Run: Pay Equity Compensation Policy

This policy establishes a consistent framework for setting, reviewing, and adjusting compensation to support pay equity, internal fairness, market competitiveness, and legal compliance. The policy is intended to align compensation practices with job-related factors and to reduce the risk of unlawful pay discrimination under **Title VII of the Civil Rights Act of 1964**, the **Equal Pay Act of 1963**, and related EEOC guidance.

This policy applies to all employees, including full-time, part-time, exempt, non-exempt, temporary, and intern workers where applicable. It applies to base pay, merit increases, promotions, adjustments, starting pay, bonuses when used in compensation decisions, and any other recurring cash compensation. **Applicable jurisdictions:** United States. **California employees:** Pay transparency and recordkeeping requirements may also apply under **California Labor Code § 432.3** and **SB 1162**. **New York employees:** Pay transparency obligations may apply under **New York Labor Law § 194-b**. Where state or local law provides greater employee rights or stricter disclosure requirements, the stricter rule controls.

For purposes of this policy: - **Compensation band** means the approved pay range for a role or level. - **Compa-ratio** means an employee's pay compared to the midpoint of the applicable compensation band. - **Pay equity review** means a documented analysis of compensation decisions to identify unexplained disparities. - **Essential function** means the fundamental duties of a role, as used in job evaluation and classification decisions. - **Reasonable accommodation** means a workplace adjustment considered through the interactive process when required by the **ADA**.

The organization will set compensation based on job-related, non-discriminatory factors such as role scope, required skills, experience, performance, location, market data, internal equity, and business needs. Compensation decisions must be made in good faith, documented, and reviewed for consistency. The organization prohibits compensation decisions based on protected characteristics under **Title VII**, including race, color, religion, sex, pregnancy, sexual orientation, gender identity, national origin, and other protected classes recognized by law. The organization also prohibits retaliation against any employee who raises a pay equity concern, participates in a pay review, or requests information protected by law. Compensation practices must also be consistent with the **FLSA** classification and overtime rules. Pay decisions may not be used to circumvent minimum wage, overtime, or recordkeeping obligations.

1. HR and Compensation will maintain written compensation bands for each job family and level. 2. Each band should include a minimum, midpoint, and maximum, supported by market data and internal job evaluation. 3. Bands must be reviewed at least annually and updated when market conditions, organizational structure, or job content materially change. 4. New or revised roles must be evaluated before posting, hiring, or promotion decisions are made. 5. Any exception to a band must be approved in writing by Compensation and HR leadership and must include a documented business rationale. 6. Managers may not promise pay outside an approved band without prior written approval. 7. California employees: job postings and candidate communications must include pay scale information where required by law.

1. Pay progression within a band may be based on performance, skill development, expanded scope, retention risk, market adjustment, or other documented job-related factors. 2. Promotions should normally move employees to the new role's compensation band, with the amount determined by internal equity and the employee's current position in range. 3. Merit increases must be based on documented performance criteria and budget approval. 4. Off-cycle adjustments require written justification and approval from HR and the applicable business leader. 5. Any pay change must be documented in the employee record, including the effective date, reason code, approver, and supporting notes. 6. If an employee requests a pay review, the manager must route the request to HR for good-faith review rather than making an informal commitment.

1. HR or Compensation will conduct periodic pay analysis at least annually and additionally when triggered by organizational changes, acquisition activity, or credible pay equity concerns. 2. The analysis should compare employees performing substantially similar work and evaluate pay differences using lawful, job-related factors. 3. Reviews should consider base pay, starting pay, progression, promotion timing, location differentials, and other relevant compensation elements. 4. Any unexplained disparity identified in the analysis must be escalated to HR leadership and Legal for review. 5. The organization will retain analysis inputs, methodology, findings, and remediation decisions in accordance with record retention requirements. 6. Pay analysis results must be handled as confidential business information and shared only on a need-to-know basis.

1. When an unexplained pay disparity is identified, HR will determine whether a corrective action is required. 2. Corrective actions may include salary adjustments, band realignment, promotion review, or other lawful remediation. 3. Corrective actions should be implemented as soon as practicable after approval. 4. The organization will document the issue, analysis, decision-maker, remedy, and effective date. 5. If a pay concern is raised through a complaint, investigation, or accommodation process, the matter must be reviewed promptly and without retaliation. 6. Employees may not be disciplined for raising a good-faith compensation concern.

1. Managers must communicate compensation decisions using approved talking points and documented rationale. 2. Employees may request general information about compensation bands, progression criteria, and the factors used in pay decisions, subject to confidentiality and applicable law. 3. Job postings and candidate communications must include pay ranges where required by applicable pay transparency laws. 4. The organization will not prohibit employees from discussing wages or compensation terms where protected by the **NLRA Section 7**. 5. Compensation information must be shared in a way that is accurate, consistent, and not misleading. 6. Any disclosure of employee-specific pay data must comply with privacy, confidentiality, and data protection obligations.

**HR / Compensation**: Maintain compensation bands, conduct pay analysis, document exceptions, and coordinate corrective actions. **Managers**: Apply approved compensation criteria consistently, submit pay recommendations with supporting documentation, and escalate concerns to HR. **Legal / Compliance**: Review high-risk pay disparities, legal exceptions, and jurisdiction-specific transparency requirements. **Employees**: Provide accurate information during review processes and raise concerns through established reporting channels. **Policy holder**: The HR leader or designated compensation owner is responsible for maintaining this policy and ensuring annual review.

Failure to follow this policy may result in corrective action, up to and including revocation of approval authority, retraining, documented warning, PIP, or other discipline consistent with company policy and applicable law. Any suspected pay discrimination, retaliation, wage-hour violation, or unauthorized disclosure of compensation data must be escalated immediately to HR and Legal. Where an employee requests leave or accommodation that affects pay, the request must be handled through the applicable **FMLA** or **ADA interactive process** procedures. Nothing in this policy limits rights protected by the **NLRA**, **FLSA**, **FMLA**, **ADA**, or applicable state law.

This policy will be reviewed at least annually and updated as needed to reflect changes in law, market practice, organizational structure, or compensation strategy. Revisions must be approved by HR leadership and, where appropriate, Legal and executive leadership. The policy holder is responsible for maintaining the current version and distribution list.