HRC EMPLOYEE HANDBOOK 2025 by Human Rights Campaign

EMPLOYEE HANDBOOK

MAY 2025

Employee

Introductory

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INTRODUCTION

Welcome to the Human Rights Campaign!

The location of HRC’s headquarters in Washington, DC is a powerful symbol for all those who visit the nation’s capital – a reminder to our allies and opponents that HRC’s work is permanent and enduring. Our building, just blocks from the White House, is a landmark destination for our members and supporters. We have deep roots in Washington, working frequently in partnership with other national organizations and engaging in regular activity on Capitol Hill. We are also proud of our work beyond Washington, D.C.,working in partnership with local and state organizations and activists with dedicated volunteers in 30+ communities, and in statehouses across the country. No matter your location or your role, your time with HRC will present opportunities that drive your passion, challenge your skills, and shape the future for the LGBTQ+ community to hurry up history.

All staff are employees of the Human Rights Campaign even though your day-to-day projects may support the mission and objectives of the Human Rights Campaign, those of the Human Rights Campaign Foundation, or both organizations. As an employee of HRC, you will be expected to contribute your talent and energies to fulfilling the mission of HRC and HRCF and to continually evolve our workplace culture.

Your employment, compensation, opportunities for advancement, and benefits are dependent upon your dedication and performance. In accordance with our Equal Employment Opportunity policy, provided in this Handbook, no one will be denied opportunities or benefits on the basis of race, color, sex, age, personal appearance, pregnancy, sexual orientation, gender identity or expression, family responsibilities, genetic information, disability, religion, national or ethnic origin, political or union affiliation, marital status, veteran status, or other legally protected category with regard to recruiting, hiring, job assignment, promotion, disciplinary action, separation, compensation, training, and other terms, conditions, and privileges of employment.

This Handbook is intended to inform you of the organization’s employment practices and policies, and HRC’s expectations of you, as an employee. Note that these practices and policies do not apply to employees of an HRC Action Center; those employees are responsible for the practices and policies set forth by their designated Action Center.

This document is not a contract, express or implied, and the language contained herein may not be construed as such. The policies and information contained in this Handbook are not intended to alter, in any way, the organization’s at-will relationship with non-represented employees (see Employment at Will), or affect the terms of the collective bargaining agreement (CBA) between HRC and the Service Employees International Union (SEIU). In the event of any discrepancy between the Employee Handbook and the CBA, the CBA will govern for those employees represented by SEIU. Any policy or practice not addressed in the CBA is governed by the stipulations and parameters described in this Employee Handbook.

Except as prohibited by law, the policies, practices, expectations, and benefits described in this Handbook may be revised, suspended, or discontinued at any time, with or without advanced notice, according to business needs, employment regulations, and/or economic conditions. HRC makes every effort to notify employees of relevant changes in a timely manner.

This Handbook supersedes any prior Handbook, policies, procedures, or practices addressing similar topics and applies to all HRC full-time, part-time, and temporary employees as well as interns and fellows, as noted, regardless of date of hire or position held. In all instances, HRC policies and practices will comply with applicable federal, state, and local laws and this Handbook will be deemed to conform to such laws.

All employees are expected to adhere to all of the policies, procedures, practices, and standards outlined in this Employee Handbook, as well as those provided on HRC’s intranet and in other HRC documents. Violation of any HRC policy, whether or not contained in this Employee Handbook, may result in disciplinary action, up to and including termination of employment.

Please read this document carefully and refer to it whenever questions arise. Your manager and the People Strategy team are also available to provide support anytime.

We wish you great success in your role with HRC!

No matter your location or your role, your time with HRC will present opportunities that drive your passion, challenge your skills, and shape the future for the LGBTQ+ community to hurry up history.

OUR GUIDING PRINCIPLES

Since 1980, HRC has worked tirelessly to build the most powerful movement for equality our country has ever seen. Despite this progress, our most marginalized are still suffering from violence, discrimination, and fear. Our goal is to ensure that all LGBTQ+ people, and particularly those of us who are transgender, people of color, and HIV+, are treated as full and equal citizens within our movement, across our country, and around the world. Read more about our mission and history, and the power of our movement here.

OUR VISION

The Human Rights Campaign and the Human Rights Campaign Foundation exist to create a world where lesbian, gay, bisexual, transgender, and queer (LGBTQ+) people in all of our intersecting identities realize systemic equality, equity, and liberation in all aspects of life.

OUR MISSION

The Human Rights Campaign and Human Rights Campaign Foundation fight to make equality, equity, and liberation a reality for all lesbian, gay, bisexual, transgender, and queer (LGBTQ+) people. As the nation’s largest LGBTQ+ civil rights organization, we drive impact by:

• Inspiring, engaging and mobilizing millions of pro-equality voters and supporters to elect pro-equality leaders and to demand equity-based policies and legislation;

• Changing hearts and minds through programming that increases understanding, visibility and support for the diverse LGBTQ+ community in all aspects of our identities; and

• Transforming the institutions and systems that shape our everyday lives by advancing LGBTQ+ inclusive policies and practices in schools, workplaces, hospitals, communities, and beyond

OUR VALUES

When HRC is at its best, our work is rooted in our values: Heart; Boldness; Learning & Openness; Equity & Intersectionality; Responsibility; Resilience; Respect; and Community & Teamwork. We look to these values to guide us as we explore new opportunities in times of success as well as crisis. We use them to drive better ways of working together and to achieve more impactful results. Our values serve as our foundation as we seek to better understand each other and the work we are called to do.

HEART

We do our best work when we do it with a strong sense of purpose and a passion for a better world. Even when we’re doing hard things, we can find love and joy in unexpected places and understand the essential role hope plays in our work.

BOLDNESS

We are innovative, creative, and courageous in our pursuit of creating real and lasting change for LGBTQ+ people. It’s our job to hurry up history.

LEARNING & OPENNESS

We build spaces for engagement, reflection, and the development of competencies that are central to our work. As part of that growth process, we must acknowledge our missteps with humility and lean into our responsibility to learn and evolve.

EQUITY & INTERSECTIONALITY

We believe that the diversity of LGBTQ+ people is one of our world’s greatest strengths, yet deep disparities exist, especially for those of us who sit at the intersection of marginalized identities. Oppression in all forms is inextricably linked, which means our mission for LGBTQ+ equality will only be realized when we collaborate with our partners to break down every barrier and ensure that all LGBTQ+ people have the same ability to thrive.

RESPONSIBILITY

We are mindful that the actions we take have an impact on people’s lives, and our duty is to them. As one of the world’s leading LGBTQ+ civil rights organizations, accountability is core to our mission. We are entrusted by those we serve to observe the highest standards and ethics.

RESILIENCE

We know that adversity can build us up instead of tearing us down. The strength and wisdom that are born out of struggle are only possible through caring and healing, empowering each other, and finding moments to celebrate our successes, large and small, even in our most challenging moments.

RESPECT

We root ourselves in our shared humanity and treat each other with kindness and compassion. We’re at our best when we honor the equal dignity and worth of all people, even in the face of conflict.

COMMUNITY & TEAMWORK

We value the transformative impact of collaboration. By working together, fostering open communication, furthering understanding, and building caring and supportive environments, we can achieve something bigger than any one of us might alone.

Our values serve as our foundation as we seek to better understand each other and the work we are called to do.

OUR LEADERSHIP PRINCIPLES

Our Leadership Principles are the fundamental values and beliefs that guide us as individuals and as an organization in our decision-making and actions. These principles establish a strong foundation for effective leadership and fostering trust, respect, and accountability among team members. HRC recognizes the important role leadership plays in carrying out our mission to end discrimination against LGBTQ+ people. We practice these principles internally to build a culture of unity and respect and to achieve success personally and professionally.

DRIVE MISSION

We make mission-driven decisions that align with our goals and values; mission is at the forefront of everyone’s mind in everything we do.

CREATE IMPACT

We create impact for LGBTQ+ people by leveraging our strengths to make meaningful change.

LEAD JOYFULLY

We embrace joy and acknowledge struggle by recognizing wins and encouraging each other.

LEARN AND EVOLVE

We grow and evolve as an HRC community by learning from each other and our experiences.

OUR EMPLOYMENT PRACTICES

EMPLOYMENT AT WILL

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows, according to non-union/union status, as delineated.

PURPOSE

This policy sets forth the organization’s practices concerning U.S. labor law provisions regarding employment at will.

POLICY

Non-Union Employees

All non-union employees’ employment with the HRC is “at will.” This means that both the employee and HRC have the right to end the employment relationship at any time, with or without cause or advanced notice.

The at-will relationship also means that HRC may change the terms or conditions of employment at any time, with or without cause or advanced notice. For example, HRC may change an employee’s job duties or eligibility for certain benefits, based on the needs of the business. HRC will provide advanced notice of such changes whenever practicable.

No HRC policy or practice, whether or not contained in this Handbook, creates or may be construed as a contract or guarantee of employment for a specific period of time. Moreover, the atwill employment relationship cannot be modified by any oral, implied, or perceived agreement. All non-union employees are employees at will. No one other than HRC’s President or the Chair of HRC’s Board of Directors is authorized to change an employee’s at-will employment or to make any agreement that alters an employee’s at-will status for any period of time. Any such change must be detailed in writing and signed by the HRC President or Chair of the Board of Directors.

Union Employees

HRC employees who are represented by SEIU are subject to the terms of their applicable collective bargaining agreement. In the event of a discrepancy between this handbook, as it applies to union employees, and the applicable collective bargaining agreement, the latter shall govern.

EQUAL EMPLOYMENT OPPORTUNITY

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows, and applies to all aspects of HRC employment, including, but not limited to, recruiting, hiring, job assignment, promotion, disciplinary action, separation, compensation, training, benefits, and other terms, conditions, and privileges of employment.

PURPOSE

This policy outlines HRC’s commitment to maintaining a workplace that provides equal employment opportunity to everyone, in accordance with applicable laws .

POLICY

HRC is committed to providing equal employment opportunity and does not discriminate against any person for any reason, including race, color, sex, age, personal appearance, pregnancy, sexual orientation, gender identity or expression, family responsibilities, genetic information, disability, religion, national or ethnic origin, political or union affiliation, marital status, veteran status, or other legally protected category with regard to recruiting, hiring, job assignment, promotion, disciplinary action, separation, compensation, training, and other terms, conditions, and privileges of employment.

HRC recognizes that many classes of people have historically been denied the opportunity to compete for certain jobs. We further recognize the value of diversity in the workplace, generally, and at HRC in particular. It is the policy of HRC to encourage and promote the recruitment of women, people of color, transgender and non-binary individuals, and other historically underrepresented communities, to the extent allowed by applicable law. The intent of this policy is to expand the pool of applicants for all positions, ensuring that members of historically underrepresented communities are aware that these opportunities exist and that the workplace at HRC is welcoming and inclusive.

Employees with questions or concerns about any type of discrimination or harassment in the workplace are encouraged to immediately bring these issues to the attention of their manager, department director, or the People Strategy department. Any manager or department director who receives a complaint or concern regarding potential discrimination or harassment must immediately report the situation to HRC’s People Strategy leaders or General Counsel who will ensure a prompt, thorough, and impartial investigation of the matter.

Employees who, in good faith, raise concerns or make complaints of discrimination or harassment, even if erroneous, are protected from all forms of retaliation. Anyone found to be engaging in any type of unlawful discrimination or harassment, including leaders or managers who knowingly permit such behavior, will be subject to disciplinary action, up to and including termination of employment.

AMERICANS WITH DISABILITIES ACT (ADA and ADAAA)

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows as well as job applicants, and concerns all aspects of employment, including recruiting, hiring, job assignment, promotion, disciplinary action, separation, compensation, training, benefits, and other terms and conditions of employment.

PURPOSE

This policy outlines the company’s commitment to upholding all requirements of the Americans with Disabilities Act (ADA) and the ADA Amendments Act (ADAAA). These are federal laws that prohibit discrimination against qualified applicants and employees with covered disabilities, and require that reasonable accommodations be provided, as needed, to qualified applicants and employees so that they may perform the essential duties of their position.

DEFINITIONS

For the purposes of this policy, disability is defined as physical or mental impairment that substantially limits one or more of an individual’s major life or bodily functions; a record of such impairment; or being regarded as having such impairment.

Major life functions include caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, and working.

Major bodily functions include physical or mental impairment, such as any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more body systems, such as neurological, musculoskeletal, special sense organs, respiratory (including speech organs), cardiovascular, reproductive, digestive, genitourinary, immune, circulatory, hemic, lymphatic, skin, and endocrine. Also covered are any psychological or psychiatric diagnoses, such as intellectual disability, organic brain syndrome, mental health conditions, and specific learning disabilities.

Substantially limiting, in accordance with ADAAA regulations, is the determination, through individualized assessment, that an impairment substantially limits a major life or bodily function, is episodic, or is in remission and may substantially limit a major life or bodily function when active. Substantially limiting impairments may include, but are not limited to, epilepsy, hypertension, asthma, diabetes, major depressive disorder, bipolar disorder, and schizophrenia. An impairment, such as cancer, that is in remission but that may return in a substantially limiting form, is also considered a disability under ADAAA regulations.

Direct Threat: A significant risk to the health, safety, or well-being of individuals with disabilities or others, when the risk cannot be eliminated by reasonable accommodation.

Qualified Individual: An individual who, with or without reasonable accommodation, is qualified to perform the essential functions of the job the individual holds or is applying for.

Reasonable Accommodation: Any change to the work environment that may be reasonably made without creating undue hardship for HRC, or posing a threat to the health or safety of the individual or others in the workplace. Examples may include modifying existing facilities to be readily accessible and/or usable for individuals with disabilities; job restructuring; modified work schedules; remote work; reassignment to a comparable open position; acquisition or modification of equipment or devices; appropriate adjustment or modification of required examinations, training materials, or policies; the provision of a qualified reader or interpreter; and other similar actions to reasonably accommodate individuals with covered disabilities.

Undue Hardship: Any action that imposes significant adversity, difficulty, or expense on HRC. Undue hardship is determined on a case by case basis. Factors in determining undue hardship include the nature and cost of the proposed accommodation in relation to the size, resources, nature, and structure of HRC’s current business model.

The examples provided in the definitions above may not be all-inclusive and should not be construed as such.

POLICY

The Human Rights Campaign is committed to providing an inclusive and welcoming environment for all members of the HRC community. The organization complies with all federal, state, and local laws concerning the employment of individuals with disabilities, including the use of service and emotional support animals, and acts in accordance with regulations and guidance issued by the Equal Employment Opportunity Commission (EEOC).

HRC makes all employment decisions based on merit, job qualifications, and an individual’s ability to perform the essential functions of the job, with or without reasonable accommodation.

It is the company’s policy to ensure that qualified individuals with covered disabilities are treated in a nondiscriminatory manner with regard to application procedures, hiring, job assignment, advancement, compensation, training, benefits, separation, and other terms and conditions of employment. Furthermore, HRC maintains the confidentiality of all medical-related employee information, as required by the ADA.

HRC will reasonably accommodate qualified applicants and employees with covered disabilities when the accommodation will enable them to perform the essential functions of the job, except in cases where such an accommodation is unreasonable or would create an undue hardship on HRC, or pose a direct threat to the health or safety of the applicant, the employee, or others in the workplace.

All employees are required to comply with the company’s health and safety standards. Any employee who poses a direct threat to the health or safety of themselves or other individuals in the workplace will be placed on leave and the situation will be addressed on an individual basis, considering all relevant circumstances.

Individuals who are found to be using illegal drugs are excluded from coverage under the company’s ADA policy, to the extent allowed by applicable law.

Employees may refer to the company’s intranet for more specific information on ADA provisions and procedures. Questions concerning ADA, including requests for accommodation, should be directed to the company’s People Strategy department.

PREGNANT WORKERS FAIRNESS ACT

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows, as well as contract workers and job applicants.

PURPOSE

This policy details HRC’s commitment to upholding all requirements of the federal Pregnant Workers Fairness Act as well as any state-specific laws providing similar protections.

POLICY

HRC will not tolerate conduct that discriminates against any applicant or employee, and is committed to supporting the needs of workers with known limitations related to pregnancy, childbirth, or related medical conditions. In accordance with the federal Pregnant Workers Fairness Act (PWFA), the company will provide reasonable accommodations to such applicants and employees, unless the accommodation would impose undue hardship to HRC’s business operations, or pose a direct threat to the health and safety of the individual or others in the workplace.

In addition to the reasonable accommodations available under the Americans with Disabilities Act, ac-

commodations for employees with known limitations related to pregnancy, childbirth, or related medical conditions may include, but are not limited to:

• Frequent breaks

• Modification of uniform requirements

• Seating for jobs that require standing

• Carrying a water bottle

• Assistance with lifting

• Assignment to light duties

• Temporary elimination of essential job function(s)

“Known limitations” are those that the applicant or employee has communicated to HRC. Employees who wish to inform the company of a limitation and/or request a reasonable accommodation should speak with the People Strategy department. In accordance with the PWFA, HRC will not request a doctor’s note to determine whether an individual has a known limitation. All medical-related information will be kept confidential.

The company will not require a covered employee to accept an accommodation without first holding a discussion between the employee and People Strategy, nor will the company require a covered employee to take a leave of absence if another reasonable accommodation can be provided.

HRC will not interfere with any individual’s rights under the PWFA or take any impermissible adverse action, including any form of retaliation, against a qualified applicant or employee because they request or use reasonable accommodations in accordance with this policy, report or oppose unlawful discrimination under the PWFA, or participate in a proceeding involving an alleged violation of the PWFA.

In addition to the federal PWFA, HRC will comply with all legal requirements related to any similar state-specific laws, including providing greater or different accommodations or benefits than those indicated in this policy.

It is the policy of HRC to encourage and promote the recruitment of women, people of color, transgender and non-binary individuals, and other historically underrepresented communities, to the extent allowed by applicable law.

HARASSMENT-FREE WORKPLACE

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows, and includes job applicants, contract workers, vendors, clients, visitors, and all others who conduct business with HRC. All principles and complaint reporting procedures set forth in this policy apply to all types of unlawful harassment.

PURPOSE

The purpose of this policy is to clearly establish HRC’s anti-harassment expectations and complaint reporting procedures to ensure a harassment-free work environment.

POLICY

Unlawful harassment is a form of discrimination. HRC is committed to providing a work environment that fosters mutual respect and is free from harassment, whether verbal, visual, or physical; implied or explicit; or in an in-person or virtual environment, for any reason, including harassment based on race or ethnicity (including, but not limited to, hair texture and protective hairstyles), religion, sex (including pregnancy; childbirth or related medical conditions; reproductive health decisions; and breastfeeding, chestfeeding, and/or nursing), national origin, disability, age (over 18), personal appearance, sexual orientation, gender identity or expression, marital status, family responsibilities, genetic information (including family medical history), matriculation (e.g., enrollment status in college, vocational school, or other educational pursuit), political or union affiliation, veteran status, lawful use of tobacco products, unemployment status, status as a victim or family member of a victim of domestic violence, or any other legally protected category. In keeping with this commitment, HRC will not tolerate harassment of any employee or business associate by anyone, including the company’s leaders, board members, managers, employees, interns, fellows, contract workers, volunteers, donors, vendors, visitors, or anyone who conducts business with HRC.

Harassment, whether overt or subtle, is a form of prohibited discrimination that is demeaning, is contrary to providing an inclusive workplace, and undermines the integrity of the employment relationship. Harassment is unacceptable in the HRC workplace and in any work-related setting, such as business-related events, external meetings, business trips, etc.

For the purposes of this policy, harassment is:

• Any behavior or action that violates Title VII of the Civil Rights Act of 1964, the ADA, the ADEA, or the GINA; all federal laws that protect against discrimination.

• Any unwelcome verbal or physical conduct based on any protected category cited above.

• Severe, pervasive, persistent conduct that unreasonably interferes with an employee’s work or job performance, or creates an intimidating, hostile, or offensive work environment.

• Any situation where an employee’s employment status, opportunities, or benefits are directly affected by the harassing conduct of a manager or person of authority.

• Severe, pervasive, or persistent misgendering and/or deadnaming.

Some examples of prohibited harassment include, but are not limited to:

• Derogatory jokes, comments, or mimicking of a person’s race, religion, culture, accent, appearance, customs, or any other protected characteristic.

• Slurs, insults, stereotypes, or name-calling concerning any characteristic protected by law.

• Threatening, intimidating, or hostile acts directed toward any individual’s protected characteristic(s).

• Offensive printed or visual materials, objects, or pictures that denigrate or show hostility or aversion toward a person or group because of any characteristic protected by law.

• Obscene or harassing use of digital or other technologies concerning any characteristic protected by law. Calls; texts or emails, including emojis, GIFs, symbols, memes, video clips, etc.; and social media usage may constitute unlawful workplace harassment even if occurring away from the workplace, on personal devices, or during non-work hours.

Sexual Harassment

Sexual Harassment is a form of unlawful discrimination and may be based on an individual’s sex, sexual orientation, or gender identity or expression. Sexual harassment may occur regardless of the sex or gender of either party involved.

Sexual harassment is defined as unwelcome verbal or physical behavior related to sex or gender, sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when:

• Submission to such conduct is made explicitly or implicitly a term or condition of employment.

• Submission to or rejection of such conduct is used as the basis for employment decisions affecting an individual.

• Such conduct has the purpose or effect of unreasonably interfering with an individual’s work or job performance, or creating an intimidating, hostile, or offensive working environment.

Examples of sexual harassment include, but are not limited to, the following unwelcome behaviors:

• Slurs, jokes, or degrading comments of a sexual nature, including sexual innuendo, suggestive comments, and explicit jokes or stories.

• Offensive flirtation, leering, or sexual gestures.

• Unwanted sexual advances or propositions.

• Offers of employment benefits (e.g., promotion, continued employment, preferential treatment, etc.) in exchange for sexual favors.

• Graphic or sexually degrading verbal or written comments about an individual’s body or appearance.

• Unwanted physical contact, such as touching, patting, pinching, or grabbing.

• Physical intimidation or assault, including cornering or blocking someone’s movement.

• Displaying pornographic or sexually suggestive printed or visual materials, objects, or pictures.

• Obscene or harassing use of digital or other technologies, including the display of sexually graphic or suggestive websites, emails, screensavers, etc.

• Sex stereotyping, such as when conduct, dress, or physical traits are ridiculed or mocked because they may not conform to another person’s expectations of how a particular sex or gender should look or behave.

Names and Pronouns

An employee has the right to be addressed by their chosen name and pronouns. No official documentation of a name or gender change is required. With a commitment to our value of Respect, we honor our colleagues by using their correct names and pronouns. This requires intentional effort by the employee’s colleagues and peers. Managers should make a particular effort to emphasize this expectation with their teams at every opportunity.

The intentional or persistent refusal to acknowledge and respect an employee’s chosen name or gender identity (for example, intentionally referring to the employee by an incorrect name or pronoun) is a form of harassment and a violation of this policy. HRC does not tolerate any form of discrimination or harassment on the basis of an employee’s gender identity or gender expression. If you are unsure of a colleague’s name or pronouns, you may ask them; ask another colleague; or refer to the intranet employee listing, the individual’s email signature, their Zoom name listing, office nameplate, ID badge, lanyard pin, etc.

Misgendering, Mispronouning, and Deadnaming

Misgendering occurs when an individual refers to another person (intentionally or unintentionally) using pronouns or other forms of address that do not reflect their chosen gender identity. When misgendering is unintentional, deliberate and conscientious effort must be made to avoid repeating the mistake. Intentional or persistent misgendering is a form of harassment and is not tolerated at HRC.

Mispronouning occurs when incorrect pronouns are used to refer to someone. When mispronouning is unintentional, deliberate and conscientious effort must be made to avoid repeating the mistake. Intentional or persistent mispronouning is a form of harassment and is not tolerated at HRC.

Deadnaming occurs when a person who has changed their name to accord with their gender identity is referred to by their birth or given name. As with misgendering and mispronouning, deadnaming can be intentional or unintentional. Intentional or persistent misgendering is a form of harassment and is not tolerated at HRC.

Severe, pervasive, or persistent misgendering, mispronouning, or deadnaming are violations of this policy. Any employee who engages in such activity may be subject to disciplinary action, up to and including termination.

HRC offers the following programs to support employees in understanding and avoiding misgendering, mispronouning, and deadnaming:

• Workshops

• Coaching

• Practice sessions

• Accountability partners

If there is a violation of the harassment policy, HRC will take prompt and appropriate action reasonably designed to halt the harassment and prevent further abuse from occurring. The priority in the course of action is always the immediate end to the harm, and preservation of the safety and well-being of the HRC employee being harassed. The People Strategy and DEIB teams will work with all parties to identify an action plan including risk assessment, safety planning, and disciplinary action.

Reasonable and effective support is available for employees working to respect colleagues by using their correct names and pronouns. If an HRC employee consistently misgenders one or more colleagues after People Strategy and DEIB intervention, they may be subject to disciplinary action, up to and including termination of employment.

Procedure for Reporting Harassment or Suspected Harassment

HRC believes that all employees have the right to a work environment that is free from unlawful harassment. Preventing harassment is everyone’s responsibility, and HRC can only prevent or remedy potential or actual harassment when informed of a situation. Any employee, intern, fellow, contract worker, board member, or others who conduct business with HRC who have experienced or witnessed behavior that may constitute harassment are encouraged to report the behavior immediately.

To report behavior that may constitute harassment, including, but not limited to, the types of conduct described in this policy, please promptly contact the company’s People Strategy department, any member of HRC leadership, or the office of the General Counsel. Reports may also be made anonymously by calling HRC’s ethics and compliance hotline (1-855-662-SAFE, company ID: 4803423507). This is an independent third-party service intended to protect employee anonymity. Those wishing to remain anonymous should avoid providing any identifying information, such as name, job title, personal address and phone number, etc.

All company leaders and managers are required to promptly report to the People Strategy department or the office of the General Counsel any behavior they overhear, observe, suspect, or become aware of that appears to violate this policy, even if the situation does not involve employees in their own department. Any leader or manager who knowingly allows or fails to report suspected harassment will be subject to disciplinary action, up to and including termination.

Misgendering, mispronouning, and deadnaming are considered forms of sex-based harassment. Any HRC employee who overhears another individual refer to an employee by the wrong name or pronoun(s) has a responsibility to inform or remind them of the employee’s correct name or pronoun(s), regardless of whether the employee is present. Any manager who overhears misgendering, mispronouning, or deadnaming is required to intervene, and is further required to report to People Strategy and DEIB any incidents of consistent or aggressive misgendering, mispronouning, or deadnaming.

It is the company’s expectation that any harassment complaint will be made in good faith, meaning the reporting individual legitimately suspects harassment has occurred. Any individual who makes a complaint that is found to be intentionally false may be subject to disciplinary action, up to and including termination.

Investigation of Harassment Complaints

HRC takes all complaints of harassment very seriously. The People Strategy department and/or General Counsel will investigate all harassment complaints promptly, objectively, and thoroughly and will maintain confidentiality to the extent practicable. The company may engage a qualified, neutral, external third party to conduct the investigation if necessary or beneficial to the situation. All employees are required to cooperate with any workplace investigation as a condition of continued employment.

If an investigation reveals that the accused party has violated this policy, HRC will take prompt and appropriate corrective action to halt the harassment and prevent recurrences. This may include disciplinary action, up to and including termination of employment.

HRC strives to conduct expeditious investigations and will provide the complainant with periodic updates. Upon completion of the investigation, the complainant will be informed of the general resolution, however details of any disciplinary action against the accused party will not be communicated.

To learn about your state’s fair employment laws, or to file a workplace complaint, you should contact your state’s fair employment practices agency (FEPA). Where no special agency has been designated to enforce anti-discrimination laws, your state’s department of labor or the closest office of the federal Equal Employment Opportunity Commission (EEOC) can provide assistance.

Disciplinary action resulting from a violation of the harassment policy may include, in no particular order, and is not limited to:

• Verbal or written warning

• Change or reduction in job responsibilities (e.g., demotion or loss of managerial status)

• Loss of promotion and/or accompanying salary increase

• Requirement to attend anti-harassment training

• Requirement to work with private coach to change behavior

• Suspension of employment

• Termination with or without notice (regardless of union representation)

No Retaliation

HRC will not tolerate any form of retaliation or discrimination against individuals who, in good faith, raise concerns about harassment or cooperate/assist in an investigation of such matters. Retaliation in any form is a violation of this policy that may result in disciplinary action, up to and including termination.

Retaliation may be any action that discourages an individual from reporting a harassment complaint or cooperating in an investigation of such, or punishes an individual who has reported or cooperated in the investigation of a harassment complaint. Prohibited retaliation against an individual includes, but is not limited to:

• Termination, demotion, suspension, or refusal to hire or consider for hire

• Failure to grant equal consideration in making employment decisions

• False accusations against the individual

• Adversely altering or affecting working conditions

• Denying employment perks or benefits

• Subtle behaviors such as increased workload, exclusion from meetings, etc.

Employees who believe they or any other individual have been retaliated against, even if the retaliation is subtle, should follow the reporting procedures set forth in this policy.

SUPPORT FOR TRANSITIONING EMPLOYEES

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows. This policy’s guidelines apply not only to employees who undergo gender transition, but to all HRC employees who share a collective responsibility to support any transitioning employee.

PURPOSE

This policy is intended to support HRC’s commitment to providing an inclusive and welcoming work environment for all employees by outlining the responsibilities, expectations, and protections the organization has established to support employees who are undergoing gender transition.

POLICY

The Human Rights Campaign is an advocate for diversity and equal employment opportunity. We support freedom of gender identity and expression and believe that a work environment based on respect, trust, and collaboration creates an inclusive employee experience where everyone is free to bring their whole self to work and thrive in their career.

All HRC employees share a responsibility to uphold our values and, in doing so, all employees are expected to support colleagues who undergo gender transition. By affirming an individual’s identity we create a culture of acceptance that extends beyond our organization.

Every transitioning individual has a right to openly be and express their true self at HRC. While still maintaining professional expectations and adhering to HRC’s policies, every employee may openly express their gender identity and characteristics at work.

HRC respects every employee’s right to privacy and, at the same time, encourages transitioning employees to share their needs with others at work to build a support network and help to ensure their individual needs are addressed as effectively and discreetly as possible. In all cases, transitioning employees may expect the ongoing support of their manager, People Strategy, and Diversity, Equity, Inclusion, and Belonging (DEIB), as well as any departments with a level of involvement in the employee’s transition process.

Transitioning employees are encouraged to participate in the necessary education of their co-workers to the extent they are comfortable, however such participation is not required.

Preventing harassment is everyone’s responsibility, and HRC can only prevent or remedy potential or actual harassment when informed of a situation.

Initiating a Transition Plan

The transitioning employee, People Strategy, and an assigned Omsbudperson (typically a member of the DEIB or People Strategy teams) will work together to create a transition plan. The employee’s input in this process is essential to ensure their comfort and safety as well as the success of the plan.

An employee who is planning to undergo any gender transition process should schedule a meeting with People Strategy and DEIB as soon as possible to discuss their needs and initiate a transition plan. The purpose of this meeting is to discuss:

1. The Ombudsperson and their role in the transition process.

2. A plan for informing the employee’s manager and identifying supportive colleagues to build a support team.

3. The roles of the manager, People Strategy, and DEIB in supporting the employee’s transition.

4. When, how, and to whom the transition will be communicated.

5. A review of relevant organizational policies, including anti-harassment and privacy policies, restroom accessibility, etc.

6. Leave benefits, relevant health care benefits, and the anticipated dates of any leave that may be needed for medical procedures.

7. Available internal and external resources.

8. The importance of addressing any issues proactively as well as reporting procedures.

Guidance for the Transitioning Employee

People Strategy, DEIB, and your manager will partner with you to create a transition plan that supports a smooth transition process at work. HRC maintains a sample transition plan that you may use as a template to guide your transition at HRC. An established plan helps reduce uncertainties and outlines shared expectations for everyone.

Transition plans vary depending on each employee’s individual needs and circumstances. The sample transition plan and steps outlined in this policy are meant to serve as tools to support a transition that is as comfortable and seamless as possible in our workplace.

Before meeting with People Strategy, DEIB, and/or your manager to develop your transition plan, please consider the following:

• How would you like your team to be made aware of your transition? (e.g., a letter from you, your manager, or People Strategy; a face-to-face meeting; individual discussions with your team, led by your manager and/or People Strategy; etc.)

• Will any workspace changes be necessary during your transition?

• How do you wish for your volunteers/donors/contractors to be informed?

• Will any changes to your professional licenses be necessary?

• What concerns do you have about your transition at work?

People Strategy and Ombudsperson Responsibilities

People Strategy and the Ombudsperson will ensure that a thorough transition plan is in place and includes the following elements:

1. Names and roles of all individuals involved in the transition plan.

2. A timeline and deadlines for all elements of the transition plan, including:

a. An initial discussion with the transitioning employee’s manager to ensure they understand their responsibilities and the transition plan.

b. Introduction of the employee’s new name and/or pronouns to their department, all HRC employees, volunteers, vendors, contractors, etc. The plan should include the method of communication, person(s) responsible, and timing.

c. Any necessary changes in administrative systems, including email, intranet, payroll, and People Strategy/HR systems, to reflect new name, pronouns, and gender identity. The Ombsbudsperson will manage monday.com to track system updates and ensure timely completion.

d. Replacement of security badge, nameplate, business cards, and other work-related identification. The Ombsbudperson will coordinate with Operations to ensure timely completion of updated materials.

e. Any leave that may be necessary for medical procedures.

3. A schedule of regular check-ins with People Strategy, the transitioning employee, their manager, the Ombudsperson, and DEIB to evaluate the status of the transition plan, determine any necessary intervention, and adjust the plan as needed.

People Strategy and the Ombudsperson must also work with DEIB to protect the transitioning employee’s privacy, to the extent possible, proactively address any misgendering, mispronouning, and/or deadnaming, and ensure that all HRC employees are respectful and supportive of the transitioning employee.

Manager Responsibilities

If you are a manager who has been informed of an employee’s gender transition, HRC expects that you will offer your full support to the employee and accept your responsibilities in ensuring the effective implementation of their transition plan. Your responsibilities include:

1. Holding an initial conversation with the employee to acknowledge their transition, review the transition plan, and assure them that you will help to make their transition as smooth as possible.

2. Working in partnership with the employee, People Strategy, DEIB, and the Ombudsperson to ensure the transition plan is complete and implemented as intended.

3. Providing sufficient flexibility to meet the employee’s needs for medical appointments and procedures.

4. Partnering with the employee to ensure that the list of individuals who must be informed of name and/or pronoun changes is complete.

5. Creating a strategy with the employee to inform others of the employee’s new name and/or pronouns, and deciding with the employee if this will be done in person, by email, via Zoom, etc. It is critically important that the employee is comfortable with the strategy and timing. HRC recommends informing others a week or two before the employee begins presenting themselves in a new gender role. You and the employee should also decide together exactly what will be said in order to encourage the support of others.

6. Continually checking in with the employee to understand their experiences at work and to address any issues or concerns throughout their transition process. Managers must provide ongoing reassurance that any information the employee shares will remain private, to the extent possible.

7. Advocating for timely completion of all transition plan deadlines. This includes following up with People Strategy, IT, Ops, and Finance regarding updates to administrative systems and identification changes. Managers should be aware that there may be delays to these changes which may be triggering for the transitioning employee.

8. Advocating on behalf of the employee to minimize their exposure to deadnaming, mispronouning, and misgendering, and modeling respectful behavior and communication across the organization.

9. Being present with the transitioning employee, either in person or virtually, on the first day they are using their new name and/or pronouns, and anytime they are interacting with others who have not yet been informed of their transition.

10. Advocating for and securing external venues with all-gender restrooms when necessary/possible.

11. Intervening anytime misgendering, mispronouning, deadnaming, or disrespectful conversation is overheard. Subtle acts of bias may also be observed, such as excluding the employee from meal periods or group activities, and must be immediately addressed.

12. Immediately reporting to People Strategy, DEIB, and the Ombudsperson any actual or perceived harassment or discrimination toward the employee.

13. Attending the People Strategy/DEIB workshop on best practices for managers in supporting an employee transitioning at work.

Name and Photo Changes

HRC will change an employee’s email address, business cards, office nameplate, and administrative records to reflect a change in name and/or gender, as outlined in the employee’s transition plan. Certain records, such as those relating to payroll and retirement accounts, require a legal name change before we are able to change our HRC records.

Operations and IT, if applicable, will update any business-related photographs on the security badge, intranet, HRC website, etc. so the transitioning employee’s gender identity and expression are accurately represented.

If a transitioning employee has questions about administrative records or photo changes, they should contact People Strategy.

Communicating Changes

Changes in name/gender/pronouns must be communicated in accordance with the transition plan. No employee may communicate on behalf of the transitioning employee without explicit approval

The transitioning employee may choose to inform some co-workers of their transition before it is officially announced. This is their choice and must be respected.

In the event a need should arise to communicate changes that are not included in the transition plan, the employee, their manager, People Strategy, and the Ombudsperson must agree on a strategy for such communication.

With changes in name and/or pronouns, there may be a period of time when many people unintentionally misgender, mispronoun, or deadname the transitioning employee. It is the responsibility of every HRC employee to proactively and respectfully address any misgendering, mispronouning, or deadnaming, whether or not the transitioning employee is present.

People Strategy and DEIB should be immediately informed of any issues or challenges that arise in communicating the transitioning employee’s changes in order to quickly and effectively resolve the situation.

Names and Pronouns

An employee has the right to be addressed by their chosen name and pronouns. No official documentation of a name or gender change is required. With a commitment to our value of Respect, we honor our colleagues by using their correct names and pronouns, whether or not they are present. This requires everyone’s intentional effort. Managers should make particular efforts to emphasize this expectation with their teams at every opportunity.

Misgendering, Mispronouning, and Deadnaming

Deadnaming occurs when a person who has changed their name to accord with their chosen gender identity is referred to by their birth or given name. As with misgendering and mispronouning, deadnaming can be intentional or unintentional. Intentional or persistent misgendering is a form of harassment and is not tolerated at HRC.

With a commitment to our value of Respect, we honor our colleagues by using their correct names and pronouns, whether or not they are present.

HRC offers the following programs to support employees in understanding and avoiding misgendering, mispronouning, and deadnaming:

• Workshops

• Coaching

• Practice sessions

• Accountability partners

HRC will investigate all claims of misgendering, mispronouning, and deadnaming. If an investigation reveals that consistent misgendering, mispronouning, or deadnaming has occurred, this is a violation of HRC’s Harassment-Free Workplace policy and HRC will take prompt and appropriate action reasonably designed to halt the harassment and prevent further occurrences. In all cases, HRC will prioritize an immediate end to the harassment and the preservation of the target employee’s safety and well-being. The People Strategy and DEIB teams will work with all parties to identify an action plan including risk assessment, safety planning, and disciplinary action. Reasonable and effective support is available for employees working to respect colleagues by using their correct names and pronouns. If an HRC employee consistently misgenders one or more colleagues, after People Strategy and DEIB intervention, they may be subject to disciplinary action, up to and including termination of employment.

Best Practices for All Employees

All HRC employees have a responsibility to support any transitioning employee by adhering to the best practices outlined below.

1. The transgender status of an individual must be treated as confidential, to the extent possible, and may only be disclosed to those with a legitimate need to know, and only with the consent of the individual.

2. It is every employee’s responsibility to intervene when misgendering, mispronouning, and/or deadnaming is overheard, whether or not the transitioning employee is present. When correcting misgendering, mispronouning, or deadnaming it should initially be presumed that the individual is not doing so intentionally. If it becomes apparent that the offense is intentional and/or if the same individual must be continually corrected, People Strategy must be informed immediately.

3. No employee may communicate to any other HRC employee, board member, vendor, contractor, or third-party any information regarding the transitioning employee without the explicit approval of the employee and People Strategy. This includes disclosing that the employee is undergoing gender transition, the status of the transition, details of the transition plan, rumors or hearsay regarding the employee or their transition, or any other related information.

4. All HRC employees are required to attend a Bystander Intervention workshop to understand and apply best practices in affirming colleagues’ names and pronouns, and avoiding misgendering, mispronouning, and deadnaming.

CONFIDENTIALITY

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to clearly establish HRC’s expectations and employees’ responsibilities concerning the protection and handling of confidential and sensitive company information.

POLICY

HRC operates as a business, an employer, a political actor, and a fundraiser. In all capacities, HRC receives, develops, or has access to information that must be treated as confidential and, therefore, is to be protected by all employees.

At HRC, we expect employees to advocate for LGBTQ+ equality and sometimes encourage team members to link HRC press releases or post about important issues on their social media accounts. While HRC’s public-facing advocacy and educational information are meant to be shared, employees also frequently have access to proprietary and/or confidential information. All information related to the operations, activities, and business affairs of HRC and/or its affiliates must be kept confidential. No employee may disclose confidential information, internally or externally, in any form, including written, verbal, or digital, without the express consent of an authorized member of HRC leadership.

Proprietary or confidential information includes that which is not generally known to the public, has not yet been released to the public, or is regarded by the company, and/or its affiliates as confidential. Examples of such information may include, but are not limited to:

• Financial data, including operating costs, profit margins, business plans and strategies, unpublished financial information, budgets and projections, and credit card and other payment information.

• The existence and/or nature of HRC’s business relationships with other entities.

• Development information, such as strategies; methods of marketing; details of any contact with actual or prospective members, donors, or suppliers; the identity and any personal information regarding members or prospective members, and donors or prospective donors; and development outcomes or financial results.

• Details concerning intellectual property, including research and development, specialized internal knowledge, software, proprietary business methods and plans, and other intellectual capital related to the business of HRC.

• People-related information, such as employee names, personal contact information, job titles, and salaries; performance reviews and disciplinary action; recruiting data; employee records; and benefits or health-related information.

• Information related to the creation, development, management, and operation of HRC’s Corporate Equality Index and Healthcare Equality Index.

• HRC’s political strategies, planned activities, and political contacts, including activities involving HRC allies, and embargoed press releases.

Employees are expected to exercise care and caution in their use of confidential information and to take appropriate action to prevent its disclosure. Employees must not discuss confidential information in public, and must be certain not to disclose such information in email or text. At all times, confidential information must be secured from public access. Computers and mobile devices must be password-protected and locked when not in use, per the company’s Internet, Email and Portable Electronic Devices policy.

Employees may not use confidential information for their own gain and must return all work-related materials and confidential information to HRC immediately upon request, or upon separation of employment.

Employees of any department with more restrictive confidential information practices must follow those guidelines and procedures.

Upon hire, all employees are required to sign HRC’s Confidentiality Agreement as a condition of employment. By signing this Agreement, employees are required to protect all confidential information during and beyond their HRC employment.

If you have any questions regarding the company’s confidentiality requirements, including whether certain information is considered confidential, please speak with your manager or the General Counsel immediately for clarification.

Nothing in this policy should be interpreted to prohibit an employee from discussing their pay and conditions of employment, or to limit an employee’s rights pursuant to the National Labor Relations Act, including 29 USC Section 157, or to otherwise disclose information as permitted by law.

Human Rights Campaign (HRC) List Policy

The HRC Development department maintains a separate HRC List policy that guides the use and protection of membership and donor lists. Any employee with access to these lists is required to adhere to the standards and guidelines of the HRC List policy.

HRC follows the Association of Fundraising Professionals (AFP) Code of Ethical Standards to ensure that our members’ and donors’ privacy and confidentiality are upheld. This includes, but is not limited to:

• Honoring and protecting a member’s or donor’s right to anonymity. HRC shall keep constituent information confidential.

• Not disclosing privileged information to unauthorized parties.

• Adhering to the principle that all member, donor, and prospect information created by, or on behalf of, an institution is the property of that institution and shall not be transferred or utilized except on behalf of that institution.

• Demonstrating respect for information about members, donors, and prospective members or donors as the property of the organization for which it was gathered.

• On a regular schedule, providing members and donors the opportunity to remove their names/ information from lists that are sold to, rented to, or exchanged with other organizations.

All employees are expected to abide by this Code and immediately seek clarification from their manager or the General Counsel when any uncertainty arises.

HOURS, PAY PRACTICES & ADMINISTRATIVE RECORDS

EMPLOYEE CLASSIFICATIONS

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows. Employee classifications do not apply to independent contractors or other external workers providing services to HRC through contractual obligation.

PURPOSE

This policy establishes guidelines that support HRC’s compliance with applicable laws and regulations related to each classification of employment.

POLICY

All non-union HRC employees are classified in one of the following categories which determine their benefits eligibility and other terms of employment.

Regular Full-Time

An employee who is regularly scheduled to work 37.5 hours per week for an indefinite term is considered a regular full-time employee and is eligible for participation in all applicable benefit programs.

Regular Part-Time

An employee who is regularly scheduled to work at least 20 but fewer than 37.5 hours per week for an indefinite term is considered a regular part-time employee and may be eligible for full or pro-rated participation in certain benefit programs.

Part-Time

An employee who is regularly scheduled to work fewer than 20 hours per week, including Retail employees, is considered a part-time employee and is not eligible for participation in the company’s benefit programs.

Temporary

An employee who is hired for a temporary, defined period of time, up to six months, (such as those hired for seasonal or short-term, project-based work) is considered a temporary employee. Temporary employees may work a full-time or part-time schedule, as agreed upon at the time of hire, and may or may not be eligible for certain HRC-sponsored benefit programs.

Note, the collective bargaining agreement between HRC and SEIU defines categories of employment for union members which govern the accrual of seniority and benefits for those employees.

INTRODUCTORY PERIOD

SCOPE

This policy applies to all new HRC employees, excluding interns, fellows, and temporary employees, and addresses the first 90 days of employment.

PURPOSE

This policy outlines the purpose, conditions, and expectations of the 90-day introductory period.

POLICY

The first 90 calendar days of employment are regarded as an introductory period for all new HRC employees. During this time, the employee and HRC become acquainted and assess the suitability of the employment relationship.

Employees will be paid for all holidays recognized by HRC that occur during the introductory period. Employees will begin accruing sick, vacation, and personal leave on their first day of employment. Accrued, paid vacation days may be used only after the successful completion of the 90-day introductory period, unless otherwise agreed upon in writing at the time of hire. If an employee should separate from HRC during the introductory period, whether initiated by the employee or HRC, they will forgo entitlement to any accrued time off or benefits.

Following the successful completion of the 90-day introductory period, employees automatically transition to regular employment status and become eligible for any applicable benefits and privileges of employment that are unavailable during the introductory period.

The 90-day introductory period applies both to employees who are new to HRC as well as those who are rehired after any period of time. Employees who are promoted or transferred to a new position are not subject to the terms of the introductory period unless the promotion or transfer occurs during the first 90 days of employment.

WORKING HOURS

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

This policy is intended to establish clear guidelines and expectations regarding HRC’s regular working hours.

POLICY

HRC maintains regular office hours of 9:00 a.m. - 5:30 p.m., Monday thru Friday. The company regularly holds and participates in events and other business activities outside of these hours.

The regular workweek consists of 37.5 working hours, beginning Saturday at 12:00 a.m. and ending Friday at 11:59 p.m. Employees typically work five consecutive days, followed by two days off, although daily and weekly schedules may vary based on individual and business needs and/or job responsibilities.

A regular workday typically consists of 7.5 working hours, beginning at 9:00 a.m. and ending at 5:30 p.m., including a one hour lunch break. With the written approval of their manager, an employee may alter their regular workday to either 8:00 a.m. - 4:30 p.m. or 10:30 a.m. - 7:00 p.m. To maintain business continuity, the employee’s established working hours should be adhered to with regularity. Non-exempt employee time must be recorded in 15-minute increments, to the nearest quarter-hour. Time worked from 1 to 7 minutes past the quarter-hour must be rounded back, and time worked from 8 to 14 minutes past the quarter-hour must be rounded forward. For example, 9:06 should be recorded as 9:00 and 9:12 should be recorded as 9:15.

OVERTIME

SCOPE

This policy applies to all non-exempt, non-union full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to outline when and how employees may obtain permission or be expected to work beyond their regular hours in a workweek.

POLICY

When HRC’s business needs cannot be met during the regular workweek of 37.5 hours, employees may be required to work overtime. When possible, advanced notice of these mandatory assignments will be provided. Employees who are required to work more than 7.5 hours in a workday may be asked to flex their time, working fewer hours on a subsequent day to maintain a 37.5 hour workweek.

Unless otherwise required by applicable law, all hours worked in excess of 37.5, up to 40, per workweek will be paid at the employee’s normal hourly rate. All hours worked in excess of 40 per workweek will be paid at a rate of 1.5 times the employee’s regular hourly rate of pay. HRC will adhere to all applicable state laws on overtime that may differ.

In the event a non-exempt employee is required to work on an HRC paid holiday or to report to work when the company is closed for inclement weather or other unforeseen circumstance, the employee will be compensated at a rate of one 1.5 times their regular hourly rate of pay for these hours.

Non-exempt employees must receive authorization in advance, usually from their manager, to work overtime. Any employee who works overtime without appropriate prior approval may be subject to disciplinary action, up to and including termination. Employees will be paid for all hours worked, consistent with applicable law.

LACTATION BREAKS

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to outline HRC’s guidelines and procedures for employees who wish to express breast milk for their child during the workday.

POLICY

HRC is committed to supporting the needs of working parents and, as such, will provide reasonable breaks during the workday for employees who need to express breast milk following the birth of their child.

When possible, employees should use regular paid rest or meal breaks for expressing breast milk. If lactation breaks cannot run concurrently with scheduled rest or meal breaks, the lactation break will be unpaid for nonexempt employees, or paid in accordance with applicable law. HRC will not unreasonably limit the amount of time or frequency with which an employee may express breast milk, however in most cases a lactation break should not exceed 30 minutes. Employees are not required to perform work-related duties during lactation breaks, nor are they required to make up time used for lactation breaks.

Employees who plan to express breast milk during the workday should notify their manager and the People Strategy department in writing as far in advance as possible, ideally prior to the conclusion of any parental leave. Employees who work in person at HRC headquarters will have access to a wellness room that is suitable for expressing breast milk, free from observation (including any video/camera system), safe, clean, and free from hazardous materials. The wellness room shall contain a surface to place a breast pump and personal items, a place to sit, and access to electricity. Employees who express breast milk at work shall also have access to a sink with running water and a refrigerator suitable for storing milk in close proximity to their workspace.

Note that certain states, including New York, may provide greater or different lactation accommodations than those described in this policy. HRC complies with all relevant provisions and requirements under the Fair Labor Standards Act as well as applicable state-specific laws.

ATTENDANCE AND PUNCTUALITY

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to establish clear guidelines and expectations regarding attendance and punctuality at HRC, and to set forth standard procedures for handling employee absence.

POLICY

Consistent attendance and punctuality are essential for the overall success of our organization and contribute to a positive and productive work environment. Employees are required to report to work on time, and to work all scheduled hours as well as any overtime approved or required by their manager.

Employee Responsibility

When an employee is late, absent, or leaves work early due to illness or emergency, they must inform their manager as soon as possible, in person or by phone or email. This communication must be received prior to the employee’s scheduled start time or prior to their departure from work, and must come directly from the employee unless they are physically unable. Notice must be provided on time each day the employee is late or absent. An employee who is absent for more than three consecutive days without contacting their manager will be considered to have voluntarily terminated their employ-

ment with the company. Excessive lateness and/or absence may result in disciplinary action, up to and including termination of employment, to the extent allowed by applicable law.

Manager Responsibility

Managers are responsible for clearly communicating expected start times to all employees. If employees do not arrive at work on time, the manager must record the lateness in the Replicon system. If an employee is unable to work on a particular day, managers must ensure that time sheets accurately reflect the duration and reason for the absence (e.g., sick leave, bereavement leave, etc.).

Consistent attendance and punctuality are essential for the overall success of our organization and contribute to a positive and productive work environment.

PAY PRACTICES

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees. Interns and fellows are paid as agreed upon at the time of hire.

PURPOSE

The purpose of this policy is to establish a fair, transparent, and consistent framework for managing regular employee pay practices, in accordance with all relevant federal, state, and local laws.

POLICY

Time Sheets

All employees are required to maintain consistent, accurate timekeeping records through HRC’s Replicon timekeeping system. All hourly employees must complete time sheets on a daily basis, accurately recording time worked, and providing all other required information. Time worked must be recorded in 15-minute increments, to the nearest quarter-hour. Time worked from 1 to 7 minutes past the quarter-hour must be rounded back, and time worked from 8 to 14 minutes past the quarter-hour must be rounded forward. For example, 9:06 should be recorded as 9:00 and 9:12 should be recorded as 9:15.

No employee is permitted to work “off the clock” at any time. If any manager requests that an employee work “off the clock,” the employee must immediately bring this issue to the attention of People Strategy.

For the purposes of this policy, “off the clock” means an employee works for HRC but does not record their total time worked in HRC’s timekeeping system. “Time worked” is defined as all the time an employee spends on the job performing assigned duties.

Time sheets are approved by the employee’s manager and submitted to the Payroll department, according to established deadlines. An employee’s failure to submit accurate time sheets when they are due may result in the suspension of direct deposit privileges, and/or other disciplinary action, up to and including termination of employment. Employees will be paid for all hours worked, consistent with state and federal laws.

Under certain circumstances, HRC may require more detailed accounting of employee timekeeping; for example, to comply with the terms of specific grants or legal reporting requirements. In these situations, affected employees will receive separate guidance.

Under no circumstances may an employee complete or alter the timekeeping records of another employee.

Early Dismissal Timekeeping

From time to time, HRC may, at its discretion, dismiss employees early. Any hourly employee who is using vacation time on the day of the early dismissal must record the full number of vacation hours approved; 7.5 for a full day. Hourly employees who are working on the day of the early dismissal should record their hours worked and should designate their remaining scheduled hours as “office closure.”

Pay Periods

All HRC employees are paid on a bi-weekly basis, typically every other Friday, through direct deposit. Direct deposit elections may be made and updated through the company’s HRIS platform. In the event that a pay day falls on a company-observed holiday, employees will be paid on the nearest workday preceding the holiday. The annual HRC Payroll Calendar may be found on the company’s intranet under the People Strategy tab, in the Payroll and Tax section.

Bi-weekly pay includes all earnings for time worked during the two preceding workweeks. For example, a paycheck issued on Friday of week three will include all earnings for time worked during weeks one and two. Employees who are paid through direct deposit may access their digital pay stubs online through HRC’s HRIS. Any employee who feels that they have not received proper payment should inform their manager and/or contact the Payroll department immediately.

Payroll Deductions

In addition to normal federal, state, and local withholding taxes, employees may authorize payroll deductions for their participation in the company’s benefit plans and employee programs. No deductions, other than those legally required or individually elected, will be made from an employee’s pay without consent.

Garnishments

HRC is required to comply with all legal processes concerning employee debt collection. Upon receipt of any garnishment order, the company will promptly notify the employee of the required wage deduction and will forward the necessary monies to the creditor, as required. Employees wishing to contest wage or income action must do so directly through the garnishment server. HRC may not delay required garnishments for any reason.

Pay Advance

HRC maintains a program through which full-time regular or full-time temporary employees may request a pay advance in order to address an unexpected financial challenge. Pay advances will be provided at HRC’s discretion, according to a number of factors which may include: the nature of the situation; the dollar amount requested; HRC’s determination that the financial challenge is truly unique, unexpected, and/or rare; the urgency or the matter; and any relevant circumstances that may pose financial or other risks to the organization.

No employee will be issued more than one pay advance per 12-month period, and all advances must be repaid to HRC within four pay periods. This program may require the employee to sign a promissory note or other legally-binding agreement.

Safe Harbor

HRC is committed to paying employees accurately, on time, and in compliance with all applicable wage and hour laws. To ensure that pay is accurate, employees are expected to review their pay stubs promptly each pay period and immediately report any potential inaccuracies or improper deductions to the Payroll team. All reports will be investigated and, if an error is found, will be corrected as soon as possible, typically during the next payroll cycle. No employee will be retaliated against for reporting potential or actual payroll errors, or for bringing forth any questions related to HRC’s pay practices.

HYBRID AND REMOTE WORK

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows, unless a role’s job responsibilities require the employee to work 100% in person. The provisions and requirements of fully remote work are dependent upon HRC approval of an employee’s application for such arrangements.

PURPOSE

This policy outlines the guidelines and expectations for employees who work within a hybrid or fully remote work model.

POLICY

HRC understands that hybrid and fully remote work arrangements have many benefits, including increased productivity, more efficient use of office space, mitigating the environmental impact and cost of commuting, and assisting employees in managing their work/life balance. HRC also believes that working in the same physical space sparks creativity, increases collaboration and camaraderie, deepens professional relationships, and at times, increases efficiency. With these factors in mind, HRC has established a standard hybrid work model, enabling employees to work two days per week in person and three days per week remotely.

Upon hire, or as requested, HRC will review employee applications for fully remote work, as outlined in this policy.

Note that, based on job responsibilities, certain roles may not be eligible for hybrid or fully remote work.

Understanding Hybrid and Remote Work

Most HRC employees are designated as hybrid, meaning they are assigned to an HRC work location and perform their job responsibilities through a combination of in-person and remote work, on a set or intermittent schedule; typically two days per week in person and three days per week remote. All hybrid employees are expected to be onsite at their designated HRC work location at least one of HRC’s anchor days which are Tuesday and Wednesday.

Upon hire or approval, some HRC employees may be designated as fully remote. These employees regularly perform their job responsibilities from a remote location, such as home or another appropriate external space. Remote employees do not maintain physical workspace in any HRC location.

Hybrid and Remote Work Expectations

When working remotely, whether fully remote or as part of the company’s hybrid work arrangement, HRC expects employees to maintain the highest levels of professionalism, integrity, and productivity. When working remotely, it is expected that you will be available and dedicated to your HRC job responsibilities during your regular working hours, unless otherwise agreed upon with your manager.

HRC’s regular employment policies and procedures contained in this Employee Handbook, published on the company’s intranet, or in other HRC documents shall apply equally, at all times, to employees when working remotely.

Additionally, HRC maintains the following expectations of all employees when working remotely:

Remote Work Location

Employees must dedicate a specific space in their home or other suitable location from which to work remotely. Secure, reliable, high-speed internet access must be available at all times during working hours. All HRC-related work must be performed from a private location and not from a coffee shop, library, coworking space, etc. The work space must be conducive to productive and efficient working, free from interruptions and distractions, and conducive to virtual meetings. Additionally, the remote work location must be safe, secure, and comfortable, and must comply with HRC’s policies regarding health and safety. Please note, HRC may elect to inspect a remote work location anytime to ensure compliance with these requirements.

Employees who are unable to secure a suitable remote work location may work 100% in person from their assigned HRC location. Similarly, those who prefer to work exclusively in person may do so. Please speak with your manager to establish such arrangements.

Equipment and Technology

HRC provides all employees with the equipment necessary to perform the responsibilities of their role, including a laptop computer which hybrid employees are expected to transport between their HRC and remote work locations. HRC computers are equipped with software, operating systems, media storage, network accounts, etc., all of which are the property of HRC and are to be used for business purposes only. Unless otherwise required by law, hybrid and fully remote employees are responsible for all costs associated with securing and maintaining reliable high-speed internet connectivity which is a requirement for working remotely.

Employees who wish to request additional equipment or technology that may be necessary to effectively carry out their job responsibilities should obtain manager approval and then contact the IT depart-

ment.

Please see the company’s Internet, Email, and Portable Electronic Devices policy for more information on employee responsibilities related to equipment and technology.

Expenses

With manager approval, employees may purchase necessary office supplies through the Operations department or through their own department’s vendor; for example, Staples.

Any additional expenses incurred in furnishing or maintaining a remote work space are the responsibility of the employee, including, but not limited to, rent or mortgage payments, construction, renovations, furniture, decor, heating/air conditioning, air filtration, lighting, electricity, internet service, etc.

Proprietary, Confidential, and Sensitive Information

All employees must protect the confidentiality of HRC data and information at all times, especially when working remotely. Any proprietary, confidential, or sensitive documents or information removed from HRC’s premises must be deemed essential to an employee’s work. Such documents and/or information must be immediately transferred to the employee’s designated remote work location and must be properly secured at all times; for example, on password-protected electronic equipment or in a locked cabinet. Anytime confidential or sensitive documents or information are no longer needed in an employee’s remote work location they must be immediately and properly returned to HRC’s offices, or shredded before disposal. Employees are responsible for consulting the IT and Operations teams to ensure their remote work location adequately protects HRC’s proprietary and confidential information.

Upon termination of an employee’s remote work arrangement and/or upon separation from the company, all HRC materials, including printed and electronic copies, must be returned to HRC.

Productivity

When working remotely, employees must consistently meet productivity expectations and standards, and must be available and maintain consistent communication during all scheduled work hours, applying their full attention to their HRC job responsibilities in a distraction-free work environment. Any child or dependent care needs must not conflict with an employee’s scheduled work hours, availability, or productivity.

Virtual Meetings

Employees working remotely are expected to appear on camera and maintain an engaged, professional presence during virtual meetings, including adhering to the guidelines provided in the company’s Dress for Your Day policy. To ensure meetings are efficient and productive, it is essential that all participants strive to create a virtual work environment that is conducive to success.

In-Person Meetings and Visitors

When working remotely, employees may not conduct in-person business meetings of any nature or host visitors for business purposes at their remote work location without prior approval from their manager. All in-person business meetings, including meetings with other HRC employees, members, donors, prospects, clients, and vendors must take place at HRC or third-party offices, or at an appropriate public location.

In-Person Presence

On occasion, an employee’s presence may be required in the office or at an alternate business location on a scheduled remote workday, in order to attend in-person meetings, or participate in team projects, presentations, or events. Commuting expenses related to any in-person business requirements are the responsibility of the employee.

Work-Related Injuries or Incidents

Hybrid and fully remote employees are expected to maintain their remote workspace in a safe manner, free from potential hazards. Employees working remotely must report any work-related injury or incident, according to the company’s Safety and Ethics Reporting policy, by submitting a completed Incident Report form to People Strategy and the General Counsel, immediately or as soon as possible; no more than two business days following the incident. The Incident Report form is available on the HRC intranet.

Any employee with HRC-related safety concerns should partner with their manager, People Strategy, and the General Counsel to agree on a course of action for addressing the concern.

HRC provides all employees with the equipment necessary to perform the responsibilities of their role, including a laptop computer which hybrid employees are expected to transport between their HRC and remote work locations.

FULLY REMOTE WORK

Upon hire or approval, certain HRC roles may be designated as fully remote. In addition to the Hybrid and Remote Work Expectations outlined above, the following guidelines apply to employees who are designated as fully remote and do not maintain workspace in any HRC location.

Eligible Roles

HRC determines the suitability of any role for a fully remote work arrangement on a case-by-case basis. Not every job may be successfully performed remotely. The company considers various factors in evaluating whether a particular role is suitable for fully remote work, including, but not limited to:

• Job responsibilities.

• Level of supervision the role requires.

• Long-term impact on career development and advancement opportunities.

• The degree to which equipment, files, records, and other job-related materials must be transported between HRC and a remote location.

• The degree to which the role requires access to confidential information.

• The need for face-to-face interaction with colleagues .

• The level of technology support required.

• Financial impact of the role being remote, including any need for travel to HRC headquarters.

Note that generally, given the nature of day-to-day responsibilities, support roles such as assistants and coordinators are not eligible for fully remote work.

Eligible Employees

Any fully remote work arrangement must be approved in advance by HRC. HRC retains sole discretion in determining the eligibility of a particular individual for a fully remote employment arrangement. To qualify for consideration, you must:

• Live more than 35 miles from HRC’s headquarters in Washington, DC.

• For current employees:

• Successfully complete nine months of employment with HRC prior to applying for remote employment, unless such an arrangement is agreed upon during the hiring process.

• Be in good standing, with no disciplinary action or performance issues for the previous 12-month period.

• Demonstrate the ability to successfully work independently, fulfilling all job responsibilities and meeting expected deadlines.

• Receive approval from your manager.

• Demonstrate timely completion of HRC organizational expectations and processes such as trainings, timesheets, and expense reports.

• Have consistent access to reliable, high-speed internet.

• Be able to maintain a designated professional workspace that is free of distractions and that enables you to protect the confidentiality of HRC’s work.

• Demonstrate the ability to successfully lead and manage your team from a remote location, if your job responsibilities require such.

• Demonstrate the ability to comply with specific security requirements, as necessary, based on your job responsibilities.

Remote Work Guidelines

HRC expects the same professionalism, availability, and responsiveness from remote and in-person employees, alike. Fully remote work guidelines include the following:

Fully Remote Work Schedule

Before transitioning to a fully remote arrangement, an employee and their manager must align on an expected work schedule. Employees who remain in the same time zone as their manager and/or team(s) are expected to work a similar schedule, or as needed according to their job responsibilities. A remote employee in a different time zone than their manager and/or team(s) must agree with their manager on a schedule that is reasonable for the employee and meets the needs of the business and their role. Deviations from or modifications to the regular work schedule must be approved by the employee’s manager in writing.

Equipment and Expenses

HRC will provide fully remote employees with the equipment necessary to perform their job responsibilities, including a laptop computer, as outlined in the Equipment and Technology section, above. Additional equipment may be available upon request with manager approval. Requests should be submitted to IT via csupport@hrc.org

HRC may provide or subsidize fully remote employees with a smartphone and/or smartphone service, as set forth in the HRC Cell Phone Option provided during new employee onboarding. HRC will generally not reimburse employees for landline services unless circumstances warrant. Such reimbursement requires the approval of the employee’s department head.

Trial Period

All fully remote employees must successfully complete a 90-day remote work trial period. During this period, HRC will evaluate whether the position is suitable for fully remote work and whether the employee works effectively from a remote location. Should HRC determine, at any time, that the remote work arrangement is unsuitable for any reason, the employee will be required to regularly report to work at a designated HRC work site or enter into a hybrid work arrangement. Note that successful completion of the trial period does not guarantee that the fully remote employment arrangement will continue indefinitely.

Relocation Costs

Any relocation costs associated with remote work are the responsibility of the employee, unless the remote employment arrangement is entered into at the request and direction of HRC. In such cases, the company’s responsibility for certain necessary expenses will be determined on a case-by-case basis.

Visiting an HRC Work Location

Once an employee enters into a fully remote arrangement they no longer maintain designated work space in any HRC location, although HRC may occasionally require them to participate in in-person events such as board meetings, retreats, dinners, and other work-related functions. When a remote employee visits or works from an HRC location, they should expect to use a “hoteling” workstation or a workstation assigned to another employee who is out of the office during the visit.

When a fully remote employee travels more than 100 miles from their remote work location to HRC headquarters on approved company business, HRC will reimburse the employee’s travel, accommodations, and per diem expenses, in alignment with the company’s Travel & Expense Policy and Procedures

found on the intranet. Such trips must be approved by the employee’s manager prior to incurring any related expenses. Further, time spent in travel to HRC headquarters or another HRC location from the employee’s remote location is considered to be work time, and counts towards an employee’s expected number of hours worked per week. Such travel time may also be included in the calculation of overtime pay if the employee is non-exempt.

Health Insurance

Fully remote employees who elect to participate in HRC’s health insurance program are encouraged to contact People Strategy to ensure they have a full understanding of their plan options. Some plans may only cover emergency care outside the metropolitan DC area, or outside of the plan’s network. Other plans may impose higher charges for using out-of-network providers. Further, it may be possible to participate in another provider network to receive in-network services in the employee’s remote work location.

Tax Implications

It is the employee’s responsibility to determine and comply with any income tax implications of working fully remote. HRC does not provide tax guidance; employees are encouraged to consult a tax professional prior to applying for fully remote work.

Continuation of Fully Remote Work

All fully remote work arrangements will be reviewed on an annual basis, in conjunction with the employee’s performance review, to reinforce and ensure expectations are consistently met.

Whether or not remote work expectations are met, HRC reserves the right to discontinue a remote work arrangement anytime. In the event the arrangement is discontinued, the employee must transition to hybrid or fully in-person work, as agreed upon, within a reasonable timeframe; usually 30 days.

Applying for a Fully Remote Work Arrangement

Employees who are interested in a fully remote work arrangement should discuss their interest, timing, and plans with their manager and others in their managerial chain as a first step. If all parties agree that the employee may be eligible for remote work, the employee should submit a completed Remote Work application, available on the HRC intranet, to People Strategy.

Review of a Remote Work application is a multistep process. Employees should expect a decision within three months of submitting the application. HRC strives to ensure equity and consistency in the approval of remote applications.

ANNUAL REMOTE WORK DAYS

SCOPE

This policy applies to all regular and temporary full-time HRC employees who work within the company’s hybrid work model.

PURPOSE

This policy outlines the guidelines and expectations for hybrid employees who wish to work remotely, up to eight additional days per year.

POLICY

All hybrid employees may choose to work remotely, within the continental United States, up to eight days per year, in addition to their regular scheduled remote work days. These days may be used intermittently or may be planned in accordance with the employee’s regular hybrid work schedule to allow for four consecutive weeks of remote work per year. Annual remote work days are granted on January 1 each year and must be used or forfeited by December 31; no annual remote work days may be carried over to the following year.

Annual remote work days must be planned as far in advance as possible and are subject to manager approval. Prior to the commencement of consecutive remote work weeks, the employee and manager must agree on an expected work schedule and establish deadlines and objectives to be met during the period of remote work.

When using annual remote work days, employees are responsible for adhering to all applicable hybrid and remote work expectations, as outlined in the company’s Hybrid and Remote Work policy, above. This includes, but is not limited to, maintaining consistent availability and productivity, ensuring appropriate handling and disposal of confidential HRC information and documents, and maintaining secure, reliable, high-speed internet connectivity. Any failure to adhere to established expectations, deadlines, or objectives may result in the employee’s loss of annual remote work days.

EMPLOYMENT FILES, RECORDS, AND DATA

SCOPE

This policy applies to all current and former full-time, part-time, and temporary HRC employees, interns, and fellows, as well as contract workers and board members. The provisions of this policy pertain to HRC’s digital and paper files and records containing employment information and personal employee data.

PURPOSE

This policy outlines HRC’s guidelines and procedures for maintaining employment files, records, and data, and for handling employee requests to review or receive copies of their employment file contents.

POLICY

HRC maintains records of employees’ personal data, including home address, phone numbers, personal email address, emergency contacts, and other pertinent information. It is the responsibility of each employee to ensure that this information is current and accurate in HRC’s system at all times to support the proper administration of employment related activities.

The company also maintains employment files that include information related to job title, salary history, performance evaluations, benefit elections, and other business-related details.

All employment files, records, and data are the property of HRC and access is restricted to those whose job responsibilities require visibility. HRC is committed to protecting employee privacy and keeps all employee files confidential. Employee information will not be released to anyone inside or outside the organization except after receiving the employee’s authorization, or as required by federal, state, or local law. Any employee who shares the files, records, or data of another employee with any unauthorized party may be subject to disciplinary action, up to and including termination of employment.

If a document related to adverse job performance or disciplinary action is placed in an employee’s file, People Strategy will notify the employee in advance.

Any employee who wishes to review their files and records may email a request to People Strategy. Any current or former employee may request a copy of the information contained in their file. All requests will be handled in accordance with applicable law. Paper-based employee files and/or their contents may not be removed from HRC’s premises.

TIME OFF

HOLIDAYS

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows insofar as it establishes the company’s schedule of holidays during which offices are closed. Work expectations and pay provisions are based on a role’s employment category and job responsibilities.

PURPOSE

The purpose of this policy is to establish the company’s schedule of annual holidays and to outline holiday work and pay expectations.

POLICY

All HRC office locations are closed in observance of the following holidays each year:

New Year’s Day Independence Day

Martin Luther King Jr. Day Labor Day

Inauguration Day (every four years) Veteran’s Day

Washington’s Birthday Thanksgiving Day

Memorial Day Day after Thanksgiving

Juneteenth Christmas Day

With the exception of Retail Store employees, these holidays are paid days off for all regular full-time HRC employees, and are unpaid days off for part-time and temporary employees and interns. Retail Stores observe Thanksgiving Day and Christmas Day as paid days off for regular full-time employees, and unpaid days off for part-time and temporary employees and interns.

Any company-observed holiday occuring on a Saturday or Sunday will be observed on the nearest weekday. Employees should consult the HRC intranet for specific holiday dates.

When a holiday occurs within an employee’s vacation period, that day will be paid as a holiday rather than a vacation day.

HRC recognizes that employees may wish to celebrate holidays or honor religious or cultural observances that differ from the company’s annual schedule of holidays. Regular full-time and regular parttime employees may use Personal Days for this purpose, according to the company’s Personal Days policy, below.

VACATION DAYS

SCOPE

This policy applies to all regular full-time and regular part-time HRC employees.

PURPOSE

The purpose of this policy is to establish the company’s practices concerning the accrual and use of vacation time.

POLICY

All regular full-time and regular part-time employees are eligible for vacation benefits. Vacation accrual is based on length of service, and is prorated for regular part-time employees, in accordance with the number of hours worked per week.

Beginning the first day of employment, regular full-time employees accrue vacation time, as follows:

Length of Service

Date of hire through end of 2nd year

3+ years of employment

Vacation Accrual

15 days per year | 4.33 hours per pay period

20 days per year | 5.77 hours per pay period

Note that any change in pay frequency will affect accrual rates, however the number of days accrued per year will remain unchanged.

Any former HRC employee who is rehired will accrue vacation time at the same rate of accrual as at the time of their departure, according to previous years of service.

Scheduling and Using Vacation Time

Employees are expected to plan their vacation time around peak periods and/or key events so as not to conflict with business priorities. Exempt employees may use vacation time in increments of 7.5 hours (one work day). Non-exempt employees may use vacation time in one-hour increments.

To schedule vacation time off, employees must submit a written request to their manager no fewer than 10 working days in advance, and also enter the request in the timekeeping system. HRC will notify the employee within five working days of the approval or denial of their request. While every attempt will be made to approve an employee’s request for vacation time, HRC will consider the needs of the business in evaluating all requests.

Any company recognized holiday that falls during scheduled vacation should be recorded as a paid holiday and will not be deducted from the employee’s accrued vacation time.

Vacation During Introductory Period

Vacation time begins to accrue on a new employee’s first day with HRC, however vacation time may not be taken during the 90-day Introductory Period, unless agreed upon in writing at the time of hire, or otherwise approved by HRC in writing, to accommodate extenuating circumstances.

Vacation Carryover

To maintain a healthy work/life balance, employees are encouraged to use their vacation time each year. HRC recognizes this may not always be possible and, therefore, employees may carry over up to 100 hours of accrued unused vacation time from one calendar year to the next.

In the event an employee takes a sabbatical, they may carry over up to 150 hours of vacation time from that year to the next calendar year.

Unless otherwise required by law, employees may accrue a maximum of 225 hours (30 days) of vacation time. Note that employees in the state of California are subject to California laws regarding vacation accrual, capping, and carryover.

Vacation Advance

With manager approval, employees may use up to five vacation days (37.5 hours) in advance of accrual.

To maintain a healthy work/life balance, employees are encouraged to use their vacation time each year.

Vacation Time During Early Dismissal - Hourly Employees

From time to time, HRC may, at its discretion, dismiss employees early prior to certain holidays. Any hourly employee who is using vacation time on the day of the early dismissal must record the full number of vacation hours approved; 7.5 for a full day. Hourly employees who are working on the day of the early dismissal will record their hours worked and will assign the remaining hours in the work day to “office closure.”

Vacation Upon Resignation

When an employee provides HRC with fewer than four weeks’ notice of resignation, they are no longer eligible to use vacation time during the notice period. It is expected that this time will be dedicated to preparing for the transfer of job responsibilities.

When an employee provides HRC with at least four weeks’ notice, managers have flexibility to approve the use of vacation time, up to the last two weeks of employment, so long as an appropriate transition plan is in place. No vacation time may be used, under any circumstances, during an employee’s last two weeks with HRC.

Vacation Pay Upon Separation

Upon separation of employment, an employee who has completed at least 90 days of service will be paid for all accrued unused vacation time to the extent allowed by applicable law.

PERSONAL DAYS

SCOPE

This policy applies to all regular full-time and regular part-time HRC employees.

PURPOSE

The purpose of this policy is to establish the company’s practices concerning eligibility and use of personal days.

POLICY

With the exception of Retail Store Managers and Assistant Managers, all regular, full-time HRC employees are eligible for four personal days per calendar year, to be used for any purpose other than to extend vacation time. With the limited number of paid holidays available to Retail Store Managers and Assistant Managers, employees who hold these roles are eligible for eight personal days per calendar year. Personal days are prorated for regular part-time employees, in accordance with the number of hours worked per week. Part-time and temporary employees, interns, and fellows are not eligible for personal days.

Personal days may be used during a new employee’s introductory period with prior approval from their manager. Each subsequent year, personal days are granted on January 1 and may be used immediately thereafter and before December 31. Personal days do not carry over from one calendar year to the next, unless required by law.

Exempt employees must use personal days in one-day increments (7.5 hours). Non-exempt employees may use personal days in half-hour increments.

Scheduling and Using Personal Days

Employees must request in writing the use of personal days from their manager at least 24 hours in advance. Generally, personal days will be approved so long as business needs allow, although personal days may not be used in conjunction with vacation time.

Personal Days During Early Dismissal - Hourly Employees

From time to time, HRC may, at its discretion, dismiss employees early prior to certain holidays. Any employee who is using personal time on the day of the early dismissal must record the full number of personal hours approved; 7.5 for a full day. Non-exempt employees who are working on the day of the early dismissal will record their hours worked and will assign the remaining hours in the work day to “office closure.”

Personal Days Upon Resignation

When an employee provides HRC with fewer than four weeks’ notice of resignation, they are no longer eligible to use personal days during the notice period. It is expected that this time will be dedicated to preparing for the transfer of job responsibilities.

When an employee provides HRC with at least four weeks’ notice, managers have flexibility to approve the use of personal days, up to the last two weeks of employment, so long as an appropriate transition plan is in place. No personal days may be used, under any circumstances, during an employee’s last two weeks with HRC.

Unused personal days are not paid upon separation of employment, unless required by applicable law.

SICK LEAVE AND SICK LEAVE DONATION

SCOPE

This policy applies to all regular full-time HRC employees. Certain policy provisions may apply to parttime and temporary employees, as required by law.

PURPOSE

The purpose of this policy is to outline the company’s sick leave eligibility, allotment, and related practices and expectations, as well as the guidelines concerning sick leave donation.

POLICY

All regular full-time HRC employees are eligible for paid sick leave. Sick leave is accrued at a rate of one day (7.5 hours) per month, or 12 days per year for regular, full-time employees. Sick leave begins accruing on the first day of employment, with a maximum accrual of 30 days or 225 hours.

Employees may use paid sick time for the following purposes:

• To care, treat, or seek a diagnosis for the employee’s physical or mental illness, physical injury, or health condition.

• To care for the employee’s family member in seeking care, treatment, or a diagnosis for a physical or mental illness, physical injury, or health condition.

• Preventive physical or mental healthcare or elective surgery, including organ donation, for the employee or their family member.

• Closure of the HRC workplace due to a public health emergency.

• To care for the employee’s child whose school or childcare provider is closed due to a public health emergency.

• Absence for any of the following reasons when the employee or their family member has been the victim of domestic violence, a sexual offense, stalking, or human trafficking:

• To obtain services from a domestic violence shelter, rape crisis center, or other shelter or service program.

• To participate in safety planning, temporarily or permanently relocate, or take other action to increase the safety of the employee or their family.

• To meet with an attorney or social services provider to obtain advice or prepare for a criminal or civil proceeding.

• To file a complaint or domestic incident report with law enforcement.

• To enroll children in a new school.

• To take other action necessary to ensure, maintain, improve, or restore the physical, psychological, or economic health or safety of the employee or their family, or to protect those who associate or work with the employee.

• Employees must notify their manager of their use of sick leave prior to the start of their workday, or as soon as possible. If the need for sick leave is foreseeable, the employee should provide as much advanced notice as possible.

Documentation from a relevant professional may be required after 5 consecutive days of sick leave. In accordance with applicable law, such documentation should not contain any description of the employee’s or their family member’s condition or situation.

If an employee is found to be using sick time for purposes other than those described in this policy or permitted by law, they may be subject to disciplinary action, up to and including termination of employment.

Some states, including the District of Columbia, offer paid family leave benefits. Please familiarize yourself with any available benefits in your work location and consult HRC’s People Strategy department if you wish to apply for these benefits.

Accrued, unused sick leave is not paid out upon separation of employment.

Staying Home When Ill

It is critical that employees do not report to work while they are ill and/or experiencing the following symptoms: fever, cough, respiratory distress, body aches, headache, chills, vomiting, diarrhea, and fatigue. Employees who report to work ill will be sent home in accordance with these health guidelines. Please contact your direct supervisor immediately upon feeling ill.

Sick Leave Advance

Sick leave advance enables employees to use sick leave prior to accrual. With the approval of their manager, employees may use up to five days, or 37.5 hours, of sick leave prior to accrual within a six month period.

Sick Leave Donation

PURPOSE: Sick leave donation is available to employees who have exhausted their sick time allotment in the course of managing their own serious illness or injury, or caring for a seriously ill or injured family or household member.

ELIGIBILITY: All regular full-time employees who have completed 90 days of employment are eligible to receive confidential donations under this program. Employees are not eligible for sick leave donation if they qualify but have not applied for short-term disability benefits or a state-funded paid family leave program. Employees may carry 75 hours of accrued vacation time while using sick leave donation, but must use any accrued vacation in excess of 75 hours prior to requesting sick leave donation.

HOW THE PROGRAM WORKS: Employees may request sick leave donations once they have exhausted all of their individual sick leave, personal days, and any comp time. They may carry up to 75 hours of accrued vacation time when requesting and using sick leave donations. To request donations, employees must submit a completed Sick Leave Request form to People Strategy, available on the HRC intranet.

Upon receiving and approving a sick leave donation request, People Strategy will notify all full-time employees of the confidential need, including the number of hours requested.

Employees may donate sick leave when they have accrued more than 75 hours, and may only donate their accrued hours in excess of 75. Those who wish to donate must complete a Sick Leave Donation form, available on the HRC intranet. Any employee who requests or donates sick leave will remain anonymous, other than to People Strategy and Payroll.

People Strategy will notify the requesting employee of the donated hours and will inform those who have donated whether their time will be needed, based on the number of hours requested. Donated hours that are not needed will be returned to the donating employee; HRC does not maintain a general sick leave donation pool.

To protect confidentiality and eliminate any potential pressure to donate leave, employees may not request sick leave donations directly from other HRC employees.

Employees may only receive donated leave if they are on continuous or non-continuous Family Medical Leave (FMLA), District of Columbia Family Medical Leave, or another similar state-specific program.

PARENTAL LEAVE FOR SCHOOL ACTIVITIES

SCOPE

This policy applies to all regular full-time and regular part-time HRC employees.

PURPOSE

The purpose of this policy is to ensure that employees are able to take time off from work, as needed, to participate in the educational needs and interests of their child(ren).

POLICY

In accordance with applicable law, an employee who is the parent, guardian, or caregiver of a child in a licensed daycare facility or primary school, kindergarten through grade 12, may take up to 24 hours of unpaid time off per calendar year for any purpose or activity that is sponsored, approved, or supervised by their child(ren)’s school or daycare facility.

Employees should plan any school-related time away from work with their manager as far in advance as possible, and may choose to use any available vacation or personal days if they wish to receive pay for this time off. Employees may also flex their time, working additional hours another day to compensate for this time off, in accordance with manager approval.

HRC may request that the employee provide documentation from the school verifying the date and time of the activity.

FAMILY AND MEDICAL LEAVE (FMLA)

SCOPE

This policy applies to all employees who have been employed by HRC for at least one year without a break in service and have worked at least 1,000 hours during the 12-month period immediately preceding the request for FMLA.

PURPOSE

The purpose of this policy is to provide employees with an understanding of the guidelines and requirements related to family and medical leaves of absence, and to support compliance with the DC FMLA program.

POLICY

HRC supports the District of Columbia Family and Medical Leave Act of 1990 (“DC FMLA”) and incorporates DC FMLA as its family and medical leave policy. Some of the important terms and conditions of DC FMLA are summarized below. In all cases, all terms and conditions of DC FMLA shall govern. Employees interested in taking a family or medical leave of absence should familiarize themselves with the entirety of the DC Family and Medical Leave program.

Eligible Employees

To be eligible for family and medical leave, you must be employed by HRC for at least one year without a break in service and have worked at least 1,000 hours during the 12-month period immediately preceding the request for family or medical leave.

Leave Entitlement

Two distinct types of leave are available under this policy: (i) family leave, for certain events within the employee’s family and (ii) medical leave, for the employee’s own serious health condition. The total leave entitlement available under this FMLA policy is 16 workweeks.

Family Leave

An eligible employee is entitled to up to 16 paid workweeks of family leave during any 24-month period for:

1. The birth of a child.

2. The placement of a child with the employee for adoption or foster care.

3. The placement of a child with the employee, for whom the employee permanently assumes and discharges parental responsibilities.

4. The care of a family member with a serious health condition.

The entitlement to family leave under (1) through (3) above expires 12 months after the birth of the child or placement of the child with the employee.

For the purpose of family leave, the definition of “family member” is someone to whom the employee is related by blood, legal custody, marriage, or registered domestic partnership or civil union; a child who lives with an employee and for whom the employee permanently assumes and discharges parental responsibility; or a person with whom the employee shares or has shared, within the previous year, a mutual residence and with whom the employee maintains a committed relationship.

A “committed relationship” is demonstrated by such factors as, but is not limited to, mutual economic interdependence including joint bank accounts, joint tenancy, shared lease, and joint/mutual financial obligations such as loans; domestic interdependence including close association, public presentment of the relationship, and/or exclusiveness of the intent of the relationship as evidenced by a will or life insurance beneficiary designation.

Medical Leave

An eligible employee is entitled to up to 16 paid workweeks during any 24-month period for instances when the employee becomes unable to perform the functions of their position. The medical leave expires when the employee again becomes able to perform the functions of the position.

For purposes of both family leave and medical leave, the definition of “serious health condition” is the same: A physical or mental illness, injury, or impairment that involves inpatient care in a hospital, hospice, or residential health care facility, or continuing treatment or supervision at home by a health care provider or other competent individual.

Intermittent Leave

Medical leave and family leave to care for a family member with a serious health condition may be taken intermittently when medically necessary. However, the employee must provide HRC with reasonable prior notice and make an effort to schedule the treatment or supervision in a manner that does not unduly disrupt the operations of HRC.

HRC supports the District of Columbia Family and Medical Leave Act of 1990 (“DC FMLA”) and incorporates DC FMLA as its family and medical leave policy.

Calculation of Leave Available

HRC calculates the amount of leave available to an employee on a “rolling” basis, measured backwards from the first date the employee takes any leave.

Notice of Intent to Take Leave

In general, where the need for family or medical leave is foreseeable, the employee is required to provide HRC with 30 days’ notice of the intent to take leave. Where the leave is not foreseeable, the employee is required to provide notice upon the discovery of the need for leave, or as soon as possible thereafter.

Relationship to Paid Leave

An employee taking family leave may elect to use paid vacation, personal, compensatory, or parental leave provided by HRC as part of the leave period, which HRC will count against the 16 workweeks of family leave available. The employee may also apply for short term disability and state leave. Any paid sick leave provided by HRC that the employee elects to use for medical leave will count against the 16 workweeks of medical leave available. If the employee depletes all of their leave on approved FMLA, HRC will provide the employee with sick leave donation. In total, the employee will have 16 weeks of paid leave on approved FMLA.

Certification of a Serious Health Condition

When an employee requests medical leave due to their own serious health condition or requests family leave due to the serious health condition of a family member, HRC may require the employee to provide certification from a health care provider. The certification must include:

1. The date the serious health condition commenced.

2. The probable duration of the condition.

3. The facts that would entitle the employee to a leave.

4. For medical leave, the certification must also include a statement that the employee is unable to perform the functions of their position.

5. For family leave, the certification must also include an estimate of the amount of time the employee will be needed to care for their family member.

HRC maintains the right to require certification at the time leave is requested and anytime during the leave.

Job Reinstatement

Under most circumstances, upon return from family or medical leave, the employee will be reinstated to the same position they held at the time leave commenced, or to a position having equivalent pay, benefits, seniority, and conditions of employment. While the employee will not lose any benefits or seniority accrued prior to taking the leave, the employee will not accrue benefits or seniority during the leave period.

In general, the employee is not entitled to any right, employment benefit, or position of employment other than that to which they would have been entitled had they not taken FMLA leave.

Benefits During Leave Period

HRC will maintain coverage under the group health, life, and long-term disability insurance plans as well as the 401k plan, for an employee on family or medical leave, at the same level and under the same conditions that coverage would have been provided had the employee not taken leave. Employees will be required to reimburse HRC for their portion of the premiums while on leave.

PAID PARENTAL LEAVE

SCOPE

This policy applies to all regular full-time HRC employees who wish to take paid parental leave for the birth, adoption, or foster care of their child.

PURPOSE

This policy is intended to support parents by providing paid time off to bond with and care for a new child. This policy outlines the guidelines and expectations associated with HRC’s paid parental leave.

POLICY

Regular full-time employees may request paid parental leave of up to four weeks during any 12-month period to bond with or care for the employee’s new child or the new child of the employee’s spouse or domestic partner. Paid parental leave is available to new parents equally, regardless of whether the child arrives by birth, adoption, or for foster care. Paid parental leave must be taken within the first 12 months of the child’s arrival.

Eligibility

Regular full-time employees are eligible for paid parental leave after six months of continuous employment.

Parental Leave Pay

Parental leave will be paid at the employee’s regular base rate of pay on the date the leave commences. Parental leave pay will terminate on the earliest of either four weeks after the leave commences; 12 months after the date of the child’s birth or placement for adoption or foster care; or the date of the employee’s separation from HRC.

Paid parental leave is paid in conjunction with HRC’s regular payroll cycle and is subject to the employee’s usual payroll deductions.

While on parental leave, HRC will maintain the employee’s coverage under all health and life insurance benefits for the entire leave period.

Parental Leave and FMLA

The Family and Medical Leave Act (FMLA) entitles eligible employees to 16 weeks of leave in a 24-month period (see the company’s FMLA policy for details). The use of paid parental leave runs concurrently with FMLA and will count toward the 16-week entitlement.

In addition to the four weeks of paid parental leave, employees eligible for FMLA may use vacation time, sick leave, personal days, and any state paid leave benefits, such as the District of Columbia Paid Family Leave, to take up to 16 total weeks of paid leave for childbirth, adoption, or foster care place-

ment. Employees who require additional sick leave to reach 16 total weeks of paid leave may request a Sick Leave Donation through HRC’s People Strategy department. (See the Sick Leave and Sick Leave Donation policy for details.) Short term disability insurance may provide additional income substitution while on parental leave. Please reach out to People Strategy with questions relating to this matter.

Requesting Paid Parental Leave

To the extent possible, employees should provide at least 30 days advanced notice of their need to take paid parental leave. In preparation for the leave, employees should agree with their manager on a plan for the continuation of their job responsibilities in their absence.

SABBATICAL LEAVE

SCOPE

This policy applies to all regular full-time HRC employees who have completed seven consecutive regular full-time years of employment since their date of hire or their most recent sabbatical leave.

PURPOSE

This policy is intended to provide employees with an understanding of HRC’s sabbatical leave eligibility, provisions, and requirements.

POLICY

HRC is pleased to offer paid sabbatical leave of up to four weeks to employees who have demonstrated long-term dedication to the organization. Sabbatical leave may be used for any purpose that supports the employee’s personal, professional, or academic development.

During sabbatical leave employees will be paid at their regular base rate of pay, according to the company’s normal payroll cycle, and will maintain the benefits in which they are enrolled at the time of the sabbatical.

An employee is eligible for sabbatical leave when they:

• Complete seven consecutive years of regular full-time employment. Employees who take an unpaid leave of absence, other than FMLA, will become eligible for sabbatical leave after seven years of employment, plus the time spent on unpaid leave.

• Hold a role that is conducive to extended time off. Employees whose roles are not eligible for hybrid or remote work will be reviewed on a case by case basis to determine eligibility for sabbatical leave.

• Submit a sabbatical leave plan, created in partnership with their manager, outlining how the employee’s job responsibilities will be performed during their absence to ensure business continuity.

• Are in good standing, with no active Performance Improvement Plan (PIP) or written warning within the previous six months.

All requests for sabbatical leave must be submitted to People Strategy at least four months in advance of the anticipated leave. People Strategy will partner with the employee’s department director or department head to review the request.

Unless otherwise approved, sabbatical leave must be taken within two years of the date the employee becomes eligible.

Sabbatical leave must be taken consecutively, up to a maximum of four weeks. Employees who choose to take fewer than four weeks will forfeit the remaining time off. Unless otherwise agreed upon at the time of the request, sabbatical leave may not be combined with any other form of leave or time off, such as vacation days, personal days, paid parental leave, etc.

Sabbatical leave is not intended to aid in job transition; employees who have submitted notice of resignation or are actively pursuing other job opportunities are not eligible for sabbatical leave.

Unused sabbatical leave is not paid out upon separation of employment. During the year in which an employee takes sabbatical leave, they may carry over up to 150 hours of vacation leave to the next calendar year.

To apply for sabbatical leave, employees must submit a completed Sabbatical Leave Request, available on the HRC intranet.

BEREAVEMENT LEAVE

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to outline HRC’s guidelines and practices related to bereavement leave, providing employees with time off to grieve the loss of a loved one.

POLICY

In the unfortunate event of a death in an employee’s immediate family, they may take a paid leave of absence of up to one workweek (37.5 hours) for regular full-time employees, or a pro-rated number of hours, according to the employee’s regular work schedule. Bereavement leave may be taken consecutively or intermittently.

For the purposes of this policy, “immediate family” is defined as an employee’s spouse, domestic partner, sibling, child, pregnancy loss, parent (including step and foster), parent-in-law, child of spouse or domestic partner, parent of domestic partner, legal guardian, legal ward, grandparent, grandchild, someone to whom the employee is a caregiver, a person who stood in loco parentis when the employee was a child, or any other relation as defined by applicable law.

HRC recognizes the ever-evolving nature of family and respects an employee’s need to observe the death of close relationships beyond those defined above. Employees may use one day (7.5 hours) of bereavement leave to observe the death of a distant relative, former coworker, close friend, or other person with whom the employee has maintained a family-like relationship.

HRC is aware that grieving is a very personal process. If an employee’s individual needs or circumstances extend beyond the provisions of this policy, they should speak with their manager and/or People Strategy.

An employee’s annual bereavement leave may not exceed 37.5 hours, except in the case of extenuating circumstances. HRC expects that employees will use bereavement leave only for the purpose of observing the death of a family member or close personal relationship and may, at its discretion, request documentation of the death and/or the relationship.

For those struggling with grief, HRC provides a confidential Employee Assistance Program. More information is available on the company’s intranet.

MILITARY LEAVE

SCOPE

This policy applies to all regular full-time and regular part-time HRC employees.

PURPOSE

The purpose of this policy is to outline HRC’s guidelines and practices related to military leave.

POLICY

HRC provides leaves of absence to employees who are called into active military service or enlisted in reserve duty, in accordance with applicable state and federal laws. HRC complies with all requirements under the Uniformed Services Employment and Reemployment Rights Act (“USERRA”) and similar applicable state law.

Unless otherwise required by law, military leave is unpaid. Employees may elect to use any accrued paid time off during any portion of an unpaid military leave of absence.

For more information, employees should contact People Strategy.

HRC recognizes the ever-evolving nature of family and respects an employee’s need to observe the death of close relationships beyond those defined above.

JURY/WITNESS DUTY LEAVE

SCOPE

This policy applies to all regular full-time HRC employees.

PURPOSE

The purpose of this policy is to outline HRC’s guidelines and practices related to jury duty and witness leave.

POLICY

HRC considers jury and witness duties to be important civic responsibilities and supports employees who are called to serve. Employees who are selected for jury duty or called to serve as a witness will continue to receive their regular base pay during court service.

When performing jury or witness duty, employees are expected to report to work whenever their presence is not required in court. If an employee’s jury or witness duty begins at 11:00 a.m. or later, they are expected to work for HRC, as usual, until their attendance is required, unless the court is more than 10 miles from their work location. Similarly, if the employee’s court service concludes at or before 4:00 p.m., they are expected to work for HRC afterward for the remainder of their normal work day, unless the court is more than 10 miles from their work location.

Employees must provide a copy of their official notification of juror selection or witness subpoena to their manager and People Strategy as far in advance of their court service as possible. Following service, a statement from the court showing dates served and compensation received must be submitted to Payroll and People Strategy.

In the event of a critical business need, HRC may ask employees to request a postponement of their jury or witness duty.

HRC complies with all applicable laws regarding jury or witness duty.

TIME OFF TO VOTE

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to ensure that all employees have the opportunity to exercise their right to vote in local, state, and federal elections.

POLICY

HRC supports the right of all employees to participate in local, state, and federal elections and will provide reasonable time off to do so, as necessary and as provided by law. Generally, employees should plan to vote prior to or after their regular scheduled working hours. Employees who do not have sufficient time to vote outside of their working hours should make voting arrangements with their manager as far in advance as possible. Non-exempt employees who require time off to vote during the workday will be paid, in accordance with applicable law.

EDUCATION LEAVE

SCOPE

This policy applies to all regular full-time HRC employees who have completed 90 days of employment and are in good standing.

PURPOSE

The purpose of this policy is to outline HRC’s guidelines and expectations related to education leave which enables employees, under certain circumstances, to take time off from work to pursue continued education.

POLICY

HRC is committed to the continuous growth and development of our employees. In accordance with the organization’s Professional Development and Licenses policy, and with prior approval from their manager and department director, an employee may take up to three paid hours off per week to attend classes as part of a professional development plan that is directly related to their work with HRC. Additional unpaid hours may be granted, as necessary, to support the employee’s program attendance.

Similarly, employees may be eligible for paid time off to attend a one-time workshop or training program directly related to their HRC job responsibilities. Such requests will be evaluated on a case-by-case basis.

Employees who wish to request education leave should speak with their manager and People Strategy prior to enrolling.

COMMUNICATION

SOCIAL MEDIA

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to support HRC employees’ use of social media in both professional and personal contexts, seeking to balance individual freedom of expression with the responsibility of all employees to protect and uphold HRC’s mission and reputation.

DEFINITION

The term “social media,” as used in this policy, encompasses all activity conducted in online platforms and applications, including, but not limited to, communicating, creating, sharing, posting, and engaging with information or content in the form of text, “likes,” emojis, gifs, memes, pictures, videos, audio recordings, etc. These platforms include, but are not limited to, Instagram, X, TikTok, Snapchat, Face-

book, Reddit, YouTube, LinkedIn, blogs, personal or public websites, and other similar sites or platforms, whether or not associated with HRC.

POLICY

Everyone at HRC is passionate about our mission and the work we do every day. Employees are encouraged to share HRC’s mission and message with the world and, at the same time, must be mindful of important social media guidelines that are intended to prevent personal and professional misunderstandings, risks to HRC’s mission, and reputational damage.

It is important to note that the same expectations and requirements outlined in HRC’s policies and procedures extend to employees’ activities online. This includes, but is not limited to, our policies concerning unlawful harassment, confidentiality, internet usage, and security.

Ultimately, you are solely responsible for your own online activity. Keep in mind that any online activity or conduct that reflects negatively on HRC, your role, or fellow employees, or adversely affects board members, donors, customers, suppliers, or people who work on behalf of HRC or HRC’s business interests may result in disciplinary action, up to and including termination of employment, as permitted by law.

Please be advised that employees should have no expectation of privacy with respect to information or communications that are posted online using HRC’s computers or networks. HRC maintains the right to monitor all activity conducted on company-owned equipment and systems.

Categories of Social Media Use

At HRC, employees’ social media use is categorized as follows:

1. Spokesperson for HRC. Use of social media sites to disseminate HRC’s official position on an issue.

2. Knowledge Resource. Use of social media in an official HRC capacity to share knowledge of HRC’s mission and work.

3. Relationship Builder. Interactions on social media that are not directly tied to an employee’s work at HRC, but that help build relationships that may later bring people into HRC’s sphere of influence.

4. HRC Promoter. Promoting official HRC content and messages to an employee’s personal contacts.

5. Personal use. Unrelated to HRC business.

The use of social media outlined in categories 1 and 2 is regulated through an internal approval process involving the Communications & Branding and Membership departments and is typically only approved when specified as part of an employee’s job responsibilities. Employees MUST receive prior authorization from these departments to use social media in these capacities.

In Categories 3-5, although not acting as an official representative of HRC, the employee’s connection to the organization is generally known. As such, it is important to consider how this type of social media

activity may affect HRC’s mission, work, and reputation prior to posting or sharing any information, message, opinion, etc. online. When using social media as described in categories 3-5, please follow the guidelines below. Note that no employee is required or expected to post HRC-related content to any personal social media account.

Guidelines

Always remember that your social media activity is a reflection of you and, sometimes also of HRC. The following guidelines are designed to support employees in maximizing the benefits of social media, while also minimizing any potential risks. These guidelines are not intended to contradict, limit, or replace applicable policies, legal requirements, or contractual obligations.

Remember Confidentiality

In accordance with HRC’s Confidentiality policy, only information that is approved/appropriate for public view may be shared through social media. Sharing HRC-related information that is not intended for the public, or is garnered through private conversations, work-related meetings, or any situation where privacy is inferred or intended may be considered a violation of HRC policy. Please review the Confidentiality policy and/or speak with your manager before posting anything online you are not certain is acceptable. Confidential information that should not be posted or shared includes, but is not limited to, addresses, phone numbers, travel schedules, security procedures, donor information, internal communications, or anything else that may compromise the safety or privacy of others or HRC’s work or mission.

Be Enthusiastic

HRC publishes a wealth of information on LGBTQ+ rights, and all employees are encouraged to share HRC’s work, mission, achievements, and activities by reposting press releases, action alerts, blog posts, etc. This is a powerful way to disseminate information to audiences that might not otherwise receive it.

Be Judicious

Use your best judgment when deciding what to post or share. Information on social media can spread quickly, so be sure that whatever you post will result in a positive contribution to the discussion. For purely personal content, we recommend that you utilize platforms’ privacy settings to ensure that your personal activities are not linked to HRC. Bear in mind that even with privacy settings there remains the potential for information about you to be more widely disseminated so we ask that you are judicious with your postings.

Write What You Know

Be sure that what you share is factually accurate. Misinformation may confuse readers and lead to unwarranted criticism of the organization or unintended consequences. If you make a mistake, be open about it and correct it quickly.

Identify Yourself

Unless you are a designated HRC spokesperson, please only use personal information, including your email address and not an HRC email address, as your primary means of identification on social media. Never post HRC information anonymously. When you discuss HRC-related matters on the internet, you must identify yourself by name and, when relevant, your role at HRC. If you are not acting as an official spokesperson for HRC, you must make clear that you are speaking for yourself and not for the organization by explicitly stating, “The views expressed in this post are my own, and do not necessarily

represent the position or opinion of HRC.” If an online conversation related to HRC becomes argumentative, please disengage and encourage the person(s) to contact HRC Communications staff and provide them with the correct (non-personal) HRC contact information.

Consider Perception

When using social media, remember that the lines between professional and personal communication are easily blurred. Consider what your audience may infer from your post, and be sure that the message will be received as you intend. Prior to posting, helpful questions to ask yourself include: Would this encourage/discourage a potential member from joining HRC? Would I feel uncomfortable if my manager, People Strategy, or a board member saw my post? Use your best judgment and exercise discretion when connecting with people on social media sites.

Consider Formality

Conversations on social media move quickly and they are, by nature, less formal than other forms of communication. Remember that casual does not mean rude or profane and appropriate language should be used in even the most informal exchanges. Please ensure that your social media content is consistent with how you want to present yourself to colleagues and the public.

Follow the Law

It is critical that social media activity does not violate copyright, trade secret, fair use, privacy, libel and defamation, federal securities, federal disclosure, or any other applicable laws. Never post anything that may be interpreted as discriminatory, harassing, threatening, obscene or pornographic, proprietary, or unlawful.

Friend Up, Not Down

In general, it is a best practice to avoid “friending” those who report to you on personal social media accounts. If a direct report friends you, however, it is appropriate to accept their request, if you wish, although no one should ever feel obliged to accept a friend request. When accepting friend requests from direct reports, be sure to apply your acceptances equally to avoid any perception of favoritism.

Remember Your Job is Your Priority During the Workday

We all agree that social media is a powerful and important tool. Using social media for non-HRC purposes during the workday is not, however, an appropriate use of your time. Be sure that your social media activity does not interfere with your job responsibilities and HRC commitments.

Pass on Press Inquiries

Social media postings related to HRC or our work may occasionally capture the attention of the news media. If you are ever approached by any outside party to make a comment regarding HRC or any issue related to our mission, it is critical that you avoid commenting and pass the inquiry to HRC’s Communications & Branding team immediately. This department is specifically skilled in handling these types of inquiries.

ADDRESSING HATE SPEECH

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows, and pertains to all forms of hate speech, internally and externally. It is important to note that this policy is separate and in addition to HRC’s policies on Harassment-Free Workplace, Standards of Conduct, and other related expectations.

PURPOSE

This policy is intended to establish guidelines for addressing hate speech as a means of strengthening inclusiveness and supporting HRC’s mission to realize a world that achieves fundamental fairness and equality for all.

POLICY

HRC is a civil rights organization focused on combating discrimination. In the course of driving HRC’s mission forward, employees may encounter hate speech or discriminatory language. We believe there may be value in naming hatred that is experienced or witnessed, and in responding to or condemning content that illustrates hatred, particularly when directed toward marginalized communities.

HRC strictly prohibits the use of hate speech or discriminatory language in our workplace or at work related events, whether or not intended as hurtful. This includes verbal and written communication, graphic images, or gestures that denigrate or show hostility or aversion toward an individual or group on the basis of any legally protected category. Hate speech and discriminatory language may only be discussed in the workplace when relevant to our work, and then only with great sensitivity and sound judgment.

Personal Communication

Whenever it may be necessary to use language that is overtly hateful or discriminatory, or may be perceived as such, in discussing personal work related experiences, employees should be mindful of the potentially harmful effects on others, including fellow employees. Generally, employees are expected to convey their experiences with alternative words that describe hate speech rather than using slurs or derogatory epithets directly. Additionally, employees must respect and abide by any request not to repeat hateful or discriminatory language in our workplace .

Internal Communications

When circulating items that contain hate speech, employees should include a warning on any potentially harmful content. For guidance on appropriate warning language, please contact the Communications team.

External Communications

Hateful or harmful speech related to external communications must be handled or addressed with care and sound judgment so as not to compound any harmful impact. Employees should consider, where necessary or appropriate, taking steps to “bleep” or obscure hateful speech, or provide a warning to the audience.

If an employee believes the depiction of hate speech or discriminatory language is essential to an external communication and consistent with our mission, they must consult with senior leaders in Communications and Diversity before publishing it.

HRC employees are required to report conduct that violates this policy, regardless of whether it comes from inside or outside of HRC. Please refer to the Safety and Ethics Reporting policy for information on filing an incident report, or report the behavior to the People Strategy department.

INTERNET, EMAIL, AND

PORTABLE ELECTRONIC DEVICE USAGE

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns and fellows, and extends to contractors, consultants, and other workers at HRC, including all individuals affiliated with third parties. This policy applies to all equipment that is owned or leased by HRC. It also applies to employee-owned equipment, to the extent it is used for HRC business purposes.

PURPOSE

The purpose of this policy is to outline the acceptable use of software, applications, computer equipment, electronic devices, mobile devices, and telephony devices at HRC or in connection with HRC business. These guidelines and restrictions are in place to protect employees and HRC. Inappropriate use exposes HRC to risks, including virus attacks, compromise of network systems and services, and potential legal liability.

DEFINITIONS

HRC Systems

All HRC-owned or licensed software and hardware systems, including, but not limited to, telephone systems, computer equipment, operating systems, storage media, email programs, web browsers, applications, software as a service, and file transfer protocols.

Personal Systems

All employee-owned, leased, or subscribed software and hardware systems, including, but not limited to, mobile devices (e.g., mobile phones and tablets), computer systems, operating systems, storage media, email programs, web browsers, applications, software as a service, and file transfer protocols.

POLICY

General Use and Ownership

Employees must be aware that any data or communications created or held on HRC systems is the property of HRC. Data or communications that are work-related and are created or held on personal systems are also the property of HRC.

The organization’s leadership may review at any time, with or without notice, the data or communications flowing through HRC networks or devices and, as permitted by law, the data or communications that are related to HRC work and are held on personal systems. HRC strongly discourages employees from saving any HRC-related information on personal systems.

Employees may use HRC systems for reasonable personal use and are responsible for exercising good judgment when doing so. Under no circumstances may employees engage in any communication using HRC systems or HRC’s name, or in connection with HRC business that could actually or potentially undermine the work or compromise the mission of HRC. In addition to personal use, this requirement extends to formal business communications, as well as business-related informal communications, such as text messages and/or activities in any messaging application.

HRC’s Information Technology department requires that all corporate or member credit card information (account numbers, expiration dates, etc.) must be stored electronically on a secure network server. No employee may store any corporate or member credit card numbers (whether encrypted or not) on employees’ personal computers or any other electronic devices that are not HRC systems and/or are not specifically designated to store credit card numbers. Any employee with access to HRC or members’ credit card information must comply with current standards and procedures for protecting such data. If employees have questions about managing HRC’s corporate or member credit card information, they should contact the Information Technology department.

For security and network maintenance purposes, HRC-authorized individuals may monitor equipment, systems, and network traffic at any time. This includes email and internet usage. HRC may audit networks and systems on a periodic basis, as necessary, to ensure compliance with this policy.

Security of Confidential or Proprietary HRC Information

HRC employees must be aware that some information sent or received through electronic means is confidential. Examples of confidential information are set forth in HRC’s Confidentiality policy and include, but are not limited to, member or donor lists, financial data, employment records, strategy documents, research data, membership reports, and member or donor credit card and bank information. Employees must take the necessary steps to prevent unauthorized access to confidential information, including the use of approved encryption applications to transmit sensitive information.

Passwords and Account Security

Employees must maintain strong passwords and secure accounts; default passwords are not permissible. No employee may share accounts, account information, passwords, PINs, keys, access cards, or any other similar confidential information for any HRC or work-related digital/online account. Authorized users are responsible for maintaining the security of passwords and account information.

Employees must lock the screens of PCs, laptops, tablets, mobile devices, and workstations when leaving these devices unattended. In general, employees must use either the HRC-authorized Azure Virtual Desktop (“AVD”) or the web version of an HRC-approved application when working remotely from any personal system.

Communication Platforms

Employees must use only their own assigned HRC email address to transmit information or documents when conducting HRC business. These systems have embedded security measures and are the required systems for communicating any HRC business information.

Employees may not use non-secure or open wireless networks to conduct or discuss HRC business, including public or unknown wireless networks. When necessary, employees must use their own hotspot, and not the hotspots of others or publicly available WiFi, to obtain wireless service, and may not allow others to use their hotspot when conducting HRC business.

Information contained on portable computers is especially vulnerable and employees must protect their laptops in accordance with the IT department’s current security standards.

HRC strongly discourages its employees from using computers that are not part of the HRC system, including employees’ own personal computers, to access or discuss HRC business or confidential data.

If an employee must print a document from a non-HRC device, they must consider the sensitivity of the

material. If the information is confidential, steps must be taken to ensure the materials are not downloaded to the device or the printer being used, and the employee must take care to delete the information once printing is complete.

No employee may post from any HRC email address to any newsgroup or other listserv unless such posting is done in the course of performing their job responsibilities and they are serving as an authorized spokesperson for HRC.

Virus Protection

All computers and electronic devices that are connected to the HRC environment, whether owned by an employee or by HRC, must run up-to-date Windows Defender or current/comparable virus-scanning software. Employees may not bypass this required function when connected to the HRC environment.

Employees must use extreme caution when opening email attachments received from third parties as they may contain viruses, malware, e-mail bombs, or Trojan horse code. Employees must always check the sender’s address prior to opening any email to confirm it matches the identity of the purported sender. Never open emails or attachments from unknown senders. In such cases, or with any questions concerning the legitimacy or safety of an email or attachment, employees should contact the Information Technology department immediately.

Employees may not install unfamiliar or unapproved software on HRC computers or electronic devices. Employees must stay up to date on software patches and updates on all personal computers and electronic devices that are used in connection with HRC business. Employees must also keep current with updates to their web browser and any plug-ins (e.g., Adobe Flash or Java), as well as firewalls, virus protection systems, and operating systems on any computers or devices that use, store, or transmit HRC information.

HRC strictly prohibits the use of hate speech or discriminatory language in our workplace or at work related events, whether or not intended as hurtful.

Lost or Stolen Equipment

Employees are required to immediately report any lost or stolen electronic devices, including desktop computers, laptops, tablets, smartphones, or other portable devices that have been used in connection with HRC business. This information should be emailed to IT and the General Counsel immediately, labeling the email as “urgent.” Similarly, if you suspect that your personal device, an HRC device, or any confidential information has been compromised, whether accidentally or intentionally, email the IT department immediately, labeling the email as “urgent.”

Unacceptable Usage

All HRC policies, expectations, and operational requirements, whether or not contained in this Handbook, apply equally to the use of IT equipment and systems. Under no circumstances is an employee of HRC authorized to engage in any activity that is illegal under applicable local, state, federal, or international law while utilizing HRC-owned electronic devices. Unless required as part of an employee’s HRC job responsibilities, employees shall not use HRC internet or e-mail services to view, download, save, receive, or send material related to or including:

• Potentially offensive content of any kind, including pornographic material.

• Promoting or suggesting discrimination on the basis of race, gender, national origin, age, marital status, sexual orientation, gender identity, religion, disability, or any other category protected by law and/or HRC’s Harassment-Free Workplace policy.

• Threatening or violent words, images, videos, or other content.

• Any activity that is illegal under applicable local, state, federal, or international law.

• Employees are expected to follow these same guidelines with respect to personal laptops and electronic devices when used in connection with HRC business, including when texting or using other messaging services.

Examples of Prohibited Activities

The examples of prohibited activities outlined below should not be construed as exhaustive; they are intended to provide a framework for employees to understand and avoid unacceptable usage.

System and Network Activities

• Violations of copyrights, trade secrets, patents, or other intellectual property, or similar materials or property protected by laws or regulations; including, but not limited to, the installation or distribution of “pirated” or other software products that are not appropriately licensed for use by HRC.

• Unauthorized copying or distribution of copyrighted material including, but not limited to, digitization and distribution of photographs from magazines, books, or other copyrighted sources; copyrighted music; and the installation of any copyrighted software for which HRC or the end user does not have an active license.

• Exporting software, technical information, encryption software or technology, in violation of international or regional export control laws, is illegal. HRC leadership should be consulted prior to the export of any material in question.

• Introduction of malicious programs into the network or server (e.g., viruses, worms, Trojan horses, email bombs, etc.).

• Revealing an employee’s account password(s) to others or allowing others to use an employee’s account. This includes family and other household members when working from home.

• Using HRC technology to actively engage in procuring or transmitting material that is in violation of applicable harassment or hostile workplace laws. (See HRC’s Harassment-Free Workplace policy.)

• Making fraudulent offers of products, items, or services from any HRC account.

• Making statements about warranty, express or implied, unless it is a part of an employee’s normal job responsibilities.

• Affecting a security breach or disruption to network communication. Security breaches include, but are not limited to, accessing data of which the employee is not an intended recipient or logging into a server or account that the employee is not expressly authorized to access, unless these activities are within the scope of the employee’s regular job responsibilities. For the purposes of this policy, “disruption” includes, but is not limited to, network sniffing, ping flood attacks, packet or IP spoofing, denial of service, and forged routing information for malicious purposes.

• Port scanning or security scanning is expressly prohibited unless IT provides prior approval in writing.

• Executing any form of network monitoring that will intercept data not intended for the employee’s host, unless this activity is part of the employee’s normal job responsibilities.

• Circumventing user authentication or security of any host, network, or account.

• Interfering with or denying service to any user other than the employee’s host (e.g., a denial-of-service attack).

• Using any program/script/command, or sending messages of any kind, with the intent to interfere with or disable a user’s terminal session, by any means, locally or through the internet/ intranet/extranet.

• Providing information about, or lists of, HRC employees, members, or donors to parties outside of HRC.

Email and Other Communication Activities

• Sending unsolicited email messages, including “junk mail” or “spam,” or other advertising/promotional materials to individuals who did not specifically request such materials.

• Using HRC’s email system to send/distribute a high volume of emails (e.g., member communications), rather than using an approved third-party service provider.

• Any communication that may be perceived as a form of harassment, whether through language/ content, frequency, or size of message sent via email, phone, or other mobile device, including text messaging or similar applications.

• Unauthorized use or forging of HRC email header information.

• Solicitation of email addresses with the intent to harass or to collect replies.

• Creating or forwarding “chain letters,” “Ponzi” schemes, or other “pyramid” schemes of any type.

• Sending unsolicited emails from HRC’s networks on behalf of, or to advertise, any services or products unrelated to HRC.

• Posting the same or similar non-business related messages to large numbers of Usenet newsgroups (newsgroup spam).

Any questions regarding permissible or unacceptable usage should be directed to the General Counsel.

Policy Cooperation and Enforcement

All employees are expected to cooperate in any investigation regarding a suspected or known violation of this policy.

Employees are required to immediately report any suspected or actual violation of this policy to the IT department and General Counsel, labeling the email as “urgent.”

Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.

RECORDING MEETINGS AND CONVERSATIONS

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows, and addresses meetings and conversations taking place in and around the HRC workplace, any remote work location, or any offsite company-related meeting or event.

PURPOSE

This policy outlines HRC’s expectations related to the recording of in-person and virtual meetings, conversations, and phone calls between or among (i) HRC employees and (ii) HRC employees and external individual(s) with whom HRC employees are conducting business, herein collectively referred to as “meeting(s).”

DEFINITIONS

For the purposes of this policy, “recording” means to capture audio or visual information or to digitally transcribe such information by any means, including, but not limited to, traditional audio and video recording devices; digital recording apps and platforms, including those used on a mobile phone, computer, or other digital device; and artificial intelligence (AI) systems.

POLICY

HRC values freedom of expression and the exchange of differing points of view, and we respect the privacy of our employees and members of our extended community. In addition, HRC acknowledges that many states and the District of Columbia have laws that require certain levels of consent when recording conversations. With dedication to HRC’s values of Responsibility and Respect, HRC strictly prohibits the secret recording of any meeting. Employees are further prohibited from arranging for others to secretly record meetings and from knowingly receiving, downloading, uploading, sharing, or publishing such recordings, except as this policy permits.

At times, HRC leadership may have a legitimate, practical reason to record a meeting, consistent with applicable law. In this case, all parties present must be informed of the purpose for recording the meeting and must provide their verbal or electronic consent prior to or immediately after the start of the recording. Note that several states require the consent of all parties, by law. If any employee or external meeting participant should deny consent, they may choose to leave the meeting, however they should be aware that their refusal to participate may result in a negative outcome, particularly if their leadership or input is essential to the purpose of the meeting. People Strategy will address any such situation with the employee, and the HRC employee who manages the relationship with an external meeting participant will address the situation with them.

In order to promote unrestrained dialogue, recognizing that not all ideas expressed in a meeting are fully formed, HRC prohibits employees from sharing recordings outside of the legitimate or practical purpose for which they are created. Under no circumstances may employees post recorded meetings on social media or any public-facing website or platform, or share with any external party without the prior written approval of HRC’s General Counsel.

Meeting recordings are typically not subject to HRC’s policies and practices concerning record retention. The individual who initiated the recording should take care to delete the file once the recording is no longer needed or relevant.

Nothing in this policy is intended to restrict an employee’s right to request a reasonable accommodation related to recording a meeting, in accordance with the Americans with Disabilities Act. Additionally, nothing in this policy is intended to interfere with, infringe upon, or restrain employee rights protected by Section 7 of the National Labor Relations Act.

HANDLING PRESS AND PUBLIC INQUIRIES

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

This policy establishes the organization’s expectations and employees’ responsibilities regarding any external inquiry on any subject related to HRC.

POLICY

During your time with HRC, you may occasionally receive a phone call, email, message on social media, or other communication from a member of the news media or the public regarding HRC, our business operations, our employees, etc. It is critical that you avoid commenting and pass the inquiry directly to HRC’s Communications team, either by contacting a member of the team directly or forwarding the request to press@hrc.org. Only members of HRC’s Communications team are authorized to respond to external inquiries. This department is specifically skilled in handling these types of communication. With inquiries regarding issues, events, or situations where you hold special expertise, the Communications team may reach out to you for partnership in crafting HRC’s response; employees who are subject matter experts may lend valuable insight to our external communication, however no employee outside of the Communications department may respond or comment independently.

It is important that employees remain vigilant and understand that even a conversation you may perceive as casual can be construed as “official” or “on the record” by the other party. Members of the press may not always wear a visible press pass or identify themselves as such.

WORKPLACE EXPECTATIONS

STANDARDS OF CONDUCT

SCOPE

PURPOSE

This policy outlines the principles by which all HRC employees are expected to operate in their affiliation with HRC. These standards support the organization’s compliance with the highest ethical and legal standards, and act to enhance our reputation and effectiveness in advancing LGBTQ+ equality.

GUIDING PRINCIPLES

To support employees in demonstrating respect for one another, preserve and enhance the reputation of HRC, and advance our mission of securing equality for LGBTQ+ people, all employees are expected to:

• Interact openly and honestly with fellow employees, colleagues, and community members, treating each other with the dignity and respect that HRC advocates for.

• Maintain the highest standards of business and ethical conduct, in accordance with applicable local, state, and federal laws and HRC’s professional standards.

• Conduct all business activities in good faith and with the intention of advancing HRC’s mission of equality.

• Work efficiently and in a manner that conserves HRC’s resources.

• Help to maintain a safe and ethical workplace by promptly questioning or reporting any activity that may be unethical, inappropriate, dangerous, or illegal.

Guiding Standards

The following standards broadly outline the obligations with which all employees must comply. Note that more detailed policies related to specific standards of conduct are published in this Handbook and on the HRC intranet, and employees are equally responsible for adhering to the requirements of those policies.

Compliance With Legal and Ethical Requirements

Laws and Procedures

Employees are required to understand all laws, regulations, codes of professional ethics, policies, and procedures that are applicable to the performance of their job duties, and to ensure that all of their actions comply with those that apply to their role. Depending on an employee’s job responsibilities, the following may be applicable:

• Political and Lobbying Efforts

Employees are required to ensure that all electoral, campaign, and ballot measure related work complies with applicable local, state, and federal campaign finance law. Employees must ensure that their lobbying of local, state, and federal officials complies with all registration and reporting requirements. Employees must ensure that they abide by local, state, and federal gifts rules

relating to public officials. Employees should refer to the HRC Political & Lobbying Policies & Procedures Manual for specific policies related to HRC’s political and lobbying efforts.

• Tax Restrictions

Employees are required to ensure that their work on behalf of HRC conforms to the organization’s distinct mission as a nonprofit organization and furthers the tax-exempt purpose of advancing equality for LGBTQ+ people. Employees must ensure that no political campaign work is conducted on behalf of HRC Foundation.

• Compliance With Investigations

Employees must fully cooperate with any federal, state, or local investigations. Employees are prohibited from making, or encouraging others to make, false or misleading representations to any person, entity, or governmental representative.

• Events and Fundraising

Employees are required to ensure that events and fundraising efforts comply with local, state, and federal laws regulating events and fundraising, including obtaining the proper authorization and/or permits prior to conducting events.

• Other Laws and Procedures

Employees are expected to follow all other laws, rules, or regulations governing their work.

Intellectual Property

HRC is committed to protecting its intellectual property and the intellectual property of others. Employees must refrain from using any intellectual property, including patented, copyrighted, or trademarked materials, without proper authorization. Further, in the course of their work at HRC, employees may have access to the intellectual property and trade secrets of HRC, including, but not limited to, donor information, financial information, and strategic plans. This information remains the sole property of HRC and may not be taken from HRC in any form by any employee when leaving the organization.

Workplace

Conduct

Ethical Conduct and Practices

HRC expects all employees to perform their job responsibilities with honesty and integrity and in a manner consistent with the mission and policies of the organization. Violations of ethical conduct, including, but not limited to, theft of property or providing false statements will be investigated and appropriate disciplinary action will be taken.

Substance Abuse

HRC is committed to an alcohol and drug-free work environment. All employees must report for work, whether in person or remote, free from the influence of alcohol and non-prescribed/illegal drugs. Employees are prohibited from participating in the unlawful manufacture, distribution, dispensation, solicitation, sale, possession, or use of a controlled substance in any HRC workplace, sponsored event, or business-related activity. Employees involved in such acts will be subject to disciplinary action, up to and including immediate termination, in accordance with HRC policies and procedures.

Confidential Information

HRC is committed to protecting its intellectual property and the intellectual property of others.

Employees must ensure that confidential information is maintained as such and is only used in a manner consistent with HRC policies, regulations, and professional standards. Confidential information may not be disclosed to anyone inside or outside of HRC, unless that individual is authorized to receive the information. Employees may only access confidential information when authorized to do so, and only for approved, HRC-related purposes.

Use of HRC Resources

All employees are responsible for the conservation of HRC’s assets and resources, including time, materials, supplies, equipment, and information, and may use them only for business-related purposes. Employee use of HRC finances, including credit cards, expense authorizations, and petty cash must be approved in advance and must comply with all relevant HRC policies. Employees must further ensure that HRC resources are used in accordance with applicable local, state, and federal laws.

Conflicts of Interest

Employees must diligently avoid all actual, perceived, and potential conflicts of interest at all times and, as such, are prohibited from engaging in any activity, practice, or act that conflicts with, or appears to conflict with, the interests of HRC. Employees may not maintain any outside business or financial interests or engage in any such business or activity that conflicts with the interests of HRC or that interferes with the employee’s ability to fully perform their job responsibilities.

Workplace Environment

Workplace Accidents and Injuries

HRC employees must promptly advise their manager of any workplace accident or injury, regardless of how serious the situation may initially appear. Employees are also required to report any actual or potential workplace hazard or dangerous work condition so that timely remediation measures may be taken to resolve the issue.

Safety and Security

All employees are responsible for maintaining a safe and secure working environment, whether in the HRC workplace, remote work locations, or at external events. Employees are expected to follow all HRC security-related policies concerning personal, physical, and cyber security, and must immediately notify HRC leadership of any actual or potential security risks, threats, or incidents.

Personal Relationships

In order to avoid actual or perceived conflicts of interest and/or disruption to the HRC workplace, employees must comply with all provisions and restrictions set forth in the organization’s Personal Relationships in the Workplace policy. In addition to other policy requirements, an employee who maintains a significant personal relationship, including, but not limited to, a romantic, spousal, or domestic partner relationship with an individual who may be doing or seeking to do business with HRC, must disclose the relationship to their manager and People Strategy and must refrain from participating in or attempting to influence HRC’s business decisions or relationship with such individual.

Responding to Legal, Ethical, or Policy Violations

Duty to Report

Employees must promptly report actual or potential legal, ethical, and policy violations, in accordance with HRC policies. Detailed information on making such reports is available in the organization’s policy on Safety and Ethics Reporting.

No Retaliation

Retaliation against any person who reports, questions, or cooperates in the investigation of any actual or potential legal, ethical, or policy violation is strictly prohibited, including any individual who brings an accusation of discrimination or harassment, or who assists with the investigation or resolution of such claim.

DRESS FOR YOUR DAY

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows, excluding employees of HRC’s retail store(s). This policy should not be construed or applied in a manner that interferes with employees’ rights under any applicable law.

PURPOSE

This policy establishes guidelines for appropriate attire anytime employees are representing HRC, including in the company’s offices, external meetings, virtual meetings, work-related events, and visits/ meetings with government officials and organizations. Different expectations apply to employees of HRC’s retail store(s) and should be discussed with the employee’s manager.

POLICY

Daily Attire and Appearance

Dress for your day is a philosophy that enables employees to dress appropriately for each day’s activities, with the expectation that they always present themselves in a clean, tidy, professional manner that reflects the company’s values, promotes collegiality among colleagues, and creates a welcoming atmosphere for visitors. These principles apply equally to employees working in person and remotely.

HRC trusts employees to use their best judgment in dressing and preparing for their day, recognizing that we maintain a “business casual” environment and, occasionally, circumstances may require a more formal appearance. For example, if you have meetings or may be interacting with external visitors, please dress in more formal business attire. If you are unsure about suitable clothing for any situation or occasion, please speak with your manager.

Note that the following clothing is not appropriate in any HRC workplace or work-related setting:

• Clothing that is excessively ripped, frayed, wrinkled, or worn.

• Overly revealing clothing, including bare midriffs or visible undergarments.

• Clothing displaying potentially offensive images or words.

• Flip flops.

Please keep in mind that coworkers may be allergic or sensitive to heavily scented colognes/fragrances.

Employees who are dressed in an unacceptable manner may be sent home or asked to change. Time used for this purpose will be unpaid or deducted from accrued leave time.

Legislative and Executive Branch Visits

To further the mission of HRC, our ability to successfully present our ideas and arguments before legislative and executive branch officials and their staff is critical, and is dependent, in part, on our polished, professional appearance and demeanor.

HRC requires employees involved in meetings with legislative and executive branch officials and/or staff to dress in a business-appropriate manner. In certain instances, formal business attire may be necessary. In other instances, “business casual” may be acceptable.

In addition to the items listed above, the following types of clothing are never appropriate for legislative and executive branch visits:

• T-shirts.

• Jeans.

• Sweatshirts.

• Athletic shoes.

• Canvas or other casual shoes, including flip-flops, sandals, rubber footwear such as Crocs, etc.

• Spandex or yoga attire, including athletic tops and leggings.

• Sweatpants or track pants.

• Any fabric resembling denim, regardless of color.

To support employees in selecting appropriate attire for legislative and executive branch visits, the following types of clothing are preferred:

• Business suits.

• Ties.

• Collared shirts or blouses, tucked in.

• Dresses or skirts in business-appropriate length and fabric (no denim of any color, spandex, or athletic fabrics).

• Tailored pants in business-appropriate fabrics (no denim of any color, spandex, or athletic fabrics).

• Sweaters, vests, or cardigans.

• Understated, coordinating socks.

• Business-appropriate shoes.

Employees whose job responsibilities include potential involvement in executive or legislative branch meetings must be prepared to dress appropriately if called to appear before officials on short notice. It is recommended that they keep a set of clothes in the office for unexpected legislative or executive meetings.

If an employee wishes to request a grooming or attire accommodation for religious or medical reasons, they must notify People Strategy as soon as possible. The request should be submitted in writing and, in the case of a medical reason, may require a doctor’s note. HRC will make every effort to accommodate such requests in accordance with state and federal laws so long as doing so does not impose an undue hardship on business operations or others in the workplace.

WORKPLACE ETIQUETTE AND DÉCOR

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows working in any HRC office location.

PURPOSE

The purpose of this policy is to establish guidelines concerning workplace etiquette and décor that enable all employees to enjoy a comfortable, inclusive workplace that maintains a professional and productive environment and reflects the image and values of HRC.

POLICY

HRC expects all employees to demonstrate respect, consideration, and dignity toward each other at all times in our workplace. It is our intention to foster a work environment that promotes inclusion, teamwork, productivity, and the values of the organization.

To maintain collegiality and minimize workplace distractions, employees are expected to demonstrate courtesy and respect to one another by adhering to the following guidelines:

Phone Etiquette

• Use a moderate tone of voice to avoid disrupting coworkers.

• Limit the use of speakerphone to situations where it is absolutely necessary.

• Avoid interrupting or listening in on coworkers’ phone conversations.

Work Style

• Respect boundaries and avoid interrupting busy coworkers. Instead, send an email or leave a voice message.

• Other than emergencies, keep personal business to a minimum and reserve it for non-work time.

• Maintain a workspace that is organized and free from clutter.

• Use computer screensavers that reflect an appropriate and professional business image.

• Be sure music is appropriate for the workplace and maintains a volume level that is not disruptive to co-workers. Employees in cubicle workspaces should utilize a headset when listening to music.

• Respect the preferred work style of those around you and make every effort to honor reasonable requests that contribute to everyone’s comfort and productivity.

Décor

Employees should feel free to decorate their office or workspace with understated artwork and/or décor that is not potentially offensive and does not violate HRC’s policies, including, but not limited to, the Harassment-Free Workplace policy. Workspaces must always present a clean, organized, professional appearance.

USE OF HRC RESOURCES

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows, and extends to all individuals working with HRC, including board members, contractors, third-party business partners, etc. This policy addresses the use of HRC’s business resources other than IT-related equipment and systems which are addressed in the company’s Internet, Email, and Portable Electronic Device Usage policy.

PURPOSE

The purpose of this policy is to establish guidelines and expectations concerning employees’ use of HRC’s business resources.

POLICY

HRC has invested significantly in business equipment and services that are vital to the smooth and efficient operation of our organization. These resources include, but are not limited to, mail and shipping services such as the U.S. Postal Service, FedEx, UPS, and messenger services; copy machines and printers; telephones; and office supplies. Most employees have access to these resources on a regular basis and they are to be used for the purpose of conducting business.

Any personal use of our mail and shipping services presents privacy and security concerns for all employees and is, therefore, not permitted. This pertains to both incoming and outgoing mail and package delivery. If an emergency should arise, please contact supportoperations@hrc.org to request a one-time use of the service you require. Note that the cost of any approved outgoing mail or packages will be the responsibility of the employee.

CONFLICTS OF INTEREST

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to provide guidelines and expectations concerning real or perceived conflicts of interest in the HRC workplace, in order to protect the organization and its employees.

POLICY

tivity that conflicts with the interests of HRC or that interferes with the employee’s ability to fully perform their job responsibilities.

A conflict of interest may occur when an employee’s outside activities or personal interests influence or appear to influence the employee’s ability to make objective decisions on the job. Conflicts that may cause, or be perceived to cause, a conflict with the interests and/or mission of HRC, or that would impair, or appear to impair, an employee’s integrity or objectivity in performing their job responsibilities should be avoided and, if unavoidable, must be disclosed to HRC’s General Counsel and People Strategy teams prior to engaging in the activity(s). The guidance of these teams must be adhered to as a condition of continued employment. Any employee who is uncertain whether a conflict exists should always disclose the arrangement in advance and obtain guidance.

Conflicting Political Points of View

In alignment with HRC’s mission, the organization generally takes a stand on local, state, and federal elections and political issues. Every employee is endowed with the First Amendment rights to free speech and association, and individual opinions and points of view may not always align with HRC’s position on an issue or candidate. No employee in their “representative capacity” may openly oppose the endorsements and positions taken by HRC. For the purpose of this policy, “representative capacity” means any situation in which an employee is acting, or is reasonably presumed to be acting, in their official capacity as an HRC employee. If an employee personally holds a position that differs from that of HRC’s and chooses to express it; for example, on their personal social media accounts, the employee has an obligation to take all steps necessary to ensure that the general public understands the opinion is that of the employee, not necessarily of HRC. Anytime these circumstances arise, the employee should disclose the conflict and discuss ways to minimize the impact on HRC by speaking with their manager or the Senior Vice President of Policy & Political Affairs.

Business Conflicts

Employees should not hold any business or personal financial interest in any entity or arrangement that provides services, products, credit, or insurance to HRC, except where the interest has been disclosed and approved by People Strategy and General Counsel. These teams will determine whether such interest creates a material conflict of interest and will advise accordingly. Any employee who is uncertain whether a business or financial arrangement or activity constitutes a conflict of interest should speak with General Counsel and/or People Strategy immediately; ideally prior to engaging in the activity.

The following examples may be helpful to employees, however they should not be construed as a comprehensive list of all possible scenarios. Employees should always seek guidance on their particular circumstances by talking with their manager, People Strategy, and the General Counsel.

Examples

• An HRC employee holds a part-time bartending job with hours outside of their regular HRC working hours. The bar does no business with HRC, nor is it reasonable to believe that the bar would ever do business with HRC.

In this situation, there is no conflict of interest.

• An HRC employee works for a catering company part-time, outside of their regular HRC working hours. The catering company is seeking a contract with HRC for the National Dinner.

This situation may present an actual or perceived conflict of interest. The employee must disclose the catering job to their manager and People Strategy to receive guidance. HRC will always attempt to preserve the interests of the employee while prioritizing the business integrity of HRC. A possible outcome in this situation may be that the employee would need to ensure they have no input or involvement with the potential HRC contract and/or any resulting business arrangement.

• An HRC employee works in the organization’s Political department. At night, they perform volunteer work for the political campaign of an individual who is challenging an incumbent candidate endorsed by HRC.

This is a conflict of interest and must be reported to the employee’s manager, the Senior Vice President of Policy & Political Affairs, and the General Counsel. The employee will receive guidance on how they must proceed.

Other Potential Conflicts of Interest Addressed in This Handbook

• Personal Relationships in the Workplace.

• Gifts to and From Third Parties.

• Outside Employment and Honoraria.

Conflict Disclosure for Employees at the Director Level and Above

On an annual basis, HRC engages in a conflicts of interest review process, applicable to board members and employees at the Director level and above. These employees are required to complete a disclosure form as part of this process.

A conflict of interest may occur when an employee’s outside activities or personal interests influence or appear to influence the employee’s ability to make objective decisions on the job.

GIFTS TO AND FROM THIRD PARTIES

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows, and addresses the exchange of gifts and/or entertainment between HRC employees and third parties.

PURPOSE

This policy is intended to ensure HRC’s full compliance with anti-bribery and anti-corruption laws. It provides guidelines that employees must follow when exchanging gifts or entertainment with third parties in order to avoid actual or perceived attempts to assert improper influence over any business-related situation or decision.

POLICY

HRC recognizes that gifts are commonly exchanged to mark special occasions or life events, such as marriage, retirement, illness, etc. When an exchange of gifts is necessary, to avoid any actual or perceived impropriety, employees must adhere to the guidelines outlined below which apply to both giving and receiving gifts. For gifting situations that differ from those described, employees must consult their manager, People Strategy, and/or the General Counsel.

1. No cash gift in any amount may be given to or accepted from any third party under any circumstances.

2. Gift cards must not exceed $25 in value, per person. Any employee or department receiving a gift card in excess of this amount must disclose the gift to the General Counsel and adhere to their guidance. Note that gift cards for personal use are taxable to the recipient employee when exchanged in a business context.

3. Employees may accept or give modest tangible gifts or entertainment with a value of less than $50 per person so long as the gift is consistent with reasonable business practices and is permissible under all applicable laws.

4. Employees may accept complimentary invitations to political events and fundraisers so long as the event is aligned with HRC’s mission.

5. Employees may accept occasional meals from current vendors/contractors when business is discussed during the meal and the value is not excessive.

6. HRC recognizes that employees may entertain donors, board members, or committee members who may insist on paying for a meal or event. This policy does not prohibit this type of hospitality so long as the donor, board member, or committee member is not a current or potential vendor/ contractor with HRC.

Important Restrictions

• Any gift, regardless of dollar value, that may be construed as an inducement to affect a business decision or obtain a favor may not be given or received.

• No HRC employee may solicit any form of gift or entertainment from any third party, regardless of value.

• If a third party attempts to solicit a gift or entertainment from an HRC employee, the employee must immediately alert their manager, People Strategy, and the General Counsel.

• HRC employees may never offer gifts of any kind under any circumstances to any public official or government representative.

Gifting Examples

The following examples are intended to guide employees in making appropriate decisions regarding gifts to or from third parties. These examples are illustrative and do not include all possible gifting scenarios. Employees should consult their manager, People Strategy, or the General Counsel before giving or accepting any gift of which they are uncertain.

1. An employee has worked with a vendor on a project that is finally complete. The vendor invites the employee to dinner to celebrate. No business will be discussed.

a. The employee may accept the meal if the cost is less than $100.

b. The employee may not accept the meal if the cost is more than $100.

2. A consultant to the Political department sends a congratulatory gift basket to the entire department of 10 employees to celebrate a job well done after an election. The value of the basket is estimated at $250.00.

a. The gift basket may be accepted as the value per employee does not exceed $100.

b. If the gift basket is sent only to the Political Director, they must disclose the gift to the General Counsel or share it among the entire department.

3. The building management company sends a deli platter to the Operations team for the department’s holiday party, plus $20.00 in cash for each member of the department. The value of the platter is estimated at $15 per person.

a. The department may accept the platter as the value does not exceed $100 per employee.

b. The department must return the cash as no cash gifts of any value may be given or received.

4. An employee is visiting New York to look at hotels for a future board meeting. One of the hotel managers offers them a free stay for the current trip and a certificate for a free weekend stay at any hotel in their chain, for personal use.

a. The employee may accept the complimentary stay for the business trip, however they must decline the free weekend offer and should report it to their manager.

5. A board member offers a field representative their ticket to a fundraiser for a candidate HRC supports. The fundraiser is $1000 per plate/ticket.

a. The field representative knows their presence at the fundraiser would contribute positively to HRC’s reputation. They must disclose the offer to the General Counsel to determine if accepting the ticket is appropriate.

PERSONAL RELATIONSHIPS IN THE WORKPLACE

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

This policy is intended to ensure that HRC maintains a professional and productive work environment, free of personal conflicts and real or perceived preferential treatment, and supports the organization’s ability to effectively and consistently enforce its policy against sexual harassment.

POLICY

HRC recognizes the importance of interpersonal connections among employees, and also understands it is essential to establish boundaries to ensure that personal relationships do not adversely affect our workplace or public perception of our organization.

Employees may not occupy a position that directly or indirectly works for, reports to, or supervises anyone with whom they have a significant personal relationship, including contract workers. Additionally, employees may not transfer into a role with such a reporting relationship.

For the purposes of this policy, a significant personal relationship is defined as the employee’s spouse or domestic partner, parent, child, sibling, grandparent, grandchild, parent’s sibling, or cousin; or the parent, child, sibling, grandparent, grandchild, parent’s sibling, or cousin of the employee’s spouse or domestic partner. Significant personal relationships also include dating or romantic relationships, sexual interactions, and business partnerships outside of HRC.

Employees must immediately inform their manager(s) and the People Strategy department of any significant personal relationship that exists or develops. Similarly, any manager or member of HRC leadership who becomes aware of a conflicting personal relationship must immediately report it to the People Strategy department.

If the relationship develops during employment, HRC will attempt to transfer one of the individuals involved to a role for which they are qualified, within 30 calendar days of receiving notice. This period may be extended for an additional 30 calendar days under extenuating circumstances, with the approval of the department director and People Strategy leadership. Every effort will be made to place the transferred employee in a position of comparable responsibility and compensation, however this cannot be guaranteed. If no suitable position exists, one of the employees may be separated from the organization.

Under no circumstances may any employee of HRC initiate or participate in a significant personal relationship with an intern, Youth Ambassador, or fellow (collectively “covered individuals”) during the covered individual’s term with HRC. This applies to all employees, whether or not they are in a reporting relationship with the covered individual.

Similarly, significant personal relationships between employees and board members must also be avoided. Members of the Board of Directors oversee the role of the President and therefore serve as indirect managers of all employees. Any relationship between an employee and a board member must be immediately disclosed to the employee’s manager and People Strategy. People Strategy’s senior leadership, in partnership with the President and General Counsel, will seek a solution which may include resignation of the board member or separation of the employee.

Any employee who is found to have violated this policy will be subject to disciplinary action, up to and including termination of employment.

INTELLECTUAL PROPERTY AND OWNERSHIP OF WORK

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

This policy is intended to remind employees of their obligations under the Confidentiality and Proprietary Rights Acknowledgement, concerning intellectual property and ownership of work.

POLICY

Upon joining HRC, all employees identified under the “Scope” of this policy are required to sign a Confidentiality and Proprietary Rights Acknowledgement, the terms of which all employees are required to adhere to throughout their employment and beyond, as detailed in the Acknowledgement. With any questions concerning HRC’s expectations and restrictions related to intellectual property and ownership of work, please reach out to the General Counsel. To obtain a copy of your signed Acknowledgment, contact People Strategy.

SIGNATURE AUTHORIZATION AND CONTRACTS

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

This policy is intended to establish which employees have the authority to sign contracts on behalf of HRC and to define the parameters that govern contracted business transactions.

POLICY

Any business dealing that commits HRC to a monetary obligation of $5,000 or more over the course of a calendar year, or that raises intellectual property, data security, confidentiality, or liability concerns, must be memorialized in writing and treated as a contract. All contracts must be approved by the General Counsel and, if committing HRC to a monetary obligation of $5,000 or more over the course of a calendar year, by the Senior Vice President of Finance and Operations, or their designee.

Unless otherwise specified, only corporate officers of HRC are authorized to sign financial instruments, contracts, and other legally binding documents on behalf of the organization. These employees should be aware that, in many instances, additional policies or procedures provide guidance and/or govern contracted transactions and signature authorization. Employees who are authorized to do so must adhere to all relevant policies and procedures when signing any legally binding document.

Any employee involved in the negotiation of goods or services on behalf of HRC must partner with their manager, General Counsel, and/or HRC leadership to ensure all transactions are completed appropriately and in accordance with applicable policy.

HANDLING GOVERNMENT INVESTIGATIONS

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

This policy is intended to ensure that all government searches and investigations in the HRC workplace, including an employee’s remote work location, are handled with consistency and adhere to all applicable legal requirements.

POLICY

In order to protect HRC and its employees, it is critically important that all government searches and investigations are handled with care and cooperation. Unless prohibited by the investigating agency, any employee who receives a search warrant or is contacted regarding an investigation must notify HRC’s General Counsel immediately. Employees are expected to adhere to the General Counsel’s guidance and advice throughout any investigative proceedings.

OUTSIDE EMPLOYMENT AND HONORARIA

SCOPE

This policy applies to all regular, full-time HRC employees.

PURPOSE

This policy defines the circumstances under which employees may engage in outside employment and provides guidelines for accepting honoraria.

POLICY

HRC employees may engage in independent contractor or consulting roles outside of their HRC working hours or while on vacation, so long as such activity does not create a real or perceived conflict of interest. Outside employment duties may not be conducted in HRC offices, or using HRC equipment or resources, and any public identification of the individual performing such duties must not include reference to HRC.

Employees may also accept honoraria or other payments for services rendered outside of HRC. If an employee receives honoraria or similar payments for services provided during the employee’s HRC working hours, or if the employee is identified as being associated with HRC, such honoraria must be paid in full to HRC.

Employees who work outside of HRC must continue to adhere to HRC’s scheduling standards, perform all of their HRC job responsibilities, and meet the goals and performance expectations of their HRC role, including attendance at events outside of normal business hours, as needed.

Employees must complete an Outside Employment Request form and receive HRC approval prior to beginning any outside employment activities. If the outside employment does not interfere with the employee’s duties at HRC or create an actual or perceived conflict of interest, the request will be approved.

The Outside Employment Request form is available on the HRC intranet. Completed forms should be submitted to hr@hrc.org for review. Once the employee’s manager, People Strategy, and the General Counsel have reviewed and approved the request, the form will be returned to the employee for signature through Docusign. Any unapproved requests will be discussed with the employee.

If it is determined that an employee’s outside work interferes with their HRC job performance or their ability to meet other requirements of HRC, the employee may be asked to modify or terminate their outside employment if they wish to remain employed by HRC.

EMPLOYEE TRAVEL AND EXPENSES

SCOPE

This policy applies to all full-time and part-time HRC employees, interns, and fellows who incur pre-approved travel and/or per diem expenses in the course of performing their job responsibilities.

PURPOSE

This policy establishes the company’s Employee Travel and Expense Policy and Procedures as the governing set of guidelines for planning work-related travel and obtaining reimbursement for per diem and other HRC expenses.

POLICY

Employees who travel on HRC business and/or incur per diem or other expenses on behalf of HRC will be reimbursed by the organization when such travel and/or expenses are pre-approved and adhere to the requirements and procedures established in the Employee Travel and Expense Policy and Procedures, available in the Finance section on the company’s intranet.

HRC recognizes the importance of interpersonal connections among employees, and also understands it is essential to establish boundaries to ensure that personal relationships do not adversely affect our workplace or public perception of our organization.

SAFETY, SECURITY & VIOLENCE PREVENTION

SAFE WORK ENVIRONMENT

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows, and extends to all individuals visiting the HRC workplace, including, but not limited to, contract workers, board members, volunteers, third-party business partners, etc. The policy addresses conduct and expectations in all HRC work locations, including properties owned or leased by the organization as well as the location of any work-related events or activities. Any employee or contractor whose primary job responsibility is to safeguard the HRC workplace may be exempt from certain policy provisions and is required to adhere to the safety and weapons-related requirements established specifically for their role.

PURPOSE

The purpose of this policy is to establish guidelines and expectations that promote a safe and secure work environment and foster a culture of awareness and accountability among all employees. This policy also defines the expectations and outcomes associated with the possession, use, or storage of weapons and ammunition in the workplace.

POLICY

HRC is committed to providing a safe workplace and minimizing the risk of violence, theft, accidents, and injuries by promoting safe practices and ensuring compliance with safety-related procedures and regulations. Any individual found to be in violation of this policy will be subject to disciplinary action, up to and including termination of employment.

Violence Prevention

HRC will not tolerate any form of violence or aggression by or toward any HRC employee, volunteer, vendor, or any third party interacting with the organization. Violence or aggression includes physical altercations, threats, threatening language, or any conduct that is intentionally hostile, abusive, intimidating, or severe. HRC employees are expected to exercise reasonable judgment in identifying and preventing potentially dangerous situations. At the first sign of danger, employees should contact HRC Security, event security, or local law enforcement immediately.

Examples of conduct that may be considered threatening, violent, or aggressive include, but are not limited to:

• Aggressive physical contact, or the threat of such contact, directed toward another individual.

• The intentional destruction or threat of destruction of HRC property or an individual’s personal property.

• Menacing or threatening phone calls, text messages, or social media activity.

• Stalking.

• Veiled threats of physical harm or similar intimidation.

• Openly endorsing the unlawful use of firearms or other weapons.

Work-related violence does not refer to zealous or impassioned verbal arguments or debates on any topic, provided there is no form of coercion.

Employees hold an important responsibility in maintaining a violence-free work environment and are encouraged to immediately report any incident that violates this policy to their manager, People Strategy, or Security. HRC will investigate all reports of actual or potential workplace violence, and any employee found to have engaged in threatening or violent behavior will be subject to disciplinary action, up to and including termination of employment.

Employees with any safety concerns while working or traveling for HRC must immediately notify their manager, the Security team, or the security officer on duty.

Security Compliance

At all times, employees are expected to comply with the following security requirements and procedures.

ID Badges

All HRC employees, as well as board members and certain third parties who require regular access to our facilities, are issued an ID Badge which must be visibly worn at all times when on HRC premises. Employees must not share their ID badge with anyone, whether or not affiliated with HRC, and should wear their badge on the assigned lanyard, as follows:

• Yellow = Board Members and Interns

• Blue = Full-Time and Part-Time Employees

• Green = Fellows

• Orange = Temporary Employees and Consultants

• Black = Tenants, UG2 Employees, Special Police Officers

• Maroon = Third-Party Contractors

Building Entry

HRC headquarters is locked at all times and requires an authorized ID badge for entry. Full-time HRC employees may access the building 24/7 for valid work-related purposes. All others with a current ID badge may access the building Monday through Friday, 8:00 a.m. to 6:00 p.m., or upon request, with advanced notice.

If an employee forgets their ID badge, they may use the Visitor Management System to obtain a temporary ID badge which must be returned to the reception desk the same day. If an ID badge is lost, please notify the Operations team immediately at supportoperations@hrc.org

Employees entering the building must avoid allowing entrance to anyone without an ID badge. If employees encounter anyone attempting to “tailgate” into the building, they should inform them that a badge is required and escort them to the reception desk.

Visitors

Only authorized visitors may enter HRC’s facilities. All visitors, including volunteers, vendors, contractors, etc., are required to sign in to the Visitor Management System to receive a daily pass and wait for the hosting employee to escort them. A visitor’s daily pass must be worn and visible at all times. Anyone in the building without a visible ID badge or daily pass should be asked to show it, or be escorted to the reception desk to obtain one.

Any visitor whose conduct is disruptive or poses a threat to HRC’s employees, business operations, or facilities should be asked to correct their behavior or be immediately escorted from the building. Any visitor incidents should be reported promptly to the Security team or the security officer on duty.

All visitors are subject to HRC’s Property Inspection and Searches procedures; see below.

Personal Property

HRC recognizes the need to bring some personal property into the office. Employees are expected to exercise reasonable care to safeguard personal items brought to work, understanding that HRC is not responsible for the loss, damage, or theft of personal belongings. Employees should not carry unnecessarily large amounts of cash or bring valuable or sentimental items to work.

Any personal property found on HRC premises should be delivered to the reception desk. Employees who are missing a personal item should first check with reception; the receptionist will return an item to the owner with proper identification and proof of ownership. Employees should report any personal property loss or damage to their manager immediately and should file an Incident Report, available on the HRC intranet.

Property Inspection and Searches

HRC respects personal privacy. Nevertheless, in order to maintain a safe and secure workplace, the organization, in accordance with applicable law, reserves the right to inspect any package or property that is taken from or brought to HRC’s premises, and may conduct unannounced searches of company or personal property at any time. This includes, but is not limited to, HRC facilities, property, storage areas, desks, and vehicles; and employees’ or visitors’ personal packages, briefcases, backpacks, purses, bags, and wallets. Employees and visitors may not interfere with or object to any lawful inspection or search conducted under the authority of HRC’s leadership.

Suspicious or Unattended Objects

Employees should be alert to the presence of suspicious or unattended objects. Unidentified backpacks, bags, packages, or other objects, particularly when located near entry and exit points, employee break areas, or in locations that may put others at risk, must be reported to on-site security immediately. If the object is unattended, suspicious, or otherwise causes concern, employees must move away from the object and warn others to stay away. Radios and cell phones should not be used near any suspicious package or object.

Weapons

HRC strictly prohibits all persons defined under the “Scope” of this policy from possessing weapons or ammunition of any kind in any HRC workplace (also defined in this policy’s “Scope”), whether concealed or carried openly with or without a permit, and further prohibits the transportation or storage of weapons or ammunition in any vehicle being used for HRC business purposes.

Employees who choose to legally carry pepper spray for personal protection may bring such spray canisters to the workplace. It is, however, a violation of this policy to openly display or inappropriately refer to the possession of pepper spray in a threatening or disruptive manner while at an HRC work location. Anyone who carries pepper spray into the HRC workplace will be liable for any injury to others, property damage, or cleanup costs resulting from the improper use or discharge of such devices.

Apart from pepper spray, anyone who believes they have a legitimate need to bring weapons or ammunition to the HRC workplace must speak with People Strategy, Security, and the General Counsel before doing so. No other HRC representative is authorized to grant such permission.

Any individual covered under the “Scope” of this policy may be subject to HRC’s Property Inspection and Searches procedures, as outlined above.

Any individual found to be in violation of this policy will be subject to disciplinary action, up to and including termination of employment.

Employees with any safety concerns while on HRC premises must immediately notify their manager, the Security team, or the security officer on duty.

Weapons Definitions

Weapon - any object or device that can be used, is traditionally used, or is designed or intended to inflict or threaten bodily harm or to damage or destroy property.

Ammunition - cartridge cases, shells, projectiles (including those that are shot from a weapon), primers, bullets (including restricted pistol bullets), propellant powder, or other devices or materials designed, redesigned, or intended for use in a firearm or destructive device.

Firearm - any device that is designed to fire a bullet, pellet, shot, flare, spear, or other projectile. This includes, but is not limited to, handguns, rifles, pistols, shotguns, revolvers, and cannons made of any material, including those made with 3D printers or similar technology, whether loaded or unloaded, as well as the ammunition for these devices.

Health and Safety

All employees share a responsibility to support and maintain a safe, healthy work environment and, therefore, are expected to adhere to all health and safety regulations, protocols, and procedures, exercising caution in all work activities.

Any unsafe work condition must be immediately reported to HRC leadership. Alternatively, employees may submit an anonymous report via the Safe Hotline by calling 1-855-SAFE (1-855-7233). They will be prompted to enter HRC’s Company ID: 4803423507. Safe Hotline will transcribe the message and report it to HRC. This is an independent third-party service intended to protect employee anonymity. Those wishing to remain anonymous should avoid providing any identifying information when leaving a message, such as name, job title, personal address or phone number, etc. Employees who identify themselves when reporting actual or potential unsafe work conditions may do so without fear of reprisal.

In the event of accident or injury, regardless of how serious the situation may initially appear, employees must immediately notify their manager to maintain compliance with health and safety laws and ensure proper recording of details in the event that such information is required for future claims or investigations.

Employees who are involved in or witness an accident or injury requiring emergency medical attention must immediately call 911.

Any employee who violates health and safety standards, causes hazardous work conditions, or fails to report or remedy any health or safety related concern may be subject to disciplinary action.

INCLEMENT WEATHER AND OFFICE CLOSURES

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

This policy is intended to provide guidance on the organization’s expectations and procedures in the event of inclement weather or office closure.

POLICY

In the event of an HRC office closure due to inclement weather or emergency, all HRC employees are expected to work remotely, performing their regular job responsibilities on a normal work schedule. This includes employees whose roles are not eligible for hybrid or remote work, such as members of the Operations team.

For weather related decisions, HRC’s headquarters follows the local schedule set by the federal Office of Personnel Management. In the event that a weather-related situation impacts your commute when HRC’s offices are otherwise open, please partner with your manager to agree on an appropriate course of action, which may include working remotely, shifting to a modified work schedule, or using paid time off.

In the event that an HRC work location must close due to an operational emergency or natural disaster, employees will be notified by email and cell phone, and must adhere to HRC guidance concerning work schedules and locations.

DRUG-FREE WORKPLACE

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to ensure a safe, healthy, and productive work environment by prohibiting the unlawful possession, use, sale, or distribution of illegal drugs in the HRC workplace. This policy is intended to comply with all applicable local, state, and federal laws.

POLICY

HRC is seriously concerned about the adverse effects of drug use and abuse on the health and safety of our employees and communities. HRC maintains a drug-free workplace, in accordance with the stipulations outlined below. Any employee who violates any aspect of this policy may be subject to disciplinary action, up to and including termination of employment.

1. HRC prohibits the unlawful manufacture, distribution, dispensation, solicitation, sale, possession, or use of illegal drugs or controlled substances in any HRC workplace, sponsored event, or supervised activity, or on the premises of the company’s owned or leased properties. This prohibition extends to marijuana, even if medical and/or recreational use is legal. Any illegal drugs or controlled substances found on HRC property may be turned over to the appropriate law enforcement agency.

2. HRC employees are prohibited from reporting to work, whether in-person or remote, or working in any HRC-related capacity while using or under the influence of illegal drugs or controlled substances. Employees who are prescribed controlled substances by a licensed medical practitioner, with authorization to report to work, must request an accommodation from People Strategy prior to performing any work under the influence of the prescribed substance. In accordance with HRC’s commitment to non-discrimination, we will endeavor to grant a reasonable accommodation when doing so does not impose undue hardship on HRC, or pose a threat to the health or safety of the employee or others in the workplace.

3. Similarly, HRC is committed to supporting employees who are recovering from substance dependencies as well as those who are undergoing or in need of treatment. We recognize that early intervention may improve the success of rehabilitation and encourage employees to seek help if needed. Available resources, including information on the company’s Employee Assistance Program, are provided on the HRC intranet. Note that treatment for alcoholism and/or other drug use disorders may be covered by HRC’s employee benefit plan.

4. Any employee who is found to be using illegal drugs or has been convicted of a criminal drug violation in the workplace, may be requested to participate in rehabilitation and counseling or may be discharged at HRC’s discretion.

5. HRC employees and interns are subject to notification requirements as a condition of employment related to certain federal grants. Any employee who is convicted of a criminal drug violation in the workplace must notify HRC in writing within five calendar days of the conviction. Upon receiving such notice, HRC will advise the relevant federal agency within 10 calendar days, as required, and will take appropriate action toward the employee within 30 days of notification.

ALCOHOL POLICY

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to ensure a safe, healthy, and productive work environment by outlining clear expectations concerning the consumption of alcohol in the workplace and at work related events.

POLICY

Given the importance of HRC’s work and the responsibilities we hold in advocating for the LGBTQ+ community, it is essential that all employees represent the organization professionally and responsibly at all times.

Employees may not arrive at work under the influence of alcohol, or consume alcohol during the workday or anytime they are serving as a representative of HRC. In rare instances, members of leadership may approve moderate alcohol consumption as part of an internal celebration or event, and employees will be notified.

The company acknowledges that employees often work at events and receptions where alcohol is

served. If an employee’s job responsibilities require that they provide active support or management of the function, they may not consume alcohol during that time. Employees who are not assigned such duties may consume a maximum of two drinks at a work-related event. If you are unsure whether consuming alcohol is appropriate in any situation, please speak with your manager prior to doing so.

Employees who consume alcohol must maintain a professional demeanor at all times. The choice to consume alcohol will be considered an aggravating factor in the internal review of any incident that may arise.

The choice to consume alcohol is a personal one. No employee is ever required to consume alcohol at events or receptions. Employees should never feel pressure to consume alcohol. Any employee found to have pressured another employee will be subject to disciplinary action.

Under no circumstances may any HRC employee drive a vehicle for any purpose associated with HRC business while under the influence of alcohol.

Note that HRC reserves the right to instruct employees not to consume alcohol at specific events.

Any employee found to be in violation of this policy will be subject to disciplinary action, up to and including termination of employment.

SMOKING AND VAPING

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows, and extends to all visitors to the HRC workplace.

PURPOSE

The purpose of this policy is to establish clear guidelines for the use of tobacco and related products, such as e-cigarettes or vaping devices, in the workplace in order to promote a safe, healthy, and comfortable environment for all employees and visitors.

POLICY

HRC is committed to providing a safe and healthy work environment and, therefore, smoking and vaping are prohibited in all areas of the HRC workplace. Employees are also expected to adhere to any smoking and vaping restrictions that may be in effect at external work-related events, offices, venues, etc.

To maintain a respectful presence during virtual meetings when working remotely, employees are expected to refrain from smoking or vaping on camera. Note that on-camera presence is required during virtual meetings, per the organization’s Hybrid and Remote Work policy.

DISTRACTED DRIVING

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows who drive for HRC business purposes, whether operating their own vehicle, a rental, or one belonging to a third party such as a volunteer.

PURPOSE

The purpose of this policy is to promote workplace safety and establish guidelines and expectations to minimize the likelihood of injury or death resulting from distracted driving.

POLICY

HRC recognizes that distracted driving can impair safe driving and contribute to vehicular accidents. Any employee driving any vehicle for HRC business purposes must adhere to the guidelines and expectations outlined below and must exercise good judgment, safety, and caution at all times while driving.

HRC employees are prohibited from driving while intoxicated or under the influence of legal or illegal drugs that may impair their ability to drive safely. HRC also prohibits driving while impaired in any way, mentally or physically, including driving while fatigued. In the event you become fatigued while driving, please find the next safe place to legally park and rest, or arrange for another driver to take over.

Use of the following devices while driving is strictly prohibited:

• Cell phones, tablets, or other mobile devices for any purpose, including talking, text messaging, video calls, etc., unless paired to a hands-free device.

• Portable music players.

• Headphones, earbuds, AirPods, etc.

• Electronic games.

• Computers.

• Any device that violates local ordinance, or state or federal law.

Interacting with an integrated touchscreen in any vehicle should be kept to a minimum while driving. Similarly, any activity that necessitates taking both hands off the wheel, or diverts attention from one’s driving responsibilities is prohibited.

While permissible, employees should limit hands-free phone conversations while driving. Any conversation that becomes animated or argumentative must be postponed until the vehicle is parked in a safe, legal area.

Some jurisdictions may prohibit mobile phone usage, even with a hands-free device. HRC employees must comply with local laws at all times. Please consult the Governors Highway Safety Association for a current list of applicable laws by state.

The following safe driving practices are also required:

• Pre-program any GPS device before the vehicle is in motion.

• Do not reach for anything in the vehicle that necessitates a shift from the proper driving position.

• Choose foods and drinks that are easy to hold and consume with one hand. Never take both hands off the wheel.

• Pre-select radio stations or playlists.

• If conversing with a passenger, stay focused on the road. Do not turn to look at them or to view anything on a mobile device. Avoid contentious conversations.

• Never write or handle paperwork while the vehicle is in motion.

• Do not read a map or atlas while the vehicle is in motion.

WORKPLACE INJURY AND ILLNESS

SCOPE

PURPOSE

This policy outlines the organization’s expectations and procedures for preventing, addressing, and reporting injury or illness in the HRC workplace, including remote work locations.

POLICY

HRC is committed to providing a safe workplace for all employees and to minimizing the risk of personal injuries at work. To support this commitment, employees are expected to maintain their workspaces, including remote work locations, in a safe manner, free from potential hazards.

It is expected that employees will immediately, or within 24 hours, report any potentially hazardous workplace environment or situation to People Strategy, Operations, or Security so that timely action may be taken to resolve the issue.

Any employee who is injured or becomes ill at work or while traveling for work should seek appropriate medical attention, when necessary. Employees who witness an injury or illness are expected to assist in addressing the situation, when doing so will not pose harm to themselves or others. In severe cases, 911 should be called immediately. First aid kits are located on each floor of HRC’s headquarters, near the stairwells. An AED unit is available on the 1st, 2nd, 4th, 6th, and 8th floors, near the first aid stations.

Regardless of how severe an injury or illness may appear, every incident must be reported within 24 hours, according to the procedures outlined in the company’s Safety and Ethics Reporting policy. This requirement includes work-related injuries that take place in an employee’s remote work location or while traveling for work.

When the injury or illness prevents an employee from performing their day-to-day job responsibilities, they may be eligible for short-term or long-term disability, FMLA, workers’ compensation, or other benefit programs. Please see contact the People Strategy department for more details.

SAFETY AND ETHICS REPORTING

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to establish HRC’s guidelines and procedures for properly documenting, reporting, and addressing workplace incidents, unusual occurrences, and potentially unethical business conduct to support the safety and well-being of HRC employees and to protect HRC’s business operations.

POLICY

As a politically active LGBTQ+ organization, all employees of HRC must maintain heightened awareness and concern for the safety of our employees, volunteers, and external partners, endeavoring at all times to protect each other and our workplace.

Further, HRC is committed to maintaining the highest standards of integrity, professional conduct, and ethical behavior in all endeavors, and is governed by the highest level of respect for the law. In alignment with the company’s Standards of Conduct, it is expected that all employees will exercise sound judgment in carrying out their job responsibilities, with the best interests of the organization, our colleagues, and our business partners in mind.

Any incident or potentially unethical conduct that may negatively affect HRC’s business operations, its employees, volunteers, visitors, or other parties associated with the organization must be reported in a timely manner, as outlined below. Any employee who is involved in or witnesses an incident is obligated to comply with any subsequent inquiry or investigation and, similarly, is required to report any new details or information that are discovered after the occurrence. New information must be relayed to People Strategy and the General Counsel within 24 hours of discovery.

Reportable Incidents

A reportable incident is any unusual occurrence that takes place on or near HRC property, at an HRC event, or in the course of pursuing authorized HRC objectives and that negatively affects, or could negatively affect, the safety and security of HRC, its employees, volunteers, visitors, or other parties associated with the organization.

Incidents include, but are not limited to:

• Accidents, whether or not they result in injury.

• Sudden, severe illness.

• Property damage.

• Security breaches or threats.

• Real or perceived harassment or discrimination.

• Environmental spills, damage, or concerns.

• Any event or situation that poses a risk to any individual’s health, safety, or security.

In emergency situations, employees should partner with a nearby member of HRC leadership and/or contact 911 immediately.

Reportable Business Conduct

Employees are required to report any actual or suspected business misconduct or wrongdoing, including, but not limited to:

• Failure to comply with laws or regulations applicable to HRC.

• Questionable or improper accounting or auditing practices.

• Fraud, theft, or embezzlement.

• Unauthorized disclosure of confidential information.

• Improper use of company resources.

• Breach of data protection.

• Money laundering.

• Bribery.

Reporting Procedures

Employees must report any incident or potential business misconduct as soon as possible by completing an Incident Report form, available on HRC’s intranet, or by sending an email to one of the following email addresses: hr@hrc.org; security@hrc.org; csupport@hrc.org; operations@hrc.org; or general. counsel@hrc.org. Employees should choose the email address that is most relevant to the type of incident. The initial email must be sent within two business days of the occurrence. Timely reporting is crucial to support prompt investigation, resolution, and implementation of remediation or preventive measures.

Employees who monitor these email addresses will receive additional training on how to respond to reports.

Alternatively, employees may submit an anonymous report via the Safe Hotline by calling 1-855-SAFE (1-855-7233). They will be prompted to enter HRC’s Company ID: 4803423507. Safe Hotline will transcribe the message and report it to HRC. This is an independent third-party service intended to protect employee anonymity. Those wishing to remain anonymous should avoid providing any identifying information when leaving a message, such as name, job title, personal address or phone number, etc.

HRC is committed to maintaining the highest standards of integrity, professional conduct, and ethical behavior in all endeavors, and is governed by the highest level of respect for the law.

No Retaliation

HRC will not tolerate any form of retaliation against individuals who, in good faith, report concerns of any nature, or who participate or cooperate in any investigation of such matters. No employee who reports an incident or concern, in good faith, even if erroneous, will be subject to adverse employment consequences as a result of such report(s). Any pending, unrelated employment actions will not be affected by reporting or raising a concern. Any employee who engages in retaliation will be subject to disciplinary action, up to and including termination of employment.

Acting in Good Faith

Employees reporting an ethics-related concern must act in good faith and have reasonable grounds for believing an actual or potential violation has occurred or may occur in the future. Making allegations maliciously, recklessly, or with knowledge that the allegations are false, will be viewed as a serious policy violation and may result in disciplinary action, up to and including termination of employment.

Confidentiality

The confidentiality of a completed Incident Report form or a report received via email must be preserved at all times, shared only with individuals who have a legitimate need to know for the purpose of investigation, resolution, or prevention. Investigations will be kept confidential to the extent possible.

MANAGING YOUR CAREER

EMPLOYEE REFERRAL PROGRAM

SCOPE

This policy applies to all full-time and part-time HRC employees who refer an eligible job candidate for a full-time HRC role. Interns and fellows are not eligible for the employee referral program.

PURPOSE

The purpose of this policy is to establish HRC’s guidelines and practices concerning employee referrals.

POLICY

HRC recognizes that employees are an important resource in the talent recruitment process, enabling us to expand our talent pipeline beyond traditional sources. Through the Employee Referral Program employees may refer a professional colleague or acquaintance for a full-time HRC role, and may be eligible for a taxable bonus of up to $500 if the candidate is hired and remains employed for at least 90 days. The employee should have sufficient knowledge of the referred applicant’s professional abilities to recommend them for a specific HRC role.

Employees may not post an open HRC role on any website or social media platform.

There is no limit to the number of employee referral bonus awards an employee may receive.

Eligibility Criteria

• The referring HRC employee must be named on the candidate’s application or must notify People Strategy of the referral via email prior to the recruitment process.

• The referred candidate must be new to HRC’s resume database and not a former applicant or previous referral from any other internal or external source.

• The referred applicant must remain continuously employed by HRC for a minimum of 90 days.

• The referring HRC employee must also be employed with HRC 90 days from the referred candidate’s hire date.

• Hiring managers and leadership team members may only refer candidates who will not report directly to them or to anyone within their department, including directorate heads.

Exclusions

The following situations and individuals are not eligible for a referral bonus:

• Any individual an HRC employee meets in the course of working the HRC booth at a professional event will not normally be considered an employee referral.

• Members of the People Strategy team.

• Hiring Managers and leadership team members recruiting for their own department or department/directorate levels.

• HRC employees who refer close family members (e.g. a parent, spouse, domestic partner, sibling, child, grandparent, grandchild, etc.).

• The referral of any former HRC employee.

• Temporary HRC employees, interns, and fellows.

• HRC employees who refer a current or former intern or temporary employee for a full-time role.

Employee Referral Procedures

1. Be sure the referred individual includes your name on their application, or email People Strategy with the referred individual’s name and the open position for which you are referring them. People Strategy should receive this email as early as possible in the recruitment process. Note that a referring employee is not typically involved in the interviewing and hiring process.

2. Once the referred individual is hired and has completed 90 days of employment, submit a completed Employee Referral Bonus form to People Strategy. The form is available on the HRC intranet.

3. People Strategy will verify that you referred the candidate and will verify your eligibility for the bonus.

Employee Referral Bonus Payments

Once eligibility is verified, employee referral bonus payments are made during HRC’s regular payroll cycle and are subject to all applicable tax withholdings.

EMPLOYMENT VERIFICATION

SCOPE

This policy applies to all full-time and part-time HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to establish HRC’s employment verification practices.

POLICY

Upon receipt of written request, HRC’s People Strategy team will provide employment verification to third parties for current and former HRC employees. Employment verification includes job title(s) and dates of employment only. Current employees may request in writing that HRC also provide salary confirmation if necessary for the purpose of securing a loan or other personal financial need. Only the People Strategy team is authorized to release this information, therefore any requests should be immediately referred to People Strategy.

HRC does not provide personal or performance references for current or former employees to anyone outside of the organization. Any manager who believes they have a legitimate need to provide a reference must partner with People Strategy prior to doing so.

PROFESSIONAL DEVELOPMENT AND LICENSES

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to establish HRC’s philosophy and guidelines concerning employees’ professional development and continued licensure.

POLICY

HRC is committed to fostering a workplace culture that promotes continuous learning, growth, and development, empowering employees to pursue their full potential while simultaneously driving the longterm evolution and success of the organization. As resources permit, HRC may assist employees with enhancing skills that are necessary for success in their current position, or developing skills that may be required to support a change in responsibilities or transfer/promotion to another role in the organization.

Additionally, HRC encourages employees to participate in professional organizations, workshops, conferences, seminars, and training programs related to their work or their professional development goals. If HRC requires an employee to attend such programs, the organization will pay for reasonable costs and grant necessary paid time off. HRC may also cover all or a portion of the costs associated with elective development programs, on a case-by-case basis. Note that all regular full-time employees are eligible for a license to access LinkedIn Learning, which offers thousands of online training modules on topics that support professional development.

Each employee’s training and development needs and objectives are discussed during their annual performance review. Employees who wish to participate in any professional development opportunity

throughout the year may request the approval of their manager to do so and may be granted paid time off to attend such programs, on a case-by-case basis.

Professional Licenses

To support employees in maintaining professional credentials required to perform their job responsibilities, HRC pays all reasonable costs incurred to maintain, but not to obtain in the first instance, an employee’s professional credentials, such as attorney or CPA license renewal, professional association dues, etc. Employees who must maintain professional licensure will be paid at their regular rate of pay for time spent on the required activities.

Internal Development Programs

HRC honors the letter and spirit of anti-discrimination laws regarding issues of homophobia, racism, sexism, classism, ageism, sexual harassment, and discrimination based on religious belief. Therefore, HRC provides annual training opportunities designed to build awareness and understanding of these and similar issues of diversity. HRC actively seeks to deliver exceptional, forward-thinking training programs that enable employees to understand best practices and build skills that drive a culture of inclusion and belonging. HRC welcomes employee suggestions and feedback to ensure training is continually effective and meaningful and reflects the ever-changing world around us.

To ensure that HRC’s leadership is continually growing and evolving to maintain current best practices, all people managers are required to participate in relevant leadership courses, including training through The Management Center, as well as internal trainings focused specifically on management practices at HRC.

Given the nature of HRC’s work, every employee holds an important responsibility to identify and propose potential training and professional development opportunities that may benefit the organization as a whole. Employees should discuss any such programs with their manager or People Strategy.

Note that HRC assumes no responsibility for training that may be necessary to correct pre-existing, unknown professional skill gaps.

DISPUTE RESOLUTION

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to outline HRC’s process for addressing employee concerns and workplace conflict.

POLICY

HRC is committed to fostering a healthy, harmonious work environment for all employees. When difficult situations arise, it is HRC’s intention to work together, internally, to resolve any concern or conflict.

Employees should initiate an open dialogue with their manager as a first step in resolving any workplace issue. Those who may be uncomfortable speaking with their manager, or believe the issue cannot be resolved in this manner, should follow the procedures outlined below:

1. The employee should make an appointment to discuss the matter with People Strategy and should bring to this meeting any documentation that specifies or relates to the issue. People Strategy will determine the best course of action for addressing the situation within a reasonable period of time.

2. The resolution process may involve consulting with the other parties involved, engaging a third party mediator, or conducting an internal investigation or mediation process with trained HRC leaders.

3. Depending on the course of action People Strategy pursues, the employee will generally receive an update within two weeks from the date of the initial meeting.

4. Alternatively, employees may submit an anonymous report via the Safe Hotline by calling 1-855SAFE (1-855-7233). They will be prompted to include HRC’s Company ID: 4803423507. Safe Hotline will transcribe the message and report it to HRC. This is an independent third-party service intended to protect employee anonymity. Those wishing to remain anonymous should avoid providing any identifying information when leaving a message, such as name, job title, personal address or phone number, etc. Employees who wish to remain anonymous should be aware of the limitations this may present in resolving certain types of disputes.

No Retaliation

HRC will not retaliate against any employee for raising any concern, pursuing dispute resolution with their manager or People Strategy, or for presenting evidence in support of their claim.

DISCIPLINARY ACTION

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to establish HRC’s general approach to disciplinary action.

POLICY

The Human Rights Campaign was founded on the principles of fair and equal treatment and seeks to ensure the fair and equal treatment of all employees. From time to time, in order to maintain a safe, positive, productive work environment and to uphold business practices that comply with all company policies and relevant legal regulations, disciplinary action may be necessary to correct or discontinue inappropriate or unlawful behavior.

The goal of disciplinary action is to establish an action plan that supports the employee in correcting a behavior or performance issue, preventing recurrence, and re-establishing expectations that will enable the employee to succeed in their role and the organization. While the success of any disciplinary action

plan is largely dependent on the willingness and commitment of the employee to make the necessary change(s), the details of the plan will be established by the employee’s manager and/or People Strategy.

Depending on the severity of the situation, informal, non-disciplinary coaching or counseling may precede formal disciplinary action. In all cases, it is HRC’s intention that coaching, counseling, and/or disciplinary action is prompt, consistent, impartial, and conducted confidentially.

HRC reserves the right, at its sole discretion, to initiate and determine the nature of any disciplinary action and to omit steps in the disciplinary process. Disciplinary action may be necessary to correct unsatisfactory job performance or behavioral issues, such as excessive absence, lateness, inappropriate behavior, or violation of company policy. Disciplinary action typically progresses as outlined below, with the aim of correcting performance or behavior:

1. Coaching/Counseling - a conversation or series of conversations between an employee and their manager or, in certain situations, a third party, to informally address a performance or behavior issue.

2. Verbal Warning - a more formal discussion that is documented in the employee’s file to inform them that a performance or behavior issue is unacceptable and must be corrected immediately.

3. Written Warning - a serious warning involving a conversation and written documentation that is held in the employee’s file. Employees with an active written warning are not considered to be in good standing.

4. Final Written Warning - this serves as the last opportunity for an employee to immediately correct their performance or behavior before termination of employment. Any employee with an active final written warning is not considered to be in good standing.

5. Termination - the immediate conclusion of an individual’s employment relationship with HRC.

A Performance Improvement Plan (PIP) may be established at any stage of disciplinary action. A PIP outlines specific expectations for improvement, indicates the date by which the improvement must be made, and states that termination may result if satisfactory performance is not achieved. A PIP may include a suspension of up to five working days when circumstances warrant.

HRC will provide employees with a written description of any disciplinary action that is placed in their employee file within five working days from issuance.

Although a progressive approach to disciplinary action is typical, and HRC is committed to maintaining consistency, any or all of the above steps may be omitted at HRC’s sole discretion. Further, HRC reserves the right to terminate employment immediately in lieu of progressive disciplinary action when performance or behavior is unlawful, threatening, or severe.

Nothing in this policy is intended to alter the at-will employment relationship between HRC and non-represented employees.

SEPARATION OF EMPLOYMENT

SCOPE

This policy applies to all full-time, part-time, and temporary HRC employees, interns, and fellows.

PURPOSE

The purpose of this policy is to establish HRC’s expectations and practices concerning separation of employment.

POLICY

It is HRC’s sincere wish that every employee will enjoy a long and fulfilling career with our organization. However, occasionally circumstances arise that necessitate a separation of employment. This policy outlines the company’s expectations and procedures related to different types of separation and provides details concerning final pay and benefits as well as the return of company property.

Separation Expectations

Voluntary Resignation

All non-union employment with the HRC is “at will.” This means that employees voluntarily enter into a work arrangement with HRC and are free to resign anytime, with or without reason, notice, or cause. (See the company’s Employment At-Will policy for more information.) Although HRC is an at-will employer, the professional courtesy of at least two weeks’ notice is strongly encouraged.

When an employee voluntarily resigns from HRC, they should inform their manager and People Strategy in writing at least two weeks in advance of their anticipated last day. No vacation or personal time may be used, under any circumstances, during an employee’s last two weeks with HRC. It is expected that this time will be dedicated to preparing for the transfer of job responsibilities. Employees who wish to use vacation or personal time during their final weeks of employment must provide HRC with at least four weeks’ notice. Managers have flexibility to approve vacation or personal time, up to the last two weeks of employment, so long as an appropriate transition plan is in place. Employees are no longer eligible for Sabbatical Leave once they have notified HRC of their resignation, or are informed of job elimination.

Job Abandonment

When an employee voluntarily resigns without proper notice or fails to report to work for three consecutive work days without reporting the absence, they will be determined to have abandoned their role with HRC and their employment will be terminated, if applicable by state law.

Termination of Employment

Termination of employment occurs when HRC, as an at-will employer, decides to end an employment arrangement with an employee, with or without reason, notice, or cause. All terminations are handled on a case-by-case basis, with the intention to support a smooth transition for the organization and the employee.

HRC

encourages employees to participate in professional organizations, workshops, conferences, seminars, and training programs related to their work or their professional development goals.

Job Elimination

Job elimination occurs when an HRC employee’s role with the organization is eliminated. Job elimination, also known as layoff, may occur for a variety of reasons including, but not limited to, organizational restructuring, expense reduction, project cancellation, realignment or elimination of job responsibilities, etc. The conclusion of a temporary assignment or a role with a specified end-date is not considered job elimination.

An employee whose job has been eliminated will receive a minimum of two weeks’ advanced notice or equivalent pay in lieu of such notice.

Pay, Benefits, and Return of Company Property Upon Separation

Unless otherwise indicated above, the following details apply to HRC’s separation practices.

Pay

Regardless of the type of separation, employees will be paid for all hours worked, minus any debt that may be owed to HRC, on or before the next scheduled payday following their last day of employment. Employees may be entitled to pay for accrued, unused vacation time, in accordance with applicable law, and will not be paid for unused personal time or sick time unless required by law. Note that employees will not be paid for accrued vacation time if the separation of employment occurs during the introductory period.

Benefits

Continuation of certain benefits may be available at the employee’s expense, if elected. The employee will be notified of the terms and conditions of such continuation, either in person or in writing.

Similarly, employees who are enrolled in the HRC 401(k) plan will receive information, verbally or in writing, on converting their 401(k) plan.

Return of HRC Property

All HRC property issued to the employee during their time with the organization must be returned in good working condition, no later than the last day of employment. This includes laptops, mobile devices, credit cards, keys, security badges, and any other HRC materials.

REIMBURSEMENTS & BENEFITS

TUITION REIMBURSEMENT AND LOAN ASSISTANCE

SCOPE

This policy applies to all full-time HRC employees in good standing who have completed at least six months of employment.

PURPOSE

The purpose of this policy is to establish HRC’s guidelines and procedures for providing eligible employees with tuition reimbursement and interest-free loan assistance for the purpose of making tuition payments.

POLICY

HRC maintains a tuition reimbursement and student loan assistance program for employees whose educational expenses directly relate to their HRC job responsibilities, as outlined in their job description.

Employees who have completed at least six months of employment and are in good standing are eligible for tuition reimbursement for classes that begin after the employee’s first six months with HRC. HRC will refund a percentage of tuition fees upon the employee’s satisfactory completion of a course that will enhance their job-related skills and/or competencies, as determined by their manager and People Strategy. Courses must be provided by an accredited institution of higher learning.

Satisfactory completion requires a minimum grade of B / 3.0 / 86% or passing in a pass/fail course. With prior approval, HRC will reimburse up to 50% of the cost of any qualifying course, up to $5250 per year per employee, in accordance with IRS law. Tuition reimbursement that does not exceed the IRS limit is generally not considered taxable income to the employee.

Employees who are eligible for this program may request a loan for HRC’s contribution to a course’s tuition, not to exceed 50%. The loan will be subject to the following conditions:

• Prior to registering for the course, the employee must notify their manager and People Strategy of their request for tuition reimbursement and loan assistance by submitting a completed Tuition Reimbursement form and Tuition Loan Agreement and Promissory Note. Both documents are available in the Benefits section on the company’s intranet. The course description and the employee’s job description must also be provided. Employees should submit their documents well in advance of course registration deadlines to allow for HRC processing time.

• By submitting the above documents, the employee acknowledges that HRC will withhold loan repayment amounts over eight pay periods if the employee does not satisfactorily complete the course. Similarly, HRC will withhold any outstanding loan balance from the employee’s final paycheck in the event of separation from HRC, for any reason, prior to completing the course.

• The loan will be interest-free between the date it is issued and the date that grades are reasonably expected.

• The loan will be forgiven when the employee provides evidence of having satisfactorily completed the course with the required grade. Only an official report card or transcript from the accredited institution will be accepted as evidence of satisfactory completion and must be provided immediately upon receipt.

• Tuition reimbursement and loan assistance will be provided for up to 50% of the cost of tuition only. Additional expenses such as text books, course materials, registration fees, transportation, etc. are the responsibility of the employee.

BENEFIT PROGRAMS

HRC strives to offer exceptional benefit programs to meet the needs of you and your family. The Benefits brochure can be found on the company’s intranet under Benefits.

For eligible employees, coverage in many HRC-sponsored benefit programs begins on the first day of employment. New employees must complete all enrollment paperwork for their selected benefits within the first 30 days of employment. New health insurance rates are posted at the beginning of each plan year; April 1st. For more information on all available benefits, please refer to the Benefits brochure