Run: Termination of Employment Policy

This policy establishes consistent procedures for managing employment separations in a lawful, respectful, and documented manner. It is designed to support compliance with applicable wage and hour laws, anti-discrimination requirements, benefits administration rules, and security/offboarding controls.

This policy applies to all employees, including full-time, part-time, temporary, and seasonal workers, unless a written employment agreement, collective bargaining agreement, or applicable law requires different treatment. Where a conflict exists, the applicable law, agreement, or jurisdiction-specific rule controls. **California employees:** final pay timing, accrued vacation/PTO payout, and related separation obligations must comply with California Labor Code requirements. **New York employees:** separation-related wage payment and notice obligations must comply with applicable New York Labor Law requirements. **Other state overlays:** HR must review state final pay, notice, and continuation coverage rules before processing a termination.

Key terms used in this policy include: - **Voluntary termination**: resignation, retirement, or other employee-initiated separation. - **Involuntary termination**: dismissal, layoff, reduction in force, or other employer-initiated separation. - **Final pay**: all earned wages, overtime, commissions, bonuses if earned under policy or agreement, and any other required compensation. - **Offboarding**: the coordinated process for ending system access, collecting property, transferring work, and completing exit documentation. - **Interactive process**: the ADA-required, good-faith dialogue used to evaluate reasonable accommodation requests when disability-related issues arise during employment or separation. - **Essential function**: a fundamental job duty of the position, as distinguished from marginal tasks.

Employment may end voluntarily or involuntarily. The company will handle each separation in a consistent, non-discriminatory, and documented manner, without regard to protected characteristics under Title VII of the Civil Rights Act of 1964 or other applicable equal employment laws. The company will not retaliate against any employee for engaging in protected activity under the NLRA, reporting concerns, requesting leave, or seeking a reasonable accommodation. Termination decisions must be based on legitimate business reasons, performance, conduct, attendance, restructuring needs, or other lawful grounds. When an employee has an active leave, accommodation request, or workplace complaint, HR must review the matter before finalizing separation to ensure the decision is not inconsistent with FMLA, ADA, or other applicable obligations.

### 1) Voluntary separations - Employees are expected to provide written notice of resignation when practicable; the standard notice period is **two weeks** unless a different period is stated in an offer letter, contract, or local law. - Managers must immediately notify HR upon receiving a resignation. - HR will confirm the last day worked, transition responsibilities, and final pay processing steps. ### 2) Involuntary separations - Before termination, the manager and HR should review the employee file, documented warnings, PIP records, attendance records, and any prior accommodations or leave activity. - Where performance or conduct is the basis for termination, the company should use documented warning steps or a PIP when appropriate, unless immediate termination is warranted by serious misconduct or business necessity. - HR and the manager must confirm the termination date, final pay requirements, benefits status, and access revocation plan before the meeting. ### 3) Termination meeting - Conduct the meeting respectfully and privately. - Provide the employee with the separation decision, effective date, and any required written notices. - Collect company property when possible, or provide a return deadline and instructions. - Do not debate the decision in the meeting; direct questions to HR. ### 4) Final pay - Final pay must be issued in accordance with applicable federal, state, and local law, including the FLSA and any stricter state final paycheck rules. - Final pay should include all earned wages and any other amounts required by law, policy, or agreement. - HR/payroll must document the calculation method and payment date. ### 5) Benefits and leave - HR will provide information about benefits continuation, including COBRA or state continuation coverage where applicable. - If the employee is on FMLA leave or has an ADA accommodation, HR must confirm whether any additional notices or coordination steps are required. - Accrued PTO/vacation payout will be handled according to applicable law and company policy. ### 6) Offboarding and access removal - IT and Security must disable access to systems, email, badges, and physical access on or before the separation effective time, subject to business continuity needs. - The employee must return company property, including devices, keys, documents, and confidential materials, by the stated deadline. - The manager must complete knowledge transfer, customer handoff, and project transition steps as needed. ### 7) Exit documentation - HR will maintain separation records, including resignation letters, termination notices, final pay records, benefits notices, and property return confirmations. - Exit interviews may be offered at HR’s discretion and should not be used to pressure the employee into waiving legal rights.

- **Managers**: notify HR promptly, document performance or conduct issues, support transition planning, and participate in separation meetings as directed. - **HR**: review legal and policy requirements, coordinate final pay and benefits notices, maintain documentation, and ensure non-discriminatory handling. - **Payroll**: calculate and issue final wages and any required payments on time. - **IT/Security**: revoke access and protect company systems and data. - **Employees**: provide notice when required or practicable, return company property, and cooperate with reasonable offboarding steps. - **Policy holder**: the HR department is the policy holder responsible for maintaining this policy and coordinating revisions.

Failure to follow this policy may result in corrective action, up to and including termination of employment, where permitted by law. The company may also take steps to recover unreturned property, address unauthorized access, or correct payroll and benefits errors. This policy does not create a contract of employment or alter at-will employment status where applicable. Nothing in this policy limits rights protected by the NLRA, FMLA, ADA, EEOC-enforced laws, or any applicable whistleblower or leave law.

Exceptions must be approved in writing by HR and Legal, or by another designated executive approver, and must comply with applicable law. Jurisdiction-specific requirements, collective bargaining agreements, and individual employment contracts take precedence over this policy where they provide greater employee rights or different procedures.

This policy will be reviewed at least annually and updated as needed to reflect changes in federal, state, and local employment laws, including wage payment, leave, anti-discrimination, and data retention requirements. Revisions must be approved by HR and Legal before publication.