Run: Reduction in Force WARN Compliance Policy

This policy establishes the process for planning, approving, communicating, and documenting reductions in force (RIFs) in a manner that is consistent with applicable law and business needs. The policy is intended to help the organization comply with the federal WARN Act, avoid discriminatory selection practices under Title VII of the Civil Rights Act of 1964 and the ADA, respect protected activity under the NLRA, and ensure wage-and-hour compliance under the FLSA during separation and final pay processing.

This policy applies to all U.S. employees, managers, HR personnel, and decision-makers involved in workforce planning, selection, communications, severance administration, and separation processing. It applies to reductions in force, layoffs, furloughs that may trigger WARN analysis, plant closings, and other workforce actions that may result in employment loss. This policy does not replace any collective bargaining agreement, state mini-WARN law, or other legally required process. Where a state or local law provides greater protection or longer notice, the more protective requirement controls.

Key terms used in this policy are defined in the Definitions section above. Additional terms: - **Employment loss**: As defined by the WARN Act, generally includes termination other than for cause, voluntary departure, or retirement; a layoff exceeding six months; or a reduction in hours of work of more than 50% in each month of any six-month period. - **Affected employee**: An employee whose role is eliminated or whose employment is otherwise impacted by a covered RIF. - **Decision group**: The business unit, site, or function used to evaluate selection criteria and business justification for a RIF. - **Good-faith notice**: Written notice provided in a timely and accurate manner, based on the employer's best available information at the time.

The organization will conduct reductions in force only when supported by legitimate business reasons and after a documented review of legal, operational, financial, and employee-relations impacts. Selection decisions must be based on objective, job-related criteria and must not be made on the basis of race, color, religion, sex, pregnancy, sexual orientation, gender identity, national origin, age, disability, genetic information, veteran status, or any other protected characteristic under applicable law. The organization will not interfere with employees' rights to engage in protected concerted activity under Section 7 of the NLRA. The organization will provide required notices, coordinate final pay and benefits, and consider severance and outplacement support in accordance with approved plans and applicable law.

1. **Initiate business review**: The policy holder, in coordination with Finance, Legal, and HR, must document the business rationale, affected locations, positions, and anticipated timing of the RIF. 2. **Conduct WARN analysis**: HR and Legal must determine whether the federal WARN Act or any state mini-WARN law applies, including whether the action constitutes a plant closing, mass layoff, or other covered employment loss event. 3. **Select employees using objective criteria**: Selection criteria must be documented, job-related, and applied consistently. Criteria may include skills, performance history, business necessity, and role redundancy. Criteria must be reviewed for disparate impact and adverse effect concerns before final approval. 4. **Review protected leaves and accommodations**: HR must review whether impacted employees are on FMLA leave, have requested or received ADA accommodations, or are otherwise protected by law. Any selection decision involving such employees must be reviewed by Legal before final approval. 5. **Prepare notices and communications**: Where required, provide WARN notices to affected employees, state dislocated worker units, and applicable local government officials. Communications must be coordinated to ensure accuracy, consistency, and confidentiality. 6. **Determine severance and release terms**: Any severance offer must be reviewed for compliance with the Older Workers Benefit Protection Act (OWBPA), the ADEA, and applicable state law. Release language must be individualized as required and must not waive rights that cannot legally be waived. 7. **Arrange outplacement support**: HR may offer outplacement services based on business needs, budget, and employee impact. Outplacement may include job search assistance, resume support, interview coaching, and access to career resources. 8. **Process final pay and benefits**: Final wages, accrued paid time off, and benefit continuation notices must be administered in accordance with the FLSA, state final pay laws, COBRA, and any applicable plan documents. 9. **Document the file**: HR must retain the business rationale, selection criteria, WARN analysis, notice copies, severance approvals, and communication records in the RIF file.

**Policy holder**: Owns the policy, approves the RIF framework, and ensures executive alignment. **HR**: Coordinates the process, maintains documentation, prepares notices, administers severance and outplacement, and ensures employee communications are consistent and timely. **Legal**: Reviews WARN applicability, release language, discrimination risk, leave/accommodation issues, and state-specific requirements. **Finance**: Confirms budget impact, severance funding, and cost modeling. **Managers**: Provide role-specific business input, participate in communications as directed, and avoid off-script statements. **Employees**: Are expected to return company property, complete separation steps, and direct policy questions to HR.

Failure to follow this policy may result in corrective action, up to and including removal from decision-making responsibilities, disciplinary action, or other employment action consistent with company policy and applicable law. Any deviation from the standard process must be approved in writing by HR and Legal and documented with the business justification. California employees: evaluate state mini-WARN obligations under the California WARN Act (Cal. Lab. Code §§ 1400-1408) and any applicable local notice requirements. New York employees: review applicable state and local notice obligations and any collective bargaining requirements. Where a collective bargaining agreement applies, the agreement and any bargaining obligations must be reviewed before implementation.

This policy will be reviewed at least annually and whenever there is a material change in federal, state, or local law, or after any significant RIF event. The policy holder, in coordination with HR and Legal, is responsible for updating procedures, notice templates, and jurisdiction-specific carve-outs as needed.