Run: Pronoun and Name Use Policy

This policy establishes the company's expectations for respectful use of employees' chosen names and pronouns in workplace interactions, records, and systems. The policy is intended to support a respectful workplace, reduce miscommunication, and help the company comply with applicable anti-discrimination laws, including **Title VII of the Civil Rights Act of 1964** and related **EEOC** guidance. The company will address name and pronoun requests in a consistent, confidential, and good-faith manner.

This policy applies to all employees, interns, temporary workers, contractors, managers, supervisors, recruiters, HR personnel, and IT administrators when acting on behalf of the company. It applies to workplace interactions, written communications, meeting settings, email signatures, directories, badges, HR records, learning systems, collaboration tools, and other company-controlled systems. **California employees:** This policy must be applied consistently with the **California Fair Employment and Housing Act (FEHA)** and any applicable local ordinances. **New York employees:** This policy must be applied consistently with the **New York State Human Rights Law** and any applicable local ordinances.

For purposes of this policy: - **Chosen name** means the name an employee asks others to use in the workplace. - **Pronouns** means the words an employee asks others to use when referring to them. - **Legal name** means the name required for payroll, tax, benefits, background checks, or other legally required records. - **Deadnaming** means using a person's former name when they have asked to be called by a different name. - **Misgendering** means referring to a person with pronouns or gendered language that are inconsistent with their stated identity. - **Interactive process** means a good-faith, individualized discussion to determine whether a workplace adjustment or system change is needed to support the employee while meeting business and legal requirements.

Employees are expected to use coworkers' chosen names and pronouns in good faith and without unnecessary questioning, delay, or disclosure. The company prohibits intentional or repeated deadnaming or misgendering, including in meetings, emails, chat messages, documents, and verbal communication, when the employee's chosen name or pronouns have been communicated. Managers and supervisors must model respectful use of names and pronouns and must correct mistakes promptly and professionally. Repeated refusal to use a coworker's chosen name or pronouns may result in corrective action, up to and including termination, consistent with applicable law and company policy. Employees are not required to provide medical documentation, legal documentation, or a court order to request use of a chosen name or pronouns, unless a specific legal or system requirement applies to a particular record or process.

1. **Employee request:** Employees may inform HR, their manager, or another designated contact of their chosen name and pronouns verbally or in writing. 2. **Record update review:** HR and People Operations will review which systems can be updated to reflect the chosen name and pronouns and which records must retain the legal name for legal, payroll, tax, benefits, or security reasons. 3. **System changes:** Where feasible, the company will update email display names, directories, badges, org charts, collaboration tools, and internal profiles promptly after the request is received. 4. **Confidential handling:** HR will limit disclosure of legal name or prior name information to personnel with a legitimate business need. 5. **Corrections:** If an employee is misnamed or misgendered, the listener should correct the mistake promptly, apologize briefly, and continue the conversation without unnecessary attention. 6. **Escalation:** Employees who experience repeated misuse, harassment, or retaliation should report the issue to HR, Ethics, Compliance, or their manager. HR will review the concern and, where appropriate, use the company's complaint and investigation process. 7. **Interactive process:** If a requested change affects a system, essential function, security control, or legal record, HR, IT, and the employee will use the interactive process to identify a workable solution.

- **Employees:** Use coworkers' chosen names and pronouns in good faith; report concerns promptly. - **Managers and supervisors:** Model compliant behavior, correct misuse, support updates, and avoid retaliation. - **HR / People Operations:** Receive requests, coordinate record updates, maintain confidentiality, and document exceptions. - **IT administrators:** Implement approved display-name, directory, badge, and system changes where technically feasible. - **Recruiters:** Use the candidate's stated name and pronouns during recruiting and onboarding, subject to legal record requirements. - **Policy holder:** Owns the policy, approves exceptions, and ensures periodic review.

Failure to follow this policy may result in corrective action, up to and including termination, depending on the severity, frequency, intent, and impact of the conduct. The company may make limited exceptions when a legal, payroll, tax, benefits, immigration, security, or technical requirement requires use of a legal name or a specific identifier. Exceptions must be handled narrowly and confidentially. This policy does not restrict employees' rights under the **NLRA Section 7** to engage in protected concerted activity, or any rights under applicable whistleblower, leave, accommodation, or anti-retaliation laws. Nothing in this policy limits the company's obligations under the **ADA** to engage in the interactive process for a reasonable accommodation, or under the **FMLA** to administer qualifying leave requests, or under the **FLSA** to maintain accurate wage-and-hour records.

This policy will be reviewed at least annually and updated as needed to reflect changes in law, system capabilities, or company practices. The policy holder is responsible for approving revisions, coordinating legal review where appropriate, and communicating material changes to affected employees and managers. Jurisdiction-specific updates must be documented explicitly, including any state or local requirements that affect name, pronoun, recordkeeping, privacy, or anti-discrimination obligations.