Run: Mental Health and EAP Policy

The Company is committed to supporting employee mental health, psychological safety, and access to confidential resources. This policy explains the mental health benefits, EAP services, crisis resources, confidentiality protections, and procedures for requesting support, accommodations, or leave related to mental health needs. This policy is intended to support compliance with applicable law, including the ADA, Title VII, FMLA, FLSA, NLRA, and applicable state privacy, leave, and paid sick leave laws.

This policy applies to all employees, including full-time, part-time, temporary, and probationary employees, unless a specific benefit or jurisdictional rule states otherwise. **Applicable jurisdictions:** United States. Where state or local law provides greater protection or additional benefits, the Company will follow the law that is most protective of the employee. **California employees:** Requests involving medical information, leave, or accommodations must be handled in accordance with applicable California privacy, leave, and disability accommodation requirements. **New York employees:** Any whistleblower-related concerns raised in connection with workplace stress, retaliation, or safety concerns must be handled consistent with applicable New York law, including NY Labor Law Section 740 where applicable. **Washington employees:** Paid sick leave and related mental health leave rights will be administered in accordance with Washington paid sick leave requirements where applicable.

The Company provides access to mental health support through its benefits program and EAP, and it prohibits retaliation against employees who seek help, request accommodations, use protected leave, or raise concerns in good faith. Employees may use available support resources without fear of discipline for seeking assistance. Managers must respond respectfully, maintain confidentiality, and refer employees to HR or the designated support contact rather than attempting to diagnose, counsel, or investigate medical details. The Company will engage in the ADA interactive process when an employee requests a reasonable accommodation for a mental health condition that affects a disability-related work limitation. The Company will also evaluate leave requests under the FMLA or applicable state leave laws when qualifying conditions are met. Nothing in this policy limits employees' rights under the NLRA to engage in protected concerted activity regarding workplace conditions, including workload, staffing, scheduling, or stress-related concerns.

The Company may offer the following resources, subject to plan terms and eligibility requirements: 1. Confidential EAP counseling sessions and referral services. 2. Health plan behavioral health coverage, if enrolled and available under the applicable plan. 3. Telehealth or virtual mental health services, where offered. 4. Reasonable accommodation review through HR. 5. Leave options under the FMLA, state leave laws, or company leave programs. 6. Paid sick leave or paid time off that may be used for qualifying mental health needs, subject to policy and law. 7. Crisis support information, including the 988 Suicide & Crisis Lifeline and local emergency services. The Company may change vendors, plan features, or eligibility rules at any time, subject to applicable law and plan documents.

Employees may access the EAP by contacting the provider directly using the current phone number, website, or mobile app listed in the benefits portal or employee handbook. To request workplace support, an employee should contact HR, their manager, or the designated benefits contact. Employees are encouraged, but not required, to share only the minimum information needed to evaluate the request. If an employee requests a reasonable accommodation, HR will begin the interactive process, which may include: - A discussion of the work limitation and the essential function affected. - Review of supporting documentation when permitted by law. - Identification of possible accommodations. - Assessment of effectiveness and undue hardship. - Implementation and follow-up. If an employee requests leave, HR will provide the applicable leave request process and required notices. Employees must follow normal call-in and documentation procedures unless prevented by the condition or by law.

The Company will handle mental health-related information on a need-to-know basis and will limit access to HR, benefits, leave administration, or management personnel only as necessary to implement a workplace accommodation, evaluate leave, or maintain operations. Where required by law, medical information will be maintained separately from general personnel files. Managers should not request diagnosis details unless HR confirms that such information is legally necessary for an accommodation, leave, or safety review. EAP providers are expected to maintain confidentiality consistent with their professional and contractual obligations. The Company will not seek EAP counseling notes or session content except where required by law or necessary to address an imminent safety concern. The Company may disclose information only when authorized by the employee, required by law, necessary to prevent a serious and imminent threat, or otherwise permitted under applicable privacy rules, including HIPAA where applicable and state privacy laws such as the CCPA/CPRA for covered personal information.

If an employee is in immediate danger or may harm themselves or others, call 911 or local emergency services immediately. Employees may also use the 988 Suicide & Crisis Lifeline in the United States for urgent mental health support. Managers who become aware of a potential crisis should: 1. Stay calm and encourage the employee to seek immediate help. 2. Contact HR or the designated emergency contact process. 3. Escalate to emergency services if there is an imminent risk. 4. Document only objective facts and actions taken, not speculation or diagnosis. The Company may remove an employee from the workplace temporarily if there is a good-faith belief that an immediate safety risk exists, consistent with applicable law and the OSHA general duty clause.

**Employees** must use support resources responsibly, follow leave and call-in procedures, and provide information needed to evaluate accommodation or leave requests. **Managers** must respond supportively, avoid discriminatory remarks or assumptions, preserve confidentiality, and refer requests to HR without delay. **HR / Benefits** must administer EAP access, coordinate accommodations and leave, maintain records appropriately, and ensure consistent application of this policy. **Compliance / Legal** must review jurisdiction-specific requirements, including ADA, FMLA, FLSA, NLRA, EEOC guidance, and state privacy or leave overlays. **Policy holder** must approve updates, ensure vendor and notice alignment, and confirm the policy is reviewed at least annually.

Violations of this policy, including unauthorized disclosure of confidential information, retaliation, harassment, interference with accommodation rights, or misuse of crisis procedures, may result in corrective action up to and including termination of employment. Any discipline will be based on a documented warning, investigation findings, and a good-faith assessment of the facts, consistent with applicable law and any collective bargaining agreement. This policy does not restrict employees from discussing wages, hours, schedules, staffing, or working conditions with coworkers or third parties as protected by the NLRA.

This policy will be reviewed annually and updated as needed to reflect changes in benefits, vendor arrangements, and legal requirements. Jurisdiction-specific carve-outs should be added or revised when state or local laws provide greater rights, including but not limited to California, New York, Illinois, and Washington requirements. The policy holder is responsible for approving revisions and ensuring employees receive updated notice when material changes occur.