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NEW YORK ADDENDUM—For New York Employees Only

To our New York employees: please note that wherever New York law provides for or offers greater protections to our employees, New York law will govern. All of the policies set forth below may not be applicable to all employees. Please contact a member of the Human Resources Department if you have any questions about any policies in this Addendum.

** IMPORTANT: Disclaimer of Contractual Obligation and Reservation of Rights **

This Handbook does not (i) create a contract, express or implied, guaranteeing you employment at Citadel for any specific duration, (ii) constitute a promise on which you have the right to rely, or (iii) alter the at-will employment relationship between you and the Firm. Nor does this Handbook, in describing Citadel’s policies or procedures, commit the Firm to follow any particular procedure in the course of imposing discipline or terminating employment.
Citadel expressly reserves the right, without prior notice, to change, modify or rescind any of the policies, procedures, and programs described in this Handbook or on the Intranet, in its sole and absolute discretion, with or without notice.
In jurisdictions where employment is “at-will”, you or Citadel may terminate your employment at any time and for any reason, with or without cause or notice (subject to your contractual and/or applicable statutory notice obligations).

Table of Contents

New York Paid Family Leave..................................................................................................... 2

Meal Periods ............................................................................................................................... 2

Sexual Harassment Prevention Policy ........................................................................................ 2

Prohibition of discrimination based on reproductive health decision making ............................ 5

New York HERO Act – Airborne Infectious Disease Exposure Prevention Plan ....................... 6

New York City, New York Employees Only ............................................................................. 14

Accommodating Employees in the Workplace ......................................................................... 14

Lactation Accommodation Policy.............................................................................................. 14

Use of Lactation Room ............................................................................................................. 14

Lactation Accommodation Request Process ............................................................................. 15

Undue Hardship ........................................................................................................................ 15

New York Paid Family Leave

For additional information on New York Paid Family Leave please refer to the My Benefits tab on the Intranet.

Meal Periods

An employee who works a shift of more than 6 hours which extends over the noon meal period (11 a.m. to 2 p.m.) is entitled to a 30 minute meal period to be taken between 11 a.m. and 2 p.m. If an employee starts his or her shift before 11 a.m. and continues after 7 p.m., the employee is entitled to both the 30 minute noon meal period and an additional 20 minute break between 5 p.m. and 7 p.m. The 30 minute meal period will be unpaid and employees will be required to record the starting and ending time of the 30 minute break.

An employee who works a shift of more than 6 hours starting between the hours of 1:00 p.m. and 6:00 a.m. is entitled to a meal period of at least 45 minutes in the middle of his or her shift. The 45 minute meal period will be unpaid and employees will be required to record the starting and ending time of the 45 minute meal break.

Sexual Harassment Prevention Policy

The Company is committed to a discrimination-free work environment, which includes maintaining a workplace free from all types of harassment, including sexual harassment. This policy supplements the Company’s Policy Against Discrimination, Harassment and Retaliation.

Scope

This policy, as well as New York State law, applies to all employees, applicants for employment, interns (paid or unpaid), non-employees, and persons conducting business with the Company, regardless of immigration status (“Covered Individuals”). A non-employee is someone who is (or who is employed by) a contractor, subcontractor, vendor, consultant, intern (paid or unpaid), or anyone providing services in the workplace. Notwithstanding the application of this policy to such individuals, nothing herein creates an employment relationship.

Unlawful sexual harassment is not limited to the physical workplace itself. It can occur, for example, while Covered Individuals are traveling for business or at employer-sponsored events or parties. Calls, texts, emails, and social media usage by Covered Individuals can constitute unlawful workplace harassment, even if they occur away from the workplace, on personal devices, or outside of work hours.

All employees must review this policy and commit to maintaining a work environment free from sexual harassment. In addition, all employees must complete annual sexual harassment training. An employee’s failure to comply with this policy and/or failure to complete annual training may result in appropriate remedial and/or disciplinary action, up to and including termination of employment.

Supervisory Responsibilities

All supervisors and managers who receive a complaint or information about suspected sexual harassment, observe what may be sexually harassing behavior, or for any reason suspect that sexual harassment is occurring are required to report such suspected sexual harassment to their manager or Human Resources Representative.

A supervisor’s or manager’s failure to report such conduct may result in disciplinary action, up to and including termination of employment. Supervisors and managers may also be subject to disciplinary action if they engage in, or in any way condone, sexually harassing conduct. Supervisors and managers will also be subject to discipline, up to and including termination of employment, for engaging in retaliation.

Reporting Sexual Harassment

Preventing sexual harassment is everyone’s responsibility. The Company cannot prevent or remedy sexual harassment unless it knows about it. Any Covered Individual who has been subjected to behavior that may constitute sexual harassment, or anyone who witnesses or becomes aware of potential instances of sexual harassment, should report such behavior to a manager or Human Resources representative.

Reports of sexual harassment may be made verbally or in writing. A form for submission of a complaint is available on the Intranet (“Complaint Form”). All Covered Individuals are encouraged to use this Complaint Form. Covered Individuals who report sexual harassment on behalf of others are encouraged to use the Complaint Form and note that it is on another person’s behalf. If a complaint is verbal, the individual making the complaint is encouraged to complete the Complaint Form in writing. If he or she refuses, the person receiving the complaint should prepare a Complaint Form based on the verbal reporting.

Any Covered Individual who engages in sexual harassment or retaliation will be subject to remedial and/or disciplinary action, up to and including termination of employment or a business relationship, or other appropriate remedy.

Investigation of Sexual Harassment

All complaints or information (whether submitted verbally or in writing) about sexual harassment will be investigated. An investigation of any complaint, information, or knowledge of suspected sexual harassment will be prompt and thorough, and the Company will strive to complete its investigation in a timely manner. Information will be shared on a need-to-know basis only; however, others named or who may have information about the complaint will be notified and will have an opportunity to supply relevant information. The investigation will be conducted in a way that is impartial and fair to all participants.

All Covered Individuals are required to cooperate in an investigation of suspected sexual harassment. Covered Individuals who participate in any investigation will not be retaliated against.

While the process may vary from case to case, investigations will generally be completed in accordance with the following steps:

Upon receipt of a complaint, Human Resources will conduct an immediate review of the allegations, and may take any interim actions as deemed appropriate.
Human Resources will request and review all relevant documents, including all electronic communications, and will take appropriate steps to preserve all documents, e-mails, and/or phone records relevant to the investigation.
Human Resources will interview all relevant parties involved, including any relevant witnesses.
Human Resources will create written documentation of the investigation, which may contain the following:
- A list of all documents reviewed, along with a detailed summary of relevant documents;
- A list of names of those interviewed, along with a detailed summary of their statements;
- A timeline of events;
- A summary of prior relevant incidents, reported or unreported; and
- The basis for the decision and final resolution of the complaint, together with any corrective action(s).
Human Resources will take appropriate steps to keep written documentation and associated documents in the Company’s secure and confidential files.

Upon completion of the investigation, a determination will be made as to whether the conduct at issue violates the policy, and/or the nature of the disciplinary action or other corrective measures, if any, to be imposed. Human Resources will notify the reporting individual and the individual(s) about whom the complaint was made, and any corrective actions will be implemented promptly.

Legal Protections and External Remedies

All Covered Individuals have a legal right to a workplace free from sexual harassment, and in addition to the internal process at the Company, Covered Individuals may also enforce this right by filing a complaint with a government agency or by pursuing available remedies in court under federal, state, or applicable local antidiscrimination laws. There is no cost to file with these governmental agencies.

Each of the agencies listed below can conduct impartial investigations, facilitate conciliation, and if the agency finds that there is probable cause or reasonable grounds to believe sexual harassment occurred, it may take the case to court or hearing and/or award relief, which varies but may include requiring the Company to take action to stop the harassment, or redress the damage caused, including payment of monetary damages, attorney’s fees and civil fines. Courts may also award remedies if a violation of law is found.

Complaints with the New York State Division of Human Rights, United States Equal Employment Opportunity Commission, and the New York City Commission on Human Rights are subject to applicable statute of limitations. In addition, a complainant also has the right to hire a private attorney, and to pursue a private legal action in federal or state court in accordance with the applicable procedural requirements and within the applicable statute of limitations. Complaining internally to the Company does not extend your time to file with an agency or in court. The contact information for each of these agencies is set forth below.

New York State Division of Human Rights One Fordham Plaza, Fourth Floor, Bronx, New York 10458 (888) 392-3644 or (718) 741-8400 www.dhr.ny.gov or www.dhr.ny.gov/complaint	United States Equal Employment Opportunity Commission (EEOC) The EEOC has district, area, and field offices where complaints can be filed. 1-800-669-4000 (TTY: 1-800-669-6820) E-mail: info@eeoc.gov www.eeoc.gov

New York City Commission on Human Rights Law Enforcement Bureau of the NYC Commission on Human Rights 40 Rector Street, 10th Floor New York, New York 10006 311 or (212) 306-7450 www.nyc.gov/html/cchr/html/home/home.shtml	The Local Police Department If the harassment involves unwanted physical touching, coerced physical confinement or coerced sex acts, the conduct may constitute a crime. Contact the local police department

Prohibition of discrimination based on reproductive health decision making

The Company prohibits harassment, discrimination, or retaliation against an employee with respect to compensation, terms, conditions, or privileges of employment because of or on the basis of the employee's or dependent's reproductive health decision making, including, but not limited to, a decision to use or access a particular drug, device or medical service. The Company prohibits any practice when it subjects an individual to inferior terms, conditions or privileges of employment because of the employee’s or employee’s dependent’s reproductive health decisions. The Company prohibits anyone from requiring that an employee to sign a waiver or other document which purports to deny an employee the right to make their own reproductive health care decisions, including use of a particular drug, device, or medical service. The Company will not access an employee's personal information regarding the employee's or the employee's dependent's reproductive health decision making, including but not limited to, the decision to use or access a particular drug, device or medical service without the employee's prior informed affirmative written consent.

Complaint and Reporting Procedure

Employees must immediately report any violation or suspected violation of this policy to their manager and Human Resources. All supervisors and managers are required to report any such information or complaints to Human Resources.

An employee may bring a civil action in court. If a violation of an employee’s reproductive health rights has been found, the court has the power to award damages and other available relief.

Retaliation Prohibited

The Company, as well as applicable state law, strictly prohibits discrimination and retaliation against anyone who, in good faith, reports or provides information about suspected violation of this policy. For purposes of this policy, retaliation or retaliatory personnel action means discharging, suspending, demoting, or otherwise penalizing an employee for: (a) making or threatening to make, a complaint to an employer, co-worker, or to a public body, that rights related to reproductive health decisions have been violated; (b) causing to be instituted any proceeding under or related to this section; or (c) providing information to, or testifying before, any public body conducting an investigation, hearing, or inquiry into any such violation of a law, rule, or regulation by such employer.

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

New York HERO Act – Airborne Infectious Disease Exposure Prevention Plan

The purpose of this plan is to protect employees against exposure and disease during an airborne infectious disease outbreak. This plan goes into effect when an airborne infectious disease is designated by the New York State Commissioner of Health as a highly contagious communicable disease that presents a serious risk of harm to the public health. This plan is subject to any additional or greater requirements arising from a declaration of a state of emergency due to an airborne infectious disease, as well as any applicable federal standards.

Employees should report any questions or concerns with the implementation this plan to the designated contact.

I. RESPONSIBILITIES

This plan applies to all employees of Citadel Americas Services LLC, Citadel Securities Americas Services LLC, and Citadel Enterprise Americas Services LLC (collectively, “Citadel”), at the following work sites:

60l Lexington Avenue, New York, New York 10022
350 Park Avenue, New York, New York 10022
140 Broadway Avenue, New York, New York 10022
520 Madison Avenue, New York, New York 10022
880 Third Avenue, New York, New York 10022

In furtherance of Citadel’s commitment to ensure compliance with all plan elements aimed at preventing the spread of infectious disease, the following supervisory employee(s) are designated to enforce compliance with the plan. Additionally, these supervisory employees will act as the designated contacts unless otherwise noted in this plan:

Name	Title	Location	Phone/Email
Fallon Sullivan	CItadel, Office of the COO	Chicago, IL	312-593-0910/ Fallon.Sullivan@Citadel.com

II. EXPOSURE CONTROLS DURING A DESIGNATED OUTBREAK

A. MINIMUM CONTROLS DURING AN OUTBREAK

During an airborne infectious disease outbreak, the following minimum controls will be used in all areas of the worksite:

1. General Awareness: Individuals may not be aware that they have the infectious disease and can spread it to others. Employees should remember to:

- - - Maintain physical distancing;
    - Exercise coughing/sneezing etiquette;
    - Wear face coverings, gloves, and personal protective equipment (PPE), as appropriate;
    - Individuals limit what they touch;
    - Limit physical contact including behaviors such as hugging and hand shaking, and
    - Wash hands properly and often.

2. “Stay at Home Policy”: If an employee develops symptoms of the infectious disease, the employee should not be in the workplace. The employee should inform the designated contact and follow New York State Department of Health (NYSDOH) and Centers for Disease Control and Prevention (CDC) guidance regarding obtaining medical care and isolating.

3. Health Screening: Employees will be screened (which may include either on-site screening or at-home screening , as instructed) for symptoms of the infectious disease at the beginning of their workday. Employees are to self-monitor throughout their workday and report any new or emerging signs or symptoms of the infectious disease to the designated contact. An employee showing signs or symptoms of the infectious disease should be removed from the workplace and should contact a healthcare professional for instructions. The health screening elements will follow guidance from NYSDOH and CDC guidance, if available.

4. Face Coverings: To protect your coworkers, employees will wear face coverings throughout the workday to the greatest extent possible, as necessary. Face coverings and physical distancing should be used together whenever possible. The face covering must cover the nose and mouth, and fit snugly, but comfortably, against the face. The face covering itself must not create a hazard, e.g. have features could get caught in office equipment or cause severe fogging of eyewear. The face coverings must be kept clean and sanitary and changed when soiled, contaminated, or damaged.

5. Physical Distancing: Physical distancing will be followed as much as feasible. Avoid unnecessary gatherings and maintain a distance of at least six feet (or such distance as recommended by the NYSDOH, CDC, or other medical advisors for the infectious agent) from each other. Use a face covering when physical distance cannot be maintained.

In situations where prolonged close contact with other individuals is likely, Citadel will use the following control methods:

- - - - restricting or limiting client or visitor entry;
      - limiting occupancy;
      - allowing only one person at a time inside small enclosed spaces with poor ventilation;
      - reconfiguring workspaces;
      - signage;
      - floor markings;
      - telecommuting;
      - remote meetings;
      - preventing gatherings;
      - restricting travel;
      - creating new work shifts and/or staggering work hours;

6.Hand Hygiene: To prevent the spread of infection, employees should wash hands with soap and water for at least 20 seconds or use a hand sanitizer with at least 60% alcohol to clean hands BEFORE and AFTER:

- - - - Touching your eyes, nose, or mouth;
      - Touching your mask;
      - Entering and leaving a public place; and
      - Touching an item or surface that may be frequently touched by other people, such as door handles, tables, or electronic screens.
        Because hand sanitizers are less effective on soiled hands, wash hands rather than using hand sanitizer when your hands are soiled.
  - 7. Cleaning and Disinfection: See Section III of this plan.
  - 8. “Respiratory Etiquette”: Because infectious diseases can be spread by droplets expelled from the mouth and nose, employees should exercise appropriate respiratory etiquette by covering nose and mouth when sneezing, coughing or yawning.
- - 9. Special Accommodations for Individuals with Added Risk Factors: Some employees, due to age, underlying health condition, or other factors, may be at increased risk of severe illness if infected. Please inform Human Resources directly if you fall within this group and need an accommodation.

B. ADVANCED CONTROLS DURING AN OUTBREAK

For activities where the Minimum Controls alone will not provide sufficient protection for employees, additional controls from the following hierarchy may be necessary. In the event of an outbreak, Citadel will determine if the following are necessary:

1. Elimination: In the event of an outbreak, Citadel will consider the temporary suspension or elimination of risky activities where adequate controls could not provide sufficient protection for employees.

2. Engineering Controls: Citadel will consider appropriate controls to contain and/or remove the infectious agent, prevent the agent from being spread, or isolate the worker from the infectious agent. Examples of engineering controls include:

i. Mechanical Ventilation:

ii. General Ventilation:

iii. Natural Ventilation:

Subject to changes based on operations and circumstances surrounding the infectious disease, engineering controls that are anticipated to be used are listed in the following table:

Engineering Controls Utilized/Location (Where Possible):

Increasing the percentage of fresh air introduced into air handling systems;
Avoiding air recirculation;
Using higher-efficiency air filters in the air handling system;
If fans are used in the facility, arrange them so that air does not blow directly from one worker to another; and
Installation of automatic disinfection systems (e.g., ultraviolet light disinfection systems).
Installation of cleanable barriers such as partitions and/or clear plastic sneeze/cough guards at open work stations.
Modification of layout to avoid points or areas where employees may congregate.

3. Administrative Controls: Policies and work rules used to prevent exposure.

Subject to changes based on operations and circumstances surrounding the infectious disease, the following specific administrative controls are anticipated to be used:

Administrative Controls Utilized (Where Possible):

Increasing the space between employees
Employee training
Identification and prioritization of job functions for which on-site presence is essential for continuous operations
Cross-training employees to ensure critical operations can continue during worker absence;
Limiting the use of shared workstations
Posted reminders of respiratory etiquette, masks, handwashing
Rearrangements to traffic flow to allow for one-way walking paths to the extent practical
Providing clearly designated entrances and exits
Allowing additional short breaks for handwashing and cleaning

4. Personal Protective Equipment (PPE) will be provided, used and maintained in a sanitary and reliable condition at no cost to the employee. The PPE that are anticipated to be used are :

PPE Required - Activity Involved:

Cloth or paper face masks or face coverings that cover the user’s nose and mouth.
Any other PPE deemed necessary or recommended, as applicable, by the state Department of Health for individuals in an office setting.

All personal protective equipment, including employee-owned personal protective equipment used at the worksite, shall be stored, used and maintained in a sanitary and reliable condition in order to be used at the worksite.

C. EXPOSURE CONTROL READINESS, MAINTENANCE AND STORAGE:

The controls we have selected will be obtained, properly stored, and maintained so that they are ready for immediate use in the event of an infectious disease outbreak and any applicable expiration dates will be properly considered.

CLEANING AND DISINFECTION (HOUSEKEEPING) DURING A DESIGNATED OUTBREAK

A. Disinfection Methods and Schedules

Objects that are touched repeatedly by multiple individuals, such as door handles, light switches, control buttons/levers, dials, levers, water faucet handles, computers, phones, or handrails must be cleaned frequently with an appropriate disinfectant. Surfaces that are handled less often, or by fewer individuals, may require less frequent disinfection.

The disinfection methods and schedules selected shall be based on specific workplace conditions. Surfaces known or believed to be contaminated with potentially infectious materials shall be cleaned and disinfected immediately or as soon as feasible, unless the area and surfaces can be isolated for a period of time prior to cleaning.

Surfaces contaminated with dust or other loose materials shall be wiped clean prior to disinfection, and the cleaning methods used should minimize dispersal of the dust and loose materials into the air.

Frequently touched surfaces, such as handrails and doorknobs, shall be disinfected throughout the workday and/or as recommended by the state Department of Health, the Centers for Disease Control and Prevention, or other medical advisors.

Shared tools, equipment and workspaces shall be cleaned and disinfected prior to sharing and/or as recommended by the state Department of Health or the Centers for Disease Control and Prevention, or other medical advisors.

Common areas, such as breakrooms, shall be cleaned and disinfected at least daily, or as recommended by the state Department of Health or the Centers for Disease Control and Prevention, or other medical advisors.

The New York State Department of Environmental Conservation (NYSDEC) and the Environmental Protection Agency (EPA) have compiled lists of approved disinfectants that are effective against many infectious agents (see dec.ny.gov and epa.gov/pesticide-registration/selected-epa-registered-disinfectants). Contracted cleaning personnel will be expected to select disinfectants based on NYSDOH, CDC, and other medical advisor guidance and follow manufacturer guidance for methods, dilution, use, and contact time.

B. Adjustments to Normal Cleaning and Disinfection (Housekeeping) Procedures

Normal office cleaning protocols will continue to be followed during an infectious disease outbreak, to the extent practicable and appropriate consistent with NYSDOH and/or CDC guidance in effect at the time. However, routine procedures may need to be adjusted and additional cleaning and disinfecting may be required.

C. If an employee develops symptoms of the infectious disease at work, it is ideal to isolate the area in accordance with guidance issued by NYSDOH or the CDC, before cleaning and disinfecting the sick employee’s work area. This delay will allow contaminated droplets to settle out of the air and the space to be ventilated.

D. As feasible, liners should be used in trash containers. Containers will be emptied often enough to prevent overfilling. Employees should refrain from forcefully squeezing the air out of trash bags before tying them closed. Trash containers may contain soiled tissue or face coverings.

IV. INFECTION RESPONSE DURING A DESIGNATED OUTBREAK

If an actual, or suspected, infectious disease case occurs at work, Citadel will take the following actions:

Instruct the sick individual to wear a face covering and leave the worksite and follow NYSDOH/CDC guidance.
Follow local and state authority guidance to inform impacted individuals.

V. TRAINING AND INFORMATION DURING A DESIGNATED OUTBREAK

A. Office of the COO will verbally inform all employees of the existence and location of this Plan, the circumstances it can be activated, the infectious disease standard, employer policies, and employee rights under the HERO Act.

B. When this plan is activated, all personnel will receive training which will cover all elements of this plan and the following topics:

1. The infectious agent and the disease(s) it can cause;
2. The signs and symptoms of the disease;
3. How the disease can be spread;
4. An explanation of this Exposure Prevention Plan;
5. The activities and locations at our worksite that may involve exposure to the infectious agent;
6. The use and limitations of exposure controls
7. A review of the standard, including employee rights provided under Labor Law, Section 218-B.

C. The training will be

1. Provided at no cost to employees and take place during working hours. If training during normal work hours is not possible, non-exempt employees will be compensated for the training time (with pay or time off);
2. Appropriate in content and vocabulary to your educational level, literacy, and preferred language; and
3. Verbally provided in person or through telephonic, electronic, or other means

VI. PLAN EVALUATIONS DURING A DESIGNATED OUTBREAK
Citadel will review and revise the plan periodically, upon activation of the plan, and as often as needed to keep up-to-date with current requirements. Any such revisions will be documented below:

Plan Revision History

Date Participants Major Changes Approved By

VII. RETALIATION PROTECTIONS AND REPORTING OF ANY VIOLATIONS

Concerns regarding violations of this plan and retaliation may be reported during regular business hours and on weekends/other non-regular business hours to the individual(s) identified in Section I of this plan. Notification of a violation by an employee may be made verbally or in writing, and without limitation to format including electronic communications. To the extent that communications between Citadel and an employee regarding a potential risk of exposure are in writing, they shall be maintained by Citadel for two years after the conclusion of the designation of a high risk disease from the Commissioner of Health, or two years after the conclusion of the Governor’s emergency declaration of a high risk disease.

In accordance with New York law, no employer, or his or her agent, or person, acting as or on behalf of a hiring entity, or the officer or agent of any entity, business, corporation, partnership, or limited liability company, shall discriminate, threaten, retaliate against, or take adverse action against any employee for exercising their rights under this plan, including reporting conduct the employee reasonably believes in good faith violates the plan or airborne infectious disease concerns to their employer, government agencies or officials or for refusing to work where an employee reasonably believes in good faith that such work exposes him or her, other workers, or the public to an unreasonable risk of exposure, provided the employee, another employee, or representative has notified the employer verbally or in writing, including electronic communication, of the inconsistent working conditions and the employer’s failure to cure or if the employer knew or should have known of the consistent working conditions.

New York City, New York Employees Only

Accommodating Employees in the Workplace

The Company complies with New York City law as it relates to the reasonable accommodation process for employees needing reasonable accommodations for a covered disability, religious belief, pregnancy, childbirth or related medical condition, or as a victim of domestic violence, sex offenses and stalking. New York City’s law is broader than the American with Disabilities Act and the Company complies with the reasonable accommodation obligations applicable to employees in New York City.

The Company will engage in the interactive process and will have a cooperative dialogue with respect to accommodations requested. The interactive process may be in writing or orally depending on the particular situation. The “cooperative dialogue” constitutes a good faith discussion between the employee and Company concerning the employee’s accommodation needs; potential accommodation that may address the employee’s need for an accommodation; and any undue hardships or other difficulties that the potential accommodation may pose on the Company. At the conclusion of the interactive process, the Company will provide an employee a determination in writing on the request for reasonable accommodation that will indicate the accommodation requests that have either been granted or denied.

No employee will be subject to retaliation for requesting or obtaining a reasonable accommodation under this policy.

Lactation Accommodation Policy

In accordance with the New York City Human Rights Law, the Company provides reasonable accommodations for employees' pregnancy, childbirth, or other related medical conditions, including accommodations for lactation. Before an employee returns from parental leave, the Company will seek to discuss with the employee whether the employee needs a reasonable accommodation to express breast milk at work.

The Company will not tolerated discrimination or harassment against any employee based on the request for or usage of lactation accommodations. Any discrimination, harassment, or other violations of this policy can be reported to the Company’s Human Resources Department.

Use of Lactation Room
The location of all dedicated lactation rooms are posted on Citadel’s Intranet site.
The lactation room is: clean; is free from intrusion and shielded from view of others; contains at least one electrical outlet, a surface to place a pump and other personal items, and a chair; is near running water (i.e., for washing hands and/or cleaning breast pump parts); and can be locked from the inside.
When more than one employee needs to use the designated lactation room, the Company will discuss various options with all employees who use the lactation room to determine what arrangement addresses each employee's needs such that each employee has access to the lactation room amenities. Options may include: finding an alternative clean space free from intrusion; sharing the space among multiple users; or creating a schedule for use. Any accommodation will ensure each employee is afforded a reasonable amount of time to pump.
The Company will provide a reasonable amount of time for an employee to express breast milk and will not unreasonably limit the amount of time or the frequency that an employee expresses breast milk. The Company will speak with the employee to determine a schedule of breaks that reasonably accommodates the pumping needs of the employee.

Lactation Accommodation Request Process
Before an employee returns from parental leave, the Company will resend this policy to the employee in writing (electronically or by mail) and request information from the employee regarding the need for a reasonable accommodation to express breast milk at work.
Employees may also independently request a lactation accommodation by contacting Human Resources.
Management will respond to a request for a lactation accommodation as quickly as possible. Under no circumstances will this amount of time exceed five (5) business days.
The Company recognizes that employees' lactation accommodation needs may change over time. Employees may request changes to their existing lactation accommodation at any point.

Undue Hardship
If the Company believes that the lactation accommodation requested poses an undue hardship on the business, the Company will discuss reasonable alternatives with the employee to accommodate the employee's needs, initiating a cooperative dialogue as quickly as possible, but absolutely no later than five (5) business days from the date of the request. The conversation between the Company and the employee will be in good faith, may occur orally or in writing, and will conclude with a final written determination of the accommodation granted or denied.
During the time it takes to respond to a request and/or engage in a cooperative dialogue to determine the accommodation, the Company will provide a temporary accommodation to the employee so that the employee can pump in a manner that meets the employee's immediate needs unless doing so poses an undue hardship.