Run: Reasonable Accommodation Religious Policy

This policy establishes the process for requesting, evaluating, approving, modifying, or denying religious accommodation requests in a consistent, respectful, and legally compliant manner. The company will engage in a **good-faith interactive process** and will consider reasonable accommodations for sincerely held religious beliefs, practices, and observances unless doing so would create an undue hardship under **Title VII of the Civil Rights Act of 1964** and applicable EEOC guidance.

This policy applies to all employees, interns, temporary workers, and managers in the United States. It covers requests related to scheduling, prayer time, religious holidays, dress and grooming, dietary practices, religious expression, and other workplace adjustments tied to religious belief or observance. **Jurisdiction-specific carve-outs:** - **California employees:** Requests involving leave, meal/rest break timing, or retaliation concerns must also be reviewed for compliance with California Labor Code requirements and any applicable California Civil Rights Department guidance. - **New York employees:** Managers must avoid retaliation or interference with protected activity and should escalate any complaint involving discipline or termination to HR and Legal. - **Washington employees:** Time-off requests that overlap with paid sick leave or protected leave must be reviewed under applicable Washington paid sick leave rules. This policy does not apply to requests that are not based on religious belief, practice, or observance; those requests should be routed to the appropriate leave, disability, or workplace policy.

The company prohibits discrimination or retaliation against any employee who requests a religious accommodation, participates in the interactive process, or uses an approved accommodation. The company will: 1. Review each request individually. 2. Assess whether the request is based on a sincerely held religious belief, practice, or observance. 3. Identify the employee's essential job functions and the workplace requirement creating the conflict. 4. Explore effective accommodation options, including temporary accommodations where appropriate. 5. Approve accommodations that do not create undue hardship. 6. Provide a written decision and document the basis for approval, modification, or denial. The company may request reasonable supporting information only when needed to evaluate the request, and will limit collection to information necessary for the decision.

For purposes of this policy: - **Policy holder** means the company department or HR function responsible for administering this policy. - **Essential function** means a fundamental job duty of the position. - **Good-faith** means honest, timely, and cooperative participation in the interactive process. - **Documented warning** means a written record of a policy or performance issue that is retained in the employee file. - **PIP** means a performance improvement plan used to address performance concerns separately from accommodation requests.

### 1) Request submission Employees should submit a religious accommodation request to HR using the designated form or by written email. The request should describe: - The religious belief, practice, or observance creating the conflict - The workplace rule, schedule, dress requirement, or duty that conflicts - The accommodation requested - The requested start date and duration, if temporary ### 2) Intake and acknowledgement HR will acknowledge the request promptly, open a confidential case file, and identify the policy holder responsible for review. Managers must forward requests to HR immediately and must not make unilateral decisions. ### 3) Interactive process HR will engage the employee in a good-faith interactive process to clarify the request, understand the conflict, and evaluate alternatives. The company may discuss options such as: - Schedule adjustments - Shift swaps - Temporary reassignment of non-essential tasks - Dress or grooming exceptions - Break-time or prayer-time adjustments - Use of accrued leave where permitted ### 4) Evaluation HR, the manager, and Legal or Compliance as needed will evaluate: - Whether the belief is sincerely held - Whether the requested accommodation is effective - Whether the accommodation affects essential functions, safety, operations, or other employees' rights - Whether an alternative accommodation would be effective with less disruption - Whether the accommodation would create undue hardship ### 5) Decision The company will issue a written decision approving, modifying, or denying the request. If modified, the decision will explain the alternative accommodation offered and the reason the original request could not be granted. ### 6) Implementation and follow-up Approved accommodations will be implemented promptly. HR may set a review date to confirm the accommodation remains effective and to address changes in job duties, schedule, or business needs. ### 7) Changes and re-evaluation Employees must notify HR if the accommodation no longer works or if their religious needs change. The company may re-evaluate accommodations when circumstances materially change.

**Employees** - Submit requests in good faith and provide enough information to evaluate the conflict. - Participate in the interactive process and communicate changes promptly. **Managers and Supervisors** - Route requests to HR immediately. - Maintain confidentiality to the extent possible. - Do not retaliate, discourage requests, or promise outcomes. - Implement approved accommodations and monitor for operational issues. **HR / Policy holder** - Coordinate the interactive process and document each step. - Evaluate requests consistently and consult Legal or Compliance when needed. - Maintain records securely and limit access to authorized personnel. **Legal / Compliance** - Review complex, high-risk, or multi-jurisdiction requests. - Advise on undue hardship, essential functions, and jurisdiction-specific requirements.

Requests and supporting documentation will be handled as confidential personnel information and shared only with individuals who have a business need to know. Misuse of this policy, failure to cooperate in the interactive process, retaliation, or unauthorized disclosure of accommodation information may result in corrective action, up to and including termination of employment. This policy does not prevent the company from addressing performance or conduct issues through ordinary management processes, including documented warnings or a PIP, provided those actions are not based on the employee's protected religious activity or accommodation request.

This policy will be reviewed at least annually and updated as needed to reflect changes in federal, state, or local law, EEOC guidance, operational requirements, or company practice. Any revisions must be approved by HR and Legal or Compliance before publication.