Run: Veterans Hiring and Support Policy

The purpose of this policy is to: - Support the recruitment, hiring, retention, and advancement of veterans and military-connected employees. - Ensure compliance with **USERRA**, the **ADA**, the **FLSA**, **Title VII**, and applicable state and local laws. - Establish a consistent process for military leave, reemployment, benefits continuation, and reasonable accommodation. - Provide managers and HR with clear responsibilities for supporting employees with military obligations. This policy is intended to be administered in a **good-faith** and non-discriminatory manner.

This policy applies to all employees, applicants, interns, temporary workers, and managers in the United States, unless a more protective federal, state, or local law applies. **Applicable jurisdictions:** United States. Where state or local law provides greater protection, the company will follow the law that is most protective of the employee. **California employees:** Any military leave, wage statement, meal/rest break, or retaliation issue must also be reviewed for California-specific requirements, including wage-and-hour rules and anti-retaliation protections. **All managers:** Must follow this policy when making hiring, scheduling, performance, leave, or discipline decisions involving military-connected employees.

For purposes of this policy, the following terms apply: - **Veteran**: An individual who has served in the uniformed services. - **Military-connected employee**: An employee with current or prior military service obligations. - **Interactive process**: A timely, individualized, good-faith discussion to identify a reasonable accommodation. - **Reasonable accommodation**: A change to the application process, job duties, schedule, or work environment that enables performance of the essential function(s) of the role, absent undue hardship. - **Essential function**: A core duty of the position that cannot be removed without changing the nature of the job. - **Undue hardship**: Significant difficulty or expense under applicable law. - **Documented warning**: A written record of performance or conduct concerns issued before escalation to a PIP or other discipline. - **PIP**: A performance improvement plan with measurable expectations, support, and a defined review period.

The company will not discriminate against applicants or employees because of veteran status, military service, or military obligations. Employment decisions will be based on qualifications, performance, business needs, and lawful criteria. The company will: 1. Provide equal access to recruiting, hiring, promotion, training, compensation, and benefits. 2. Consider military experience as relevant work experience where appropriate. 3. Provide a timely, good-faith interactive process for accommodation requests related to service-connected disabilities or other protected needs. 4. Administer military leave and reemployment rights in accordance with **USERRA**. 5. Maintain pay practices that comply with the **FLSA**, including proper exempt/non-exempt classification and overtime rules. 6. Prohibit retaliation, interference, or adverse treatment related to military service, leave, accommodation requests, or protected complaints. The company will not require an employee to waive rights under USERRA, the ADA, or any other applicable law as a condition of employment.

### 1) Recruiting and Hiring - Job postings should encourage qualified veterans and military-connected candidates to apply. - Recruiters and hiring managers should evaluate military experience for transferable skills, leadership, technical training, and mission-critical experience. - Interview questions must focus on job-related qualifications and may not inquire into protected medical information or unlawfully penalize military service. - Where required for federal contractors or other covered employers, the company will maintain appropriate veteran outreach and recordkeeping practices. ### 2) Military Leave and Notice - Employees should notify their manager and HR as soon as practicable when military obligations arise. - HR will review the request, confirm applicable leave rights, and document the expected duration when known. - The company will not deny leave because of staffing concerns if leave is protected by law. ### 3) Reemployment After Service - Employees returning from protected military service should contact HR promptly upon return or as required by law. - HR will assess reemployment rights, seniority, benefits, pay, and position restoration under **USERRA**. - The company will restore the employee to the position they would have attained with reasonable certainty, or an equivalent position where required by law. ### 4) Reasonable Accommodation - Employees or applicants may request an accommodation verbally or in writing. - HR will begin the **interactive process** promptly and may request limited documentation when permitted by law. - The company will identify effective accommodations that allow the employee to perform the **essential function** of the job, unless doing so creates an undue hardship. - Examples may include schedule adjustments, modified equipment, leave, reassignment to a vacant position where required, or changes to non-essential duties. ### 5) Pay, Timekeeping, and Classification - Non-exempt employees must record all hours worked, including any approved overtime, in accordance with the **FLSA**. - Managers may not permit off-the-clock work or improperly classify employees to avoid overtime obligations. - Military leave, paid leave, and unpaid leave will be administered consistently with wage-and-hour requirements and applicable state law. ### 6) Benefits, Seniority, and Training - Benefits continuation, accruals, seniority, and training access will be handled in accordance with applicable law and plan terms. - HR will explain any employee contributions, reinstatement deadlines, or documentation requirements. - Employees on military leave will be considered for training, promotion, and development opportunities when legally required and operationally feasible.

**HR / People Team** - Maintain this policy and coordinate compliance reviews. - Manage leave, accommodation, and reemployment requests. - Keep confidential records separate from general personnel files where appropriate. **Managers** - Support employees with military obligations. - Escalate leave, accommodation, or reemployment questions to HR immediately. - Avoid retaliatory comments, schedule changes, or discipline tied to military service. **Employees** - Provide notice of military obligations as soon as practicable. - Participate in the interactive process in good faith. - Submit time records accurately and follow call-in or leave procedures when able. **Compliance / Legal** - Review complex cases, disputes, and jurisdiction-specific requirements. - Confirm whether a documented warning or PIP is appropriate when performance issues may overlap with protected leave or accommodation needs.

Violations of this policy may result in corrective action, up to and including termination, subject to applicable law and any collective bargaining agreement. The company will not discipline an employee for exercising rights under **USERRA**, the **ADA**, the **FLSA**, or other applicable law. Before issuing a **documented warning** or placing an employee on a **PIP**, managers must consult HR when the employee has an active military leave, accommodation request, or reemployment issue. Any complaint of discrimination, retaliation, interference, or failure to accommodate must be escalated to HR or Compliance immediately. The company will investigate concerns promptly and take corrective action where warranted. **State-specific overlays:** - **California employees:** Review any discipline, leave, or retaliation issue for California Labor Code and FEHA implications. - **New York employees:** Review whistleblower and retaliation concerns under applicable New York law. - **Washington employees:** Review paid sick leave interactions where military-connected absences overlap with state leave rights. - **Illinois employees:** Review scheduling and rest-period issues under applicable Illinois law where relevant.

This policy will be reviewed at least annually and updated as needed to reflect changes in law, business operations, or best practices. The policy holder is responsible for maintaining the current version, documenting revisions, and ensuring managers receive updated guidance after material changes. **Version control:** - Version: 1.0 - Effective date: 2026-01-01 - Review frequency: Annual