New York Pay Transparency Addendum

This addendum establishes the Company’s requirements for pay transparency in New York in accordance with New York Labor Law §194-b. For covered positions, the Company will include a salary or pay range in every job advertisement, promotion opportunity, and transfer opportunity.

This policy is intended to support lawful, consistent, and good-faith compensation communication and to reduce the risk of noncompliant postings.

This addendum applies to:

• All New York-based job advertisements, whether internal or external.
• Promotion opportunities and transfer opportunities for positions that can be performed, in whole or in part, in New York.
• HR, recruiting, compensation, and hiring manager personnel who create, approve, or publish openings.

Coverage note: This addendum is intended for employers covered by NY Labor Law §194-b, including employers with 4 or more employees. If a posting is managed by a third party, the Company remains responsible for ensuring the required pay disclosure is included.

Salary or pay range: The minimum and maximum annual salary or hourly wage the Company in good faith believes at the time of posting it is willing to pay for the position.

Job advertisement: Any written description of an available position, including postings on job boards, career sites, internal portals, email announcements, and printed notices.

Promotion opportunity: An opportunity to advance to a higher-level role or title.

Transfer opportunity: An opportunity to move to a different role, department, or location that is not a promotion.

Good-faith range: A range based on current compensation planning, budget, market data, internal equity, and the actual pay the Company reasonably expects to offer.

For every covered New York job advertisement, promotion opportunity, and transfer opportunity, the Company will disclose a salary or pay range in the posting or notice.

The disclosed range must be:

1. Based on a good-faith assessment at the time of posting.
2. Narrow enough to be meaningful to applicants and employees.
3. Approved before publication by HR or Compensation, as applicable.
4. Updated when a posting is materially revised.

The Company will not publish a covered opportunity without the required pay disclosure.

1. Draft the range: The hiring manager or recruiter proposes a salary or pay range using approved compensation data, budget authority, and internal equity review.
2. Review and approval: HR or Compensation confirms the range is in good faith and appropriate for the role before the posting is released.
3. Include in the posting: The approved salary or pay range must appear in the job advertisement, promotion notice, or transfer notice.
4. Use consistent language: If the role is hourly, list an hourly range; if salaried, list an annual salary range.
5. Revise carefully: If the role changes materially, the range must be re-reviewed and re-approved before reposting.
6. Document the basis: Retain the rationale used to set the range, including market data, budget approval, and final approval records.
7. Third-party postings: Recruiters, agencies, and vendors must follow this policy and may not publish a covered posting without the required range.

New York employees: If a posting is visible to New York applicants or employees, the pay disclosure requirement applies when the opportunity is covered by §194-b.

HR / People Operations

• Maintain the standard posting template and approval workflow.
• Train recruiters and hiring managers on pay transparency requirements.
• Escalate suspected noncompliant postings for correction.

Compensation

• Provide good-faith pay ranges and supporting market or internal equity data.
• Review exceptions and material changes to posted ranges.

Hiring Managers / Recruiters

• Submit accurate role details and proposed pay ranges.
• Ensure no posting is published without approval.
• Notify HR promptly if the role scope changes.

Policy holder

• The Company is the policy holder and is responsible for compliance by employees, managers, and vendors acting on its behalf.

If a noncompliant posting is identified, HR must remove or correct it as soon as practicable and document the remediation.

Employees who fail to follow this addendum may be subject to corrective action, up to and including a documented warning, removal of posting privileges, retraining, a PIP where performance issues are ongoing, or other discipline consistent with Company policy and applicable law.

The Company prohibits retaliation against any employee who raises a good-faith concern about pay transparency compliance.

Exceptions are limited and must be approved in writing by HR and Legal before publication.

• California employees: This addendum does not replace any California pay scale obligations that may apply to California-based roles.
• Multi-state roles: If a role is open to New York applicants or employees, the New York requirements must be evaluated before posting.
• Confidential compensation discussions: Individual compensation discussions may remain confidential, but that does not remove the obligation to disclose a salary or pay range in covered postings.

This addendum will be reviewed at least annually and whenever New York pay transparency requirements change.

The Company will update this addendum, posting templates, and approval workflows as needed to maintain compliance with NY Labor Law §194-b and related guidance from the New York State Department of Labor.