Run: Religious Accommodation Policy

This policy explains how the company receives, reviews, and responds to requests for religious accommodation in the workplace. The company is committed to complying with **Title VII of the Civil Rights Act of 1964** and EEOC guidance by considering reasonable accommodations for sincerely held religious beliefs and practices, including scheduling, attire, grooming, and access to prayer or meditation space.

This policy applies to all employees, interns, temporary workers, and applicants where applicable. It applies to workplace practices, scheduling, dress and grooming standards, break arrangements, and use of company space. **California employees:** requests must also be evaluated consistently with California Fair Employment and Housing Act requirements. **New York employees:** managers must avoid retaliation and preserve records of requests and decisions. This policy does not limit rights protected by the NLRA, FMLA, ADA, or any state or local law that provides greater protection.

For purposes of this policy: - **Religious accommodation** means a change to a workplace rule, practice, or schedule that allows an employee to observe a sincerely held religious belief or practice. - **Interactive process** means a timely, good-faith discussion between the employee and the company to identify possible accommodations. - **Undue hardship** means more than a minimal cost or burden under applicable law. - **Essential function** means a fundamental job duty that cannot be removed without changing the nature of the role. - **Sincerely held religious belief** includes traditional and nontraditional religious beliefs and practices protected by Title VII.

The company will consider reasonable religious accommodations unless the accommodation would create an undue hardship, conflict with an essential function, or otherwise violate applicable law or safety requirements. Requests may include, but are not limited to: 1. Schedule changes for worship, holy days, fasting, or religious observance. 2. Exceptions to dress code requirements for religious attire. 3. Exceptions to grooming standards for religious hair, beard, or head-covering practices. 4. Access to a private or semi-private space for prayer or meditation when reasonably available. 5. Break-time adjustments where operationally feasible. The company will not retaliate against any employee for requesting an accommodation or participating in the review process.

1. **Submit a request.** Employees should submit a request to HR or their designated policy holder as soon as the need is known. Requests may be made verbally or in writing, but written requests are preferred. 2. **Provide information.** The employee may be asked to describe the religious practice involved, the workplace barrier, and the accommodation requested. Medical documentation is not required for a religious accommodation request. 3. **Interactive process review.** HR will review the request in good faith, discuss alternatives with the employee, and evaluate whether the request can be approved as submitted or whether an alternative accommodation is available. 4. **Manager coordination.** Managers must promptly forward requests to HR and must not deny, delay, or alter a request without HR review. 5. **Decision.** HR will communicate the decision in writing when practicable, including any approved accommodation, duration, conditions, or alternative arrangement. 6. **Implementation and follow-up.** Approved accommodations will be implemented promptly and may be revisited if job duties, schedules, or operational needs change. 7. **Recordkeeping.** HR will maintain request records, decision notes, and supporting documentation in a confidential file separate from the personnel file.

- **Employees / policy holders:** Submit requests promptly, participate in the interactive process, and notify HR if the accommodation is no longer needed or is not working. - **Managers:** Escalate requests immediately, maintain confidentiality, and avoid making assumptions about religious beliefs or practices. - **HR / Compliance:** Lead the interactive process, evaluate undue hardship, document decisions, and coordinate implementation. - **Leadership:** Ensure resources are available for reasonable accommodations and support consistent application of this policy.

Failure to follow this policy may result in corrective action, up to and including a documented warning or inclusion in a PIP for managers who fail to escalate or who retaliate against an employee. Exceptions may be approved when required by law or when an alternative accommodation is equally effective. Safety-related restrictions may apply where an accommodation would create a direct conflict with OSHA requirements or other applicable safety rules. Employees who believe a request was improperly denied may escalate the matter to HR, the Compliance Officer, or another designated reviewer.

This policy will be reviewed at least annually and updated as needed to reflect changes in Title VII, EEOC guidance, state law, and company operations. Any material changes should be communicated to affected employees and managers. The policy holder is responsible for maintaining the current version and ensuring acknowledgements are renewed when required.