Run: Lactation and Nursing Mother Policy

This policy establishes the process and standards for supporting employees who are lactating or expressing breast milk at work. The policy is intended to comply with the **Fair Labor Standards Act (FLSA)**, as amended by the **PUMP for Nursing Mothers Act (PUMP Act)**, and to align with **EEOC** guidance regarding time and place to pump at work.

This policy applies to all employees in the United States who are lactating, expressing milk, or requesting lactation accommodations while working onsite, in a hybrid arrangement, or in another work setting controlled by the company. It applies to policy holders, managers, supervisors, HR, and facilities personnel responsible for implementing accommodations. Where state or local law provides greater protection, the more protective requirement will apply.

For purposes of this policy: - **Reasonable break time** means the time needed for an employee to express milk, including additional time to travel to and from the lactation space, set up equipment, and clean up as needed. - **Private space** means a space that is shielded from view, free from intrusion, and not a bathroom. - **Expressing milk** means removing breast milk from the body by hand or with a pump or other device. - **Undue hardship** has the meaning provided under applicable federal law and is evaluated narrowly; the company will use a good-faith, interactive process before concluding that an accommodation cannot be provided.

The company will provide reasonable break time and a private, non-bathroom space for employees to express breast milk for their nursing child for up to one year after the child's birth, and longer where required by applicable law. The company will not retaliate against any employee for requesting or using lactation accommodations, and no employee will be required to choose between expressing milk and taking otherwise available break time when a reasonable accommodation can be provided. The company will also make a good-faith effort to provide access to a secure location for temporary milk storage and to support practical needs associated with pumping during the workday.

1. **Requesting accommodation**: Employees should notify HR, their manager, or another designated contact as soon as they need lactation accommodations. Advance notice is encouraged when possible, but the company will respond promptly to unplanned needs. 2. **Interactive process**: HR will engage in an interactive process with the employee to identify the preferred schedule, location, and any equipment or access needs. 3. **Break scheduling**: Managers must allow reasonable break time as needed. When operationally feasible, lactation breaks may be coordinated with existing rest or meal periods, but the employee's need to express milk takes priority over convenience-based scheduling. 4. **Space assignment**: Facilities or HR will identify a private lactation space that is not a bathroom and that is shielded from view and free from intrusion. The space should include a chair, flat surface, access to an electrical outlet when reasonably available, and a nearby sink or handwashing access when feasible. 5. **Milk storage**: Employees may store expressed milk in a personal cooler, designated refrigerator, or other approved secure location, subject to reasonable sanitation and labeling requirements. The company will not require employees to store milk in a bathroom or in an unsecured area. 6. **Cleaning and hygiene**: Employees are responsible for cleaning personal pumping equipment and disposing of waste. The company will maintain the designated space in a sanitary condition and will address maintenance issues promptly. 7. **Escalation**: If an employee believes the accommodation is not being provided, the employee should contact HR immediately. HR will investigate and resolve concerns in good faith.

**Employees** must communicate their needs, follow reasonable sanitation and storage rules, and report access issues promptly. **Managers and supervisors** must support approved break time, avoid discouraging requests, and coordinate staffing without interfering with the employee's rights. **HR** must administer the interactive process, document accommodation requests, coordinate with facilities, and maintain confidentiality to the extent practicable. **Facilities / Operations** must identify, maintain, and secure the lactation space and support access to utilities or storage as applicable.

The company prohibits retaliation, interference, or discrimination related to lactation accommodation requests or use of pumping breaks. Managers or employees who violate this policy may be subject to documented warning, coaching, PIP, or other corrective action up to and including termination, depending on the severity of the violation. Any denial of accommodation must be reviewed by HR and, where applicable, legal counsel before final determination. The company will consider state-specific overlays, including California and New York lactation accommodation rules, and will apply the most protective standard where required.

This policy will be reviewed at least annually and updated as needed to reflect changes in federal, state, or local law, including updates to the FLSA, PUMP Act, EEOC guidance, and any applicable state lactation accommodation requirements.