local pay transparency laws must also be followed.

Eligible employees must be allowed to apply through the designated internal process during the posting period. Applications should be reviewed using job-related, objective criteria. Interview practices must be consistent and documented. - HR or the hiring manager should confirm minimum qualifications before interviews are scheduled. - Interview questions must relate to the position and must not seek information about protected characteristics. - Candidates should be evaluated using the same core criteria whenever practicable. - Reasonable accommodation requests must be handled through the interactive process. - Employees may be asked to disclose conflicts of interest, scheduling restrictions, or licensing issues only when job-related and lawful.

Selection decisions must be based on legitimate business needs, qualifications, performance history, interview results, and other job-related factors. The organization will use good-faith consideration and will not make decisions based on race, color, religion, sex, pregnancy, sexual orientation, gender identity, national origin, age, disability, genetic information, veteran status, or any other protected characteristic under applicable law. The final decision-maker must document the basis for selection or non-selection. If two candidates are substantially equal, the organization may consider business continuity, relevant experience, skills, and development needs, provided the criteria are applied consistently.

Compensation for internal transfers and promotions will be determined in accordance with the organization's compensation structure, internal equity, budget, market data, and applicable law. Any pay change must comply with the FLSA and any applicable state wage and hour requirements. - Nonexempt employees must continue to be paid for all hours worked and receive overtime pay when required by law. - Exempt status must be reviewed whenever a promotion or transfer materially changes duties, authority, or salary basis requirements. - Pay increases for promotions are not guaranteed unless stated in a written compensation plan. - Salary changes, bonus eligibility, and incentive eligibility must be documented before the effective date of the move. - Any pay transparency obligations tied to the posting or offer must be satisfied before selection.

Approved transfers and promotions will include a written effective date, reporting relationship, compensation change if any, and any transition expectations. The organization may delay a move to support training, business continuity, or completion of critical work, provided the reason is documented and applied consistently. Employees should not assume a transfer or promotion is final until they receive written confirmation from HR or the authorized hiring leader.

- **Employees:** Review postings, submit complete applications, maintain performance expectations, and notify HR of any accommodation needs. - **Managers:** Post openings as required, use objective criteria, avoid retaliation, and document selection decisions. - **HR:** Maintain the process, review eligibility exceptions, ensure compliance with EEOC, ADA, FLSA, and pay transparency laws, and retain records. - **Compensation Team:** Review pay changes for internal equity, classification, and wage-and-hour compliance.

Retaliation against an employee for applying for an internal opportunity, requesting an accommodation, raising a concern, or engaging in protected concerted activity under the NLRA is prohibited. Violations of this policy may result in corrective action, up to and including termination of employment. Any exception to this policy must be approved by HR and documented. Suspected discrimination, retaliation, or pay inequity concerns should be reported promptly through the organization's complaint process.

This policy will be reviewed at least annually and updated as needed to reflect changes in business practices, EEOC guidance, FLSA requirements, pay transparency laws, and other applicable federal, state, and local laws.