Run: Pay Transparency Policy

This policy establishes the company's standards for pay transparency, including salary range disclosure, job posting requirements, and compensation communication practices. The policy is intended to support lawful, consistent, and good-faith compensation practices while meeting applicable state-specific pay transparency requirements and related obligations under the EEOC and FLSA.

This policy applies to all U.S. employees, applicants, recruiters, hiring managers, and policy holders involved in recruiting, posting jobs, setting compensation, or responding to compensation inquiries. Where state or local law provides greater protection or stricter disclosure requirements, the more protective rule controls. California employees, New York employees, Colorado employees, Washington employees, and employees in any other jurisdiction with pay transparency requirements must follow the applicable jurisdiction-specific rules.

**Salary range**: The good-faith minimum and maximum annual or hourly compensation the company reasonably expects to pay for a position at the time of posting or disclosure. **Compensation**: Base pay and, where required by law or company practice, bonuses, commissions, incentives, or other forms of remuneration. **Job posting**: Any internal or external advertisement, requisition, or notice used to recruit for an open position, promotion, or transfer opportunity. **Good-faith range**: A pay range established using current market data, internal equity, budget, classification, and the essential function of the role. **Policy holder**: The HR, recruiting, or compensation leader responsible for maintaining and enforcing this policy.

The company will disclose salary ranges or pay scales in job postings and other required notices when required by applicable law, and will provide compensation information to applicants or employees upon request when required by law. Compensation decisions must be made in good faith, based on job-related factors such as experience, skills, education, performance, internal equity, market data, and the essential function of the role. The company will not retaliate against any applicant or employee for asking about, discussing, or disclosing wages, salary ranges, or compensation information, consistent with NLRA Section 7 rights and applicable state law. The company will maintain pay practices that are consistent with Title VII of the Civil Rights Act of 1964 and the EEOC's anti-discrimination requirements, and will ensure wage and hour classifications are handled consistently with the FLSA.

1. **Before posting a role**: HR or Recruiting must confirm whether the position is subject to any state or local pay transparency law and determine the required disclosure format. 2. **Set the range in good faith**: The hiring manager and compensation partner must document the salary range before the posting is published. 3. **Include required disclosures**: Job postings must include the salary range or pay scale, and any other compensation disclosures required by applicable law, such as bonus or commission information where mandated. 4. **Use consistent language**: Postings must avoid misleading statements, open-ended pay promises, or language that conflicts with the approved range. 5. **Respond to requests**: If a current employee or applicant requests compensation information, HR must respond according to the applicable jurisdiction's requirements and company response standards. 6. **Document exceptions**: Any deviation from the standard disclosure process must be approved by HR and the policy holder and documented with the legal basis for the exception. 7. **Maintain records**: Recruiting and HR must retain job postings, approved ranges, and disclosure records in accordance with the company's recordkeeping schedule and applicable law.

**California employees**: Job postings must include pay scale information as required by California Labor Code § 432.3, and pay data reporting obligations may apply under California's pay data reporting rules. **New York employees**: Job advertisements, promotions, and transfer opportunities must include compensation or a range of compensation as required by New York Labor Law § 194-b. **Colorado employees**: Postings must include compensation, a general description of benefits, and other required disclosures under Colorado's Equal Pay for Equal Work Act. **Washington employees**: Postings must include wage scale or salary range and a general description of benefits and other compensation, as required by Washington law. **Other states and localities**: The company will monitor and apply any additional pay transparency requirements in jurisdictions where it recruits or employs workers.

**HR / People Operations**: Maintain this policy, confirm jurisdictional requirements, and oversee compliance training. **Recruiting**: Ensure postings include required disclosures and use approved compensation language. **Hiring Managers**: Provide accurate role information, support good-faith range setting, and avoid off-script compensation promises. **Compensation**: Establish and document salary ranges using market, internal equity, and budget data. **Policy holder**: Review exceptions, approve policy updates, and coordinate with legal counsel as needed.

Violations of this policy may result in corrective action, up to and including removal of a posting, retraining, documented warning, PIP, or other disciplinary action, depending on the severity of the issue and applicable law. Retaliation against any employee or applicant for raising a pay transparency concern, participating in an investigation, or exercising protected rights is prohibited and may result in immediate corrective action.

This policy will be reviewed at least annually and whenever pay transparency laws change in a state or locality where the company recruits or employs workers. Updates must be approved by HR, Legal, and the policy holder before publication. The company will communicate material changes to affected employees, recruiters, and hiring managers.