Run: Workers' Compensation Policy

This policy establishes the process for promptly reporting workplace injuries and illnesses, obtaining appropriate medical treatment, filing and managing workers' compensation claims, assigning temporary light duty or modified work when available, coordinating wage replacement benefits, and supporting a safe return to work. This policy is intended to comply with applicable state workers' compensation laws and related federal requirements, including the ADA, EEOC anti-discrimination rules, FLSA wage and hour requirements, and OSHA reporting and safety obligations.

This policy applies to all employees, including full-time, part-time, temporary, and seasonal employees, as well as supervisors and managers responsible for injury reporting and work restrictions. It applies to all work-related injuries, illnesses, exposures, and incidents occurring during the course of employment, including incidents occurring at company facilities, job sites, client locations, travel required for work, and other locations where work is performed. California employees: workers' compensation administration must also be coordinated with California-specific claims handling, notice, and return-to-work requirements. Other state-specific requirements may apply based on the employee's work location.

For purposes of this policy: - **Work-related injury or illness** means any injury, illness, or condition that is caused by or arises out of employment, subject to applicable state law. - **Medical treatment** means evaluation, first aid, emergency care, physician care, therapy, prescriptions, or other treatment related to the injury or illness. - **Light duty / modified work** means temporary assignments that accommodate medical restrictions while the employee recovers. - **Essential function** means a fundamental duty of the position, not a marginal task. - **Reasonable accommodation** means a workplace adjustment required under the ADA that enables a qualified individual with a disability to perform the essential functions of the job, unless doing so would create undue hardship. - **Good-faith** means honest, timely, and cooperative participation in reporting, claim handling, and the interactive process.

The company will respond promptly to reported workplace injuries and illnesses, direct employees to appropriate medical care when required, and coordinate workers' compensation claims in accordance with applicable law. The company will not retaliate against any employee for reporting an injury, filing a claim, requesting medical care, participating in an investigation, or exercising rights under workers' compensation, the ADA, the FMLA, the NLRA, or any other applicable law. The company may provide temporary light duty or modified work when available and when consistent with medical restrictions, business needs, and applicable law. Light duty is not guaranteed and does not replace any legal obligation to provide a reasonable accommodation through the interactive process. Wage replacement, benefit eligibility, and leave coordination will be administered according to the applicable state workers' compensation system and any overlapping leave or wage-and-hour requirements.

1. **Immediate reporting**: Employees must report any work-related injury, illness, exposure, or near-miss to a supervisor as soon as practicable, and no later than the end of the shift unless emergency circumstances prevent it. 2. **Supervisor response**: The supervisor must ensure the employee receives emergency assistance if needed, notify HR or the designated claims contact immediately, and document the incident using the company incident report form. 3. **Medical treatment**: The company will direct the employee to appropriate medical care consistent with applicable state law. In emergencies, employees should call emergency services or go to the nearest emergency room. 4. **Claim filing**: HR or the claims administrator will provide required claim forms, notices, and instructions, and will submit reports to the insurer or state agency as required. 5. **Work restrictions**: Employees must provide medical work restrictions, if any, to HR. The company may request fitness-for-duty or work-status documentation to the extent permitted by law. 6. **Light duty / modified work**: If available, the company may offer temporary modified work that fits the employee's restrictions and essential functions of the business. Assignments may include reduced physical demands, alternate tasks, or adjusted schedules. 7. **Wage replacement coordination**: HR will coordinate workers' compensation wage replacement benefits and any available paid time off, sick leave, or other leave benefits in accordance with law and company policy. Exempt employees will not have salary deductions made in a manner inconsistent with FLSA requirements. 8. **Return-to-work**: Before returning, the employee must provide any required release or work-status documentation. The company will evaluate whether the employee can resume regular duties, continue modified work, or needs an interactive process for reasonable accommodation. 9. **Ongoing updates**: Employees must promptly report changes in condition, restrictions, treatment status, or expected return date. Supervisors and HR must maintain good-faith communication throughout recovery. 10. **Recordkeeping**: Incident reports, medical restrictions, claim documents, and return-to-work records must be maintained confidentially and separately from general personnel files to the extent required by law.

- **Employees**: Report injuries promptly, seek appropriate care, provide work restrictions and status updates, and cooperate in the claims and return-to-work process. - **Supervisors/Managers**: Respond immediately to incidents, ensure safety, escalate to HR, preserve the scene when appropriate, and support temporary work restrictions. - **HR / Claims Administrator**: Coordinate claim reporting, notices, benefits, leave coordination, documentation, and communications with the insurer and employee. - **Safety Team**: Investigate incidents, identify corrective actions, and support prevention measures. - **Finance / Payroll**: Process wage replacement, PTO offsets, or payroll adjustments in accordance with law and approved claim status. - **Legal / Compliance**: Review disputed claims, accommodation issues, retaliation concerns, and state-specific requirements.

Failure to report an injury promptly, falsification of an incident report, refusal to cooperate with a lawful investigation, or misuse of leave or benefits may result in corrective action, up to and including termination, subject to applicable law. Discipline will not be imposed for good-faith reporting of injuries, filing a workers' compensation claim, requesting medical care, or engaging in protected activity under the NLRA, ADA, FMLA, EEOC laws, or applicable state whistleblower protections. Any disciplinary action must be reviewed to ensure it is based on legitimate, documented business reasons and not on retaliation or discrimination.

This policy will be reviewed at least annually and updated as needed to reflect changes in workers' compensation law, wage-and-hour requirements, ADA accommodation standards, OSHA obligations, and state-specific rules. California employees: review for compliance with California workers' compensation, leave, and anti-retaliation requirements. New York employees: review for any applicable whistleblower and retaliation protections. Other jurisdictions may require additional notices, forms, or timelines.