Run: Tobacco and Vaping Workplace Policy

This policy establishes a smoke-free and vape-free workplace, protects employees, visitors, customers, and contractors from exposure to tobacco smoke and aerosol, and sets clear rules for any permitted tobacco or vaping use in designated areas. The policy also supports employee health through access to cessation resources.

This policy applies to all employees, temporary workers, interns, contractors, visitors, and vendors while on company premises, in company vehicles, at client sites, and during company-sponsored events where the company controls the work environment. It applies during working time and non-working time on company property, except where a designated area is expressly permitted by law and approved by the company. **Applicable jurisdictions:** This policy is intended for U.S. workplaces and must be applied together with state and local smoke-free workplace laws. Where local law is more restrictive, the stricter rule controls. **California employees:** Follow all applicable California smoke-free workplace requirements and any local ordinances that are more protective than this policy. **New York employees:** Follow all applicable New York smoke-free air requirements and local ordinances. **Washington employees:** Follow all applicable Washington smoke-free workplace rules and paid break requirements when scheduling breaks.

For purposes of this policy: - **Tobacco products** include cigarettes, cigars, pipes, chewing tobacco, snuff, and similar products. - **Vaping products** include e-cigarettes, vape pens, and similar electronic nicotine delivery systems. - **Smoking** includes inhaling, exhaling, burning, or carrying any lighted tobacco product. - **Designated smoking area** means a location approved by the employer for tobacco or vaping use, if allowed by law, that is separated from indoor work areas and positioned to minimize exposure to others. - **Interactive process** means the good-faith, individualized discussion used to evaluate a request for reasonable accommodation under the ADA.

1. **Smoke-free expectation.** Smoking, vaping, and the use of tobacco products are prohibited in all indoor workplace areas, enclosed company vehicles, restrooms, conference rooms, break rooms, stairwells, lobbies, and any other non-designated areas. 2. **Designated areas only.** If the company provides a designated smoking area, tobacco or vaping use is allowed only in that area and only when permitted by applicable law. Employees must use the area in a way that does not create a nuisance, safety hazard, or exposure to others. 3. **No retaliation or discrimination.** This policy will be enforced consistently and without discrimination on the basis of any protected characteristic under Title VII of the Civil Rights Act of 1964 or other applicable law. 4. **Break time treatment.** Nonexempt employees must accurately record all work time and break time in accordance with the FLSA. Unpaid meal periods and paid rest breaks, if provided, are governed by company policy and applicable law; tobacco or vaping breaks are not guaranteed and may not extend paid working time. 5. **Accommodation requests.** Employees who believe a disability-related accommodation is needed must contact HR to begin the ADA interactive process. Any accommodation will be evaluated individually and may be denied if it would create undue hardship or conflict with safety or legal requirements. 6. **Protected concerted activity.** Nothing in this policy is intended to interfere with employees' rights under Section 7 of the NLRA to engage in protected concerted activity, including discussing workplace conditions or terms of employment.

1. **Posting and communication.** HR or Facilities will post smoke-free signage where required by law and communicate designated areas, if any, to employees and visitors. 2. **Use of designated areas.** Employees may use designated areas only during approved break times or non-working time, unless local law requires otherwise. Employees must dispose of cigarette butts, ash, and related waste in approved receptacles. 3. **Visitor and contractor compliance.** Managers are responsible for informing visitors, vendors, and contractors of this policy and directing them to approved areas. 4. **Reporting concerns.** Employees should report policy violations to their manager, HR, or the Compliance Officer. Reports will be handled in good faith and, where possible, confidentially. 5. **Cessation support.** The company may provide access to cessation resources such as an Employee Assistance Program (EAP), quitline information, health plan resources, or wellness programs. Availability of resources does not create a guarantee of coverage or benefits. 6. **Accommodation requests.** Requests for reasonable accommodation related to nicotine dependence, disability, or another medical condition must be submitted to HR. HR will engage in the interactive process and document the outcome.

**Employees** must comply with this policy, use designated areas only when permitted, and follow all posted instructions. **Managers** must enforce the policy consistently, address violations promptly, and escalate repeated concerns to HR. **HR** must maintain the policy, coordinate the interactive process for accommodation requests, and provide information about cessation resources. **Facilities / Operations** must maintain signage, receptacles, and any designated areas in compliance with applicable law. **Policy holder**: HR is the policy holder responsible for review, updates, and recordkeeping.

Violations of this policy may result in corrective action up to and including a documented warning, removal from the premises, suspension, or termination of employment, depending on the severity and frequency of the violation and any applicable law. Repeated violations may be addressed through a PIP when conduct affects performance or compliance expectations. The company will apply discipline in a consistent, non-discriminatory manner and will not retaliate against employees for raising concerns in good faith.

This policy will be reviewed at least annually and updated as needed to reflect changes in federal, state, and local law, operational needs, and available cessation resources. Any revisions must be approved by HR and Legal before publication.