Run: Return to Work Policy

This policy establishes a consistent, compliant process for returning employees to work after illness, injury, disability-related absence, workers' compensation leave, or other approved leave. The policy is intended to: - Support safe and timely reintegration into the workplace. - Ensure decisions are based on job-related, good-faith assessments. - Coordinate medical clearance, work restrictions, light duty, and accommodations. - Maintain compliance with the ADA, FMLA, FLSA, Title VII, NLRA, and applicable state and local laws.

This policy applies to all employees, including full-time, part-time, temporary, and seasonal employees, unless a collective bargaining agreement, state law, or other legally required process provides different rights or procedures. It applies to return-to-work situations following: - Non-work-related illness or injury. - Work-related injury or occupational illness. - Pregnancy-related leave or medical restrictions. - FMLA leave or other protected leave. - Any other absence requiring review of work restrictions or medical clearance. **Jurisdictional carve-outs:** - California employees: return-to-work and accommodation decisions must be evaluated consistent with the California Fair Employment and Housing Act (FEHA) and any applicable workers' compensation rules. - Washington employees: paid sick leave and protected leave rights must be honored under Washington law. - Illinois employees: scheduling and rest-period obligations, including the One Day Rest in Seven Act where applicable, must be considered when assigning modified schedules. - Employees covered by a collective bargaining agreement: the agreement may impose additional return-to-work, seniority, or light-duty requirements.

For purposes of this policy, the following terms apply: - **Full duty**: The employee can perform all essential functions of the role without restrictions. - **Restricted duty**: The employee may work, but one or more essential or non-essential tasks must be limited. - **Temporary accommodation**: A short-term adjustment approved through the interactive process. - **Undue hardship**: Significant difficulty or expense under the ADA standard. - **Fitness-for-duty release**: A provider statement confirming whether the employee may return with no restrictions, with restrictions, or not yet able to return.

Employees may return to work only when they are able to safely perform the essential functions of their position, with or without a reasonable accommodation, and when any required medical clearance has been received. The Company will engage in a good-faith interactive process when an employee requests an accommodation or presents a medical restriction that may affect job performance. The Company will not discriminate on the basis of disability, sex, pregnancy, race, color, religion, national origin, age, or any other protected characteristic under applicable law. Return-to-work decisions will be individualized, documented, and based on legitimate business and safety needs. The Company will not retaliate against employees for using protected leave, requesting accommodation, reporting workplace injury, or engaging in protected concerted activity under the NLRA.

1. **Employee notice** - The employee must notify HR or the designated leave administrator as soon as practicable that they are ready to return or that restrictions remain in place. - The employee must provide any required release or certification before resuming work when permitted by law. 2. **Medical documentation review** - HR will review the provider's documentation to determine whether the employee may return full duty, return with restrictions, or remain off work. - Documentation requests must be job-related and consistent with business necessity and applicable law. 3. **Interactive process and accommodation review** - If restrictions affect essential functions, HR will begin the interactive process to evaluate reasonable accommodations. - Possible accommodations may include modified equipment, schedule changes, reassignment of marginal tasks, remote work where feasible, or temporary leave extension. 4. **Light duty assignment** - Light duty may be offered when available and operationally feasible. - Light duty is temporary, may be limited in duration, and does not guarantee a permanent position or permanent reduction of essential functions. - Light duty assignments must not be used to replace an ADA accommodation analysis. 5. **Return-to-work approval** - HR, in consultation with the manager and, where appropriate, Safety or Workers' Compensation, will confirm the start date, restrictions, and any accommodation terms in writing. - Managers may not independently approve or deny return-to-work status without HR review. 6. **Full-duty reinstatement** - Once the employee provides clearance to return without restrictions, or once accommodations are implemented that allow performance of essential functions, the employee will be reinstated to the position held before leave or to an equivalent position when required by law. 7. **Follow-up monitoring** - HR may conduct periodic check-ins to confirm the accommodation remains effective and to address any changes in restrictions. - Updated documentation may be requested when the employee's condition changes or when permitted by law.

**Employee** - Provide timely notice of return-to-work readiness and any restrictions. - Submit required medical documentation promptly. - Participate in the interactive process in good faith. - Follow approved restrictions and accommodation terms. **Manager** - Refer all return-to-work questions to HR. - Do not request medical details beyond what is legally permitted. - Implement approved restrictions and accommodations. - Escalate safety concerns or performance issues to HR. **HR / Leave Administrator** - Coordinate documentation, leave status, and return-to-work approvals. - Conduct the interactive process and document accommodation decisions. - Maintain confidentiality of medical information. - Ensure compliance with FMLA, ADA, EEOC guidance, FLSA, and applicable state laws. **Safety / Workers' Compensation** - Review job hazards and physical requirements when relevant. - Help evaluate safe work restrictions and transitional duty assignments. **Policy Holder / Department Head** - Ensure staffing decisions support compliant return-to-work practices. - Approve operational changes needed for temporary assignments or accommodations.

Failure to follow this policy may result in delayed return-to-work approval, removal from duty until documentation is received, or corrective action if an employee refuses to comply with lawful, job-related requirements. The Company will not discipline an employee for: - Taking protected leave under the FMLA or applicable state law. - Requesting a reasonable accommodation. - Reporting a workplace injury or safety concern. - Engaging in protected activity under the NLRA. Any discipline must be based on documented, legitimate business reasons and applied consistently. If an employee cannot return to work because of a disability, pregnancy-related condition, or other protected condition, the Company will evaluate leave extension, accommodation, or reassignment options before taking adverse action. **Data privacy:** Medical records and return-to-work documentation will be stored separately from personnel files and handled in accordance with applicable privacy laws, including the ADA confidentiality rules, the CCPA where applicable, and any local data protection requirements.

This policy will be reviewed at least annually and updated as needed to reflect changes in federal, state, and local employment laws, operational requirements, and business practices. Revisions must be approved by HR and legal counsel or another designated compliance authority before publication.