Employee Resource Groups Policy

Purpose

To support a workplace where employees can form voluntary Employee Resource Groups (ERGs) — also called affinity or network groups — that build community, communication, and professional development around shared interests or identities, while making clear how these groups operate within the Company.

Policy

The Company supports a positive environment in which ERGs can function, subject to the guidelines below. Groups may not engage in unlawful activity or activity harmful to the Company or its employees.

ERGs organized around a shared interest or a protected characteristic (for example, race, sex, national origin, disability status, veteran status, sexual orientation, or gender identity) are permitted, but — consistent with current EEOC guidance on Title VII and DEI-related practices — must be open to participation by all employees regardless of whether they share that characteristic. An ERG's name or stated focus may reflect a particular community or interest, but the group itself may not restrict who can join, lead, or benefit from it based on a protected characteristic.

Formation and participation

• Participation in any ERG is entirely voluntary and is not part of an employee's job duties.
• All employees are eligible to participate in any ERG, regardless of race, sex, national origin, or any other protected characteristic; the Company does not select or screen participants, and no ERG may limit or condition membership on a protected characteristic. This applies to leadership roles and any mentoring, sponsorship, training, or similar opportunities offered through the group, not just general membership — under current EEOC guidance, segregating any of these opportunities by protected characteristic is treated the same as restricting membership itself, even where the same content or resources are made available to each group.
• No employee may be pressured to join, or not join, an ERG.
• No employee's standing with the Company may be affected, positively or negatively, by their decision to participate or not participate — ERG participation (or non-participation) must not be a factor in performance ratings, promotion, compensation, or any other employment decision.
• ERG access and participation must be consistent with the Company's equal employment opportunity policies — groups may not be used to exclude employees based on a protected characteristic in a way inconsistent with those policies, whether through formal eligibility rules or informal/unofficial encouragement or discouragement.

Communications

• Start-up phase. While a new group is forming, use only Company-approved communication channels (for example, a designated intranet page or bulletin board) so employees can learn about it and decide whether to participate. Get approval from the designated internal-communications or HR contact before posting.
• Ongoing communications. Once established, a group may use limited individual email, internal messaging, and approved posting locations for routine communication. Groups may not send company-wide mass communications, use Company letterhead, or send unsolicited messages to employees who haven't opted in.
• Scheduling tools (e.g., shared calendars) may be used for meeting logistics. Groups do not get dedicated phone lines or other dedicated infrastructure.

Use of Company resources and name

• Funding. ERGs generally operate without dedicated Company funding, unless HR determines that supporting a specific group provides a clear, direct benefit to the Company — in which case funding decisions are made by HR leadership.
• Facilities. Requests to use Company facilities or property for group activities must be approved by HR or the relevant facility/site lead.
• Use of the Company name. A group may identify its members as Company employees (for example, "[Group Name] — a Network Group of [Company] Employees"), but may not present itself as owned, controlled, or officially sponsored by the Company (for example, "[Company] [Group Name]" implies official sponsorship and should be avoided) unless the Company has formally chartered the group as an official ERG program.

What ERGs are not

• ERGs do not represent individual employees, or groups of employees, in their dealings with the Company.
• ERGs may not be used to negotiate or resolve issues related to wages, hours, or other terms and conditions of employment. Any such concerns should go through the Company's normal channels (a manager, HR, or the Company's problem-resolution/open-door process).
• ERGs may not conduct employee surveys or polls about wages, hours, or other terms and conditions of employment. Employees with such concerns should be directed to HR.

Responsibilities

Role	Responsibilities
Employees	Participate voluntarily; follow Company communication and resource-use guidelines.
HR	Approve group communications, facility use, and any funding requests; ensure ERGs operate consistently with EEO policy.
Managers	Support employee participation without pressuring for or against it.

References

• Equal Employment Opportunity policy
• Problem Resolution / Open-Door policy
• Solicitation and Distribution of Materials policy