Run: Public Speaking and Press Inquiry Policy

This policy establishes the approval, preparation, review, and follow-up process for employee public speaking engagements and responses to press inquiries. It is intended to protect company interests, ensure accurate and consistent messaging, and reduce legal and reputational risk while preserving employee rights under applicable law, including NLRA Section 7 protected concerted activity.

This policy applies to all employees, contractors, managers, executives, and designated spokespersons when they: - Speak at conferences, panels, webinars, podcasts, community events, or other public forums. - Respond to journalists, editors, bloggers, broadcasters, or other media representatives. - Discuss company business, operations, products, customers, finances, personnel matters, or workplace issues in a public setting. - Use company name, title, branding, slides, data, or internal information in a public presentation. This policy does not restrict legally protected activity, including employees’ rights under NLRA Section 7 to engage in concerted activity or to discuss wages, hours, or working conditions where protected by law.

**Authorized spokesperson**: An employee formally approved to speak on behalf of the company to the media or in public forums. **Press inquiry**: Any request for comment, interview, quote, background information, or statement from a media representative. **Public speaking engagement**: Any external presentation, panel, interview, podcast, webinar, keynote, or similar event where company-related topics may be discussed. **Talking points**: Pre-approved themes, facts, and messaging guidance prepared for a specific engagement or inquiry. **Sensitive topic**: Any subject involving legal claims, litigation, employee relations, discrimination, harassment, safety incidents, financial results, customer data, confidential information, or other matters requiring escalation. **Good-faith review**: A timely, honest, and documented review of proposed remarks for accuracy, compliance, and alignment with company messaging.

1. Only authorized employees may represent the company in public speaking engagements or respond to press inquiries on behalf of the company. 2. Employees must obtain prior approval before accepting any invitation to speak or before providing any comment that could reasonably be understood as a company statement. 3. Employees may not disclose confidential, proprietary, customer, employee, or attorney-client privileged information in any public forum. 4. Employees must not make discriminatory, harassing, retaliatory, or otherwise unlawful statements, and must follow EEOC/Title VII requirements when discussing workplace topics. 5. If a public speaking engagement or press inquiry may affect work time, travel time, or compensation, managers must coordinate with HR and Payroll to ensure FLSA-compliant timekeeping and classification practices. 6. Employees must not imply that personal opinions are official company positions unless expressly authorized to do so. 7. The company will not prohibit employees from engaging in protected concerted activity or other rights protected by applicable labor law.

### A. Request and Authorization 1. The employee must submit a speaking or media request to their manager and the Communications or Public Relations team as soon as the opportunity is identified. 2. The request must include the event name, date, audience, organizer, topic, expected remarks, and whether the employee will be identified by company title or affiliation. 3. Communications, HR, and Legal will determine whether the employee may proceed as an authorized spokesperson, whether additional review is needed, or whether the request must be declined. ### B. Preparation and Talking Point Review 1. Approved engagements must be supported by draft remarks, slides, Q&A notes, or talking points when appropriate. 2. Communications or Legal may review materials for accuracy, confidentiality, privilege, brand alignment, and legal risk. 3. The employee must use only approved talking points for company-related statements unless given express permission to deviate. 4. If the topic involves personnel matters, discrimination, harassment, accommodations, investigations, or complaints, HR and Legal must review the content before the engagement. ### C. Press Inquiries 1. Employees who receive a press inquiry must not provide off-the-cuff comment on behalf of the company unless they are an authorized spokesperson. 2. The employee should politely refer the inquiry to the designated contact in Communications or Public Relations. 3. If immediate response is necessary, the employee may use the approved holding statement provided by Communications. ### D. During the Engagement 1. The employee must stay within approved scope and avoid speculation, personal attacks, or unsupported statements. 2. If a question falls outside approved talking points, the employee should defer, note the question, and escalate it after the event. 3. If the employee becomes aware of a legal, safety, or reputational issue during the engagement, they must report it promptly after the event. ### E. Follow-Up 1. Within a reasonable time after the engagement, the employee must provide Communications or their manager with any requested follow-up notes, media coverage, audience questions, or commitments made. 2. Any promised follow-up must be tracked and completed in good faith. 3. If inaccurate or unauthorized statements were made, the employee must notify Communications, HR, or Legal immediately so corrective action can be evaluated.

- **Employee / Speaker**: Submit requests, use approved materials, avoid unauthorized statements, and complete follow-up items. - **Manager**: Review business relevance, confirm time away from work, and route requests for approval. - **Communications / Public Relations**: Coordinate media responses, prepare talking points, approve messaging, and maintain spokesperson lists. - **HR**: Review employment-related topics, ensure consistency with workplace policies, and advise on protected activity concerns. - **Legal**: Review high-risk topics, litigation-related matters, confidentiality issues, and potential regulatory exposure. - **Executive Leadership**: Approve statements or appearances involving strategic, financial, or enterprise-level matters.

Failure to follow this policy may result in removal from speaking or media duties, retraining, documented warning, PIP, or other corrective action up to and including termination, consistent with applicable law and company policy. The company will not discipline employees for engaging in protected activity under the NLRA or for raising workplace concerns in a manner protected by law. Any discipline must be applied in a non-discriminatory manner consistent with Title VII, ADA, FMLA, and other applicable requirements. Where speaking duties affect hours worked, travel time, or off-the-clock work, managers must coordinate with HR and Payroll to ensure FLSA-compliant recording and payment of time.

Exceptions must be approved in writing by Communications, HR, and Legal, or by Executive Leadership when required. Emergency statements, crisis communications, or legally mandated disclosures may follow a shortened approval process, but any deviation must be documented after the fact.

This policy will be reviewed at least annually and updated as needed to reflect changes in business operations, media practices, and applicable law, including EEOC guidance, NLRA requirements, and FLSA obligations. Jurisdiction-specific updates will be added where required. **California employees:** any policy implementation that affects protected leave, retaliation protections, or workplace reporting should be reviewed for California-specific requirements before enforcement. **New York employees:** whistleblower-related communications must be reviewed for compliance with applicable New York Labor Law protections, including NY Labor Law Section 740 where relevant.