Run: Political Activity in the Workplace Policy

This policy establishes expectations for political activity in the workplace, including political discussions, solicitation, use of company resources, and voting-related time off. It is intended to maintain a respectful, productive work environment while complying with applicable laws, including the National Labor Relations Act (NLRA), state voting leave laws, and wage and hour requirements.

This policy applies to all employees, managers, supervisors, temporary workers, interns, and contractors while on company premises, during working time, at company-sponsored events, and when using company systems or resources. Where a state or local law provides greater rights or stricter requirements, the company will follow the law that is most protective of employee rights.

For purposes of this policy: - **Political activity** includes campaign-related speech, fundraising, endorsements, distribution of political materials, and electioneering. - **Solicitation** means asking others to support, donate to, or participate in a political cause or campaign. - **Working time** means the time an employee is expected to be performing job duties; it does not include bona fide meal periods, rest breaks, or off-duty time. - **Protected concerted activity** means employee activity protected by Section 7 of the NLRA, including certain discussions about wages, hours, or working conditions. - **Voting-related time off** means time off requested or required under applicable law to vote or travel to vote.

1. **Neutrality and respect.** Employees must not disrupt operations, harass coworkers, or create a hostile work environment through political speech or activity. 2. **No political solicitation during working time.** Employees may not solicit coworkers for political donations, signatures, volunteer activity, or campaign support during working time or in work areas where solicitation is otherwise restricted by company policy. 3. **No use of company resources for political activity.** Company email, messaging systems, printers, meeting rooms, logos, and other resources may not be used for political campaigning or fundraising unless the company has given prior written approval. 4. **No retaliation or unlawful interference.** The company will not retaliate against employees for lawful political activity outside work or for rights protected by applicable law. Nothing in this policy is intended to interfere with rights protected by the NLRA or other applicable laws. 5. **Manager conduct.** Managers and supervisors must not pressure employees to support or oppose any candidate, party, or ballot measure, and must not suggest that political views will affect scheduling, assignments, promotions, or employment decisions. 6. **Workplace discussions.** Limited political discussion may occur during non-working time so long as it remains respectful, non-disruptive, and consistent with this policy and other workplace conduct rules.

### A. Requesting voting-related time off 1. Employees should submit a request for voting-related time off as soon as practicable, and whenever possible at least 1 business day in advance. 2. The request should include the date, anticipated time away, and whether the employee needs a schedule adjustment or unpaid leave. 3. Managers must review requests promptly and coordinate coverage without discouraging lawful voting leave. 4. If state law requires paid voting leave, the company will provide the amount of paid time off required by law and will not require employees to use PTO unless permitted by law. ### B. Handling political solicitation and complaints 1. Employees who feel pressured or harassed by political activity should report the concern to HR, a manager, or the compliance contact. 2. HR will review the complaint, document the concern, and determine whether coaching, a documented warning, or other corrective action is appropriate. 3. If the issue may involve protected concerted activity, discrimination, retaliation, or a wage and hour concern, HR will escalate to legal or compliance review before discipline is issued. ### C. Use of company communications 1. Managers may limit political messages in company channels to preserve productivity and prevent misuse of business systems. 2. Any approved political communication must be clearly identified as personal and must not imply company endorsement.

**Employees** must follow this policy, avoid disruptive solicitation, and request voting-related time off in a timely manner. **Managers and supervisors** must enforce this policy consistently, avoid coercion or retaliation, and escalate concerns involving protected rights or potential legal issues. **HR** must review requests for voting-related time off, maintain records of approvals and denials, and ensure compliance with applicable state and local laws. **Compliance / Legal** must review exceptions, investigate complaints involving protected activity, and advise on jurisdiction-specific requirements. **Policy holder** is responsible for maintaining the policy, updating it for legal changes, and ensuring annual review.

Violations of this policy may result in corrective action up to and including a documented warning, removal of access to company systems, reassignment, suspension, or termination, depending on the severity of the conduct and applicable law. Discipline will be applied in a good-faith, consistent manner and will not be imposed for activity protected by the NLRA, FLSA, state voting leave laws, or other applicable law. **Exceptions:** - **California employees:** voting leave, paid time off, and notice requirements will be administered in accordance with California Elections Code provisions governing time off to vote. - **Employees covered by collective bargaining agreements:** this policy will be applied consistent with the applicable agreement and the NLRA. - **State/local law overrides:** where a jurisdiction provides greater employee rights or more specific voting leave requirements, those rules control.

This policy will be reviewed at least annually and updated as needed to reflect changes in federal, state, and local law, including voting leave requirements and labor law developments. The policy holder should document revisions, communicate material changes to employees, and obtain re-acknowledgement when required.