Run: Marijuana and Cannabis Workplace Policy

This policy establishes the company's expectations for marijuana and cannabis use in the workplace, including possession, use, impairment, testing, reporting, and accommodation. The policy is intended to support workplace safety, productivity, compliance with applicable law, and consistent enforcement. This policy is not intended to interfere with rights protected by the National Labor Relations Act (NLRA), including protected concerted activity, or to limit any rights under applicable state law.

This policy applies to all employees, interns, temporary workers, contractors, and visitors while on company premises, in company vehicles, at company-sponsored events, and while performing work for the company. This policy applies during working time and while an individual is representing the company, whether on-site, remote, or traveling for business. California employees: any drug-testing or off-duty conduct rules must be applied consistently with California law, including privacy and off-duty conduct protections where applicable. Other state-specific protections, including local cannabis employment laws, will be applied as required.

For purposes of this policy: - **Cannabis / Marijuana** means cannabis products, THC, and related derivatives, whether inhaled, ingested, applied, or otherwise consumed. - **Impairment** means observable or documented signs that an employee may not be fit for duty. - **Safety-sensitive role** means a position where impairment could create a heightened risk of injury, incident, or operational failure. - **Reasonable accommodation** and **interactive process** have the meanings described in the glossary and are handled under the ADA and applicable state law. - **Good-faith** means an honest, timely, and documented effort to evaluate concerns, request information, and determine next steps.

1. **Prohibited conduct.** Employees may not possess, use, purchase, sell, distribute, manufacture, or be impaired by marijuana or cannabis while on company premises, in company vehicles, during working time, or while performing company business. 2. **No impairment at work.** Employees must report to work fit for duty and remain free from impairment that could affect safety, performance, or judgment. 3. **Off-duty use.** Off-duty cannabis use may still result in discipline if it causes impairment at work, violates a safety-sensitive rule, conflicts with a lawful testing requirement, or otherwise violates applicable law or company policy. 4. **Prescription and medical use.** The company will evaluate requests involving medical cannabis or other cannabis-related needs through the interactive process where required by law. However, the company is not required to permit use or impairment at work, and may deny accommodation where cannabis use would prevent performance of an essential function or create an undue hardship or direct threat. 5. **Federal law and safety-sensitive work.** Because marijuana remains a controlled substance under federal law, the company may impose stricter restrictions in safety-sensitive roles, where required by federal contract, federal funding, transportation rules, or other applicable law. 6. **NLRA and protected activity.** Nothing in this policy prohibits employees from discussing wages, hours, working conditions, or other protected concerted activity.

1. **Reporting impairment concerns.** Supervisors and managers must promptly report suspected impairment to HR or designated management. Reports should be based on specific, observable facts such as odor, unsteady movement, confusion, slurred speech, unsafe behavior, or inability to complete tasks. 2. **Fit-for-duty assessment.** When impairment is suspected, the company may remove the employee from duty pending assessment, document observations, and determine whether testing, leave, or other action is appropriate under applicable law. 3. **Testing.** The company may require drug testing where permitted by law, including pre-employment, reasonable suspicion, post-incident, return-to-duty, random, or follow-up testing for safety-sensitive roles. Testing will be administered and interpreted in accordance with applicable federal, state, and local law. 4. **Accommodation requests.** Employees seeking accommodation related to a disability or medical condition must notify HR as soon as practicable. The company will engage in the interactive process, request supporting information when lawful and necessary, and evaluate whether a reasonable accommodation exists. 5. **Confidentiality.** Information about testing, medical documentation, and accommodation requests will be maintained as confidential to the extent required by law and shared only with those who need to know. 6. **Return to work.** An employee removed from duty may be required to provide a fitness-for-duty release, complete testing, or meet other lawful conditions before returning to work.

**Employees** must comply with this policy, report to work unimpaired, cooperate with lawful testing, and promptly request accommodation when needed. **Managers and supervisors** must watch for observable signs of impairment, document concerns in good faith, escalate issues promptly, and avoid making medical judgments. **HR** must coordinate testing, accommodation requests, documentation, discipline, and state-law review. **Policy holder** must ensure the policy is communicated, enforced consistently, and reviewed for state-specific updates and legal changes. **Legal / Compliance** must review carve-outs for state cannabis laws, privacy rules, and any federal contractor or safety-sensitive requirements.

Violations of this policy may result in corrective action, up to and including removal from duty, a documented warning, a performance improvement plan (PIP), suspension, or termination, depending on the facts, severity, prior history, and applicable law. The company will apply discipline in a consistent, non-discriminatory manner and will not retaliate against employees for requesting accommodation, reporting concerns, or engaging in protected activity. FLSA note: any non-exempt employee who performs work time during an investigation, testing process, or disciplinary meeting must be paid for all compensable time in accordance with the Fair Labor Standards Act and applicable state wage-and-hour law.

This policy will be reviewed at least annually and updated as needed to reflect changes in federal, state, and local law, testing practices, and operational needs. Jurisdiction-specific carve-outs must be documented before implementation. California employees, New York whistleblower protections, Illinois One Day Rest in Seven Act considerations, and Washington paid sick leave coordination should be reviewed where applicable. Any revisions should be approved by HR, Legal, and the policy holder before publication.