1.1 This policy establishes the Organization's mandatory procedures for using E-Verify, the internet-based system operated by the U.S. Department of Homeland Security (DHS) in partnership with the Social Security Administration (SSA), to electronically verify the identity and employment authorisation of all newly hired employees in the United States. The Organization participates in E-Verify in compliance with applicable federal requirements, including the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA), Executive Order 12989 as amended, and any applicable state E-Verify mandate in effect in the jurisdictions where the Organization operates. This policy applies to all new hires at every U.S. location, regardless of position level, employment type, or citizenship status. The Organization shall not use E-Verify for pre-employment screening or to discriminate against any individual based on national origin, citizenship status, or immigration status.

1.2 The Organization shall comply with all E-Verify Memorandum of Understanding (MOU) requirements and federal regulations governing the program. Key compliance obligations include completing Section 1 of Form I-9 on or before the employee's first day of employment and Section 2 within 3 business days of the start date; submitting an E-Verify case for each new hire no later than the third business day after the employee begins work for pay; accepting any document or combination of documents from the Lists of Acceptable Documents presented by the employee, without specifying or preferring particular documents based on citizenship or national origin; following the referral and appeal procedures for Tentative Nonconfirmation (TNC) results as prescribed by DHS and SSA; and maintaining all required records, including Form I-9 and E-Verify case results, for the applicable retention period. The Organization shall display the required E-Verify participation poster and the Right to Work poster in English and Spanish at all U.S. hiring locations.

1.3 The HR department shall serve as the sole administrator of the Organization's E-Verify account, and the Head of Human Resources shall designate specific trained individuals as authorised E-Verify users. Only authorised users who have completed the E-Verify tutorial and passed the associated knowledge test shall create E-Verify cases, review case results, take action on Tentative Nonconfirmations, or close cases. Authorised user access shall be reviewed quarterly, and access shall be promptly revoked for individuals who leave the HR department or the Organization. The Organization shall maintain a log of all authorised E-Verify users, including the date of their training completion and the date their access was granted or revoked. No Hiring Manager, supervisor, or non-HR employee shall independently access or operate the E-Verify system.

2.1 Every new hire shall complete Section 1 of Form I-9, Employment Eligibility Verification, on or before their first day of employment for pay. The HR department shall ensure that the employee is provided with the current version of Form I-9, the Lists of Acceptable Documents, and instructions for completing Section 1. The employer representative shall complete Section 2 of Form I-9 within 3 business days of the employee's first day of work by physically examining original, unexpired documents from the Lists of Acceptable Documents presented by the employee. The employer representative shall not request specific documents, suggest which documents the employee should present, reject documents that reasonably appear to be genuine and relate to the employee, or require more documents than the minimum required. For remote hires, the Organization shall utilize an authorised representative to conduct the physical document examination in compliance with DHS guidance, or shall use any alternative procedures authorised by DHS for remote verification.

2.2 An E-Verify case shall be created for each new hire no later than the third business day after the employee's first day of employment for pay. The authorised E-Verify user shall enter the employee's information exactly as it appears on the Form I-9 into the E-Verify system, including the employee's legal name, date of birth, Social Security number, citizenship or immigration status, and the document information from Section 2. The user shall verify that all data entered matches the Form I-9 before submitting the case. E-Verify cases shall not be created before the employee has accepted the offer and begun work, and shall not be created selectively for certain employees based on national origin, ethnicity, or perceived immigration status. The Organization shall process E-Verify cases for all new hires uniformly and without discrimination.

2.3 The Organization shall maintain completed Forms I-9, E-Verify case verification results, Tentative Nonconfirmation notices and referral letters, and any supporting correspondence for each employee for a period of 3 years after the date of hire or 1 year after the date of termination, whichever is later. Forms I-9 and associated documentation shall be stored in a secure, access-controlled system separate from general personnel files. The HR department shall conduct an annual audit of Form I-9 and E-Verify records to verify completeness, accuracy, and proper retention. Records that have reached the end of their retention period shall be securely destroyed in accordance with the Organization's records retention and destruction policy. The Organization shall be prepared to present Forms I-9 and E-Verify records to authorised government officials upon request with 3 business days' notice, as required by law.

2.4 The Organization shall conduct a comprehensive internal I-9 audit at least annually, reviewing a statistically representative sample of not fewer than 25 percent of all active Forms I-9 or the entirety of the I-9 inventory if the workforce is fewer than 200 employees. The audit shall verify that Section 1 was completed on or before the first day of employment, Section 2 was completed within 3 business days, all required fields are populated and accurate, acceptable documents were properly recorded, re-verification was completed timely for employees with expiring work authorisation, and E-Verify cases were submitted within the required timeframe. Errors identified during the audit shall be corrected in accordance with USCIS guidance for making corrections to Form I-9, including initialling and dating any changes without using correction fluid or back-dating. The audit findings shall be compiled into a written report, reviewed by Legal Counsel, and presented to the Head of Human Resources with recommended corrective actions within 30 days of audit completion.

3.1 If E-Verify returns a Tentative Nonconfirmation (TNC) result, the authorised E-Verify user shall promptly notify the employee of the TNC in a private setting, no later than the next business day after receiving the TNC. The employee shall be provided with the system-generated Further Action Notice in the language of their choice (English or Spanish) and shall be informed of their right to contest the TNC with the issuing agency (SSA or DHS) within 8 federal government working days. The employee shall sign the Further Action Notice indicating whether they choose to contest or not contest the TNC. The Organization shall not take any adverse employment action against the employee based on the TNC, including termination, suspension, reduction in hours, reassignment to less favourable duties, or withholding pay, while the case is pending resolution. The employee shall continue to work under the same terms and conditions as any other employee during the contest period.

3.2 If the employee elects to contest the TNC, the authorised E-Verify user shall refer the case through the E-Verify system within the required timeframe, and the employee shall visit the relevant agency (SSA office or contact DHS) within 8 federal government working days to resolve the discrepancy. The employee shall continue to work without restriction during the contest and resolution period, which may take up to 120 days or longer for DHS cases. The E-Verify user shall monitor the case status regularly and take action on any system prompts within the required timeframes. If E-Verify returns an Employment Authorised result after the employee contests the TNC, the case shall be closed with a confirmed employment authorisation status. If E-Verify returns a Final Nonconfirmation result, the Organization shall terminate the employee's employment promptly, as continued employment is not permitted under the E-Verify MOU. The termination shall be conducted respectfully and in compliance with applicable employment law.

3.3 If the employee chooses not to contest the TNC by indicating 'No' on the Further Action Notice, or fails to visit the relevant agency within the 8-federal-government-working-day window after electing to contest, the Organization shall close the E-Verify case as a Final Nonconfirmation and shall terminate the employee's employment. The termination shall be conducted in a private meeting with the employee, attended by an HR representative, and documented in writing. The employee shall be paid for all hours worked through the date of termination, and all final pay shall be processed in accordance with applicable state wage payment laws. The Organization shall provide the employee with written notification of the reason for termination and information regarding any applicable appeal rights. All TNC and Final Nonconfirmation documentation shall be retained with the employee's Form I-9 records for the required retention period.

4.1 The Organization shall implement the following anti-discrimination safeguards in its E-Verify program: E-Verify shall not be used to pre-screen applicants or job candidates before they have accepted an offer of employment and begun work for pay; E-Verify cases shall be submitted for all new hires uniformly and shall not be selectively applied to employees based on national origin, citizenship status, ethnicity, race, or any other protected characteristic; the Organization shall not request or prefer specific documents from the Lists of Acceptable Documents based on an employee's citizenship status, national origin, or appearance, and shall accept any valid combination of documents the employee chooses to present; the Organization shall not re-verify employment eligibility for employees with unexpired work authorisation except as required when authorisation documents expire; and the Organization shall not use E-Verify for existing employees unless required by a federal contract or applicable state law.

4.2 All HR personnel and authorised E-Verify users involved in the Form I-9 completion and E-Verify process shall complete mandatory anti-discrimination training within 30 calendar days of assuming their role and annually thereafter. The training shall cover the anti-discrimination provisions of the Immigration and Nationality Act (INA) as enforced by the Department of Justice, Immigrant and Employee Rights Section (IER), including prohibitions against citizenship status discrimination, national origin discrimination, document abuse and unfair documentary practices, and retaliation against employees who assert their rights under the INA. The training shall also cover proper procedures for examining identity and work authorisation documents without over-documenting or under-documenting, and the legal consequences of E-Verify-related discrimination, including civil penalties of up to $2,507 per individual for unfair immigration-related employment practices. Training completion shall be documented and retained by the HR department.

4.3 Any employee or applicant who believes they have been subjected to discrimination, document abuse, or retaliation in connection with the Form I-9 or E-Verify process may file a complaint through any of the Organization's internal reporting channels, including the HR department, the designated Compliance Officer, or the confidential ethics and compliance hotline. The Organization shall investigate all internal complaints within 15 business days and shall take corrective action where a violation is substantiated. In addition, affected individuals have the right to file a complaint directly with the Department of Justice, Immigrant and Employee Rights Section (IER) by calling 1-800-255-7688 or filing online at the IER website. The Organization shall post information about these external reporting options alongside the required E-Verify and Right to Work posters at all U.S. hiring locations. Retaliation against any individual who files a complaint, whether internally or externally, is strictly prohibited.

5.1 Where the Organization holds federal contracts or subcontracts that include the FAR E-Verify clause (FAR 52.222-54), the Organization shall comply with the additional verification requirements applicable to federal contractors. These requirements include verifying new hires organization-wide within 3 business days of their start date, verifying existing employees assigned to work on covered federal contracts within 30 calendar days of their assignment to the contract, and verifying all existing employees organization-wide if the Organization has elected the all-employees option in its E-Verify MOU. The Contracts and Procurement department shall notify the HR department of all contracts containing the FAR E-Verify clause within 5 business days of contract execution. The HR department shall maintain a register of covered contracts and shall ensure that E-Verify cases for assigned employees are submitted within the required timeframes. Failure to comply with federal contractor E-Verify requirements may result in contract termination, debarment, and civil penalties.

5.2 The Organization shall comply with all applicable state E-Verify mandates in each state where it operates. State requirements vary significantly and may mandate E-Verify use for all employers, employers above a specified workforce threshold, state contractors and subcontractors, or specific industries. As of the effective date of this policy, the Organization operates in states with the following E-Verify requirements, which shall be incorporated into operational procedures: mandatory E-Verify for all employers in states such as Alabama, Arizona, Georgia, Mississippi, North Carolina, South Carolina, Tennessee, and Utah; mandatory E-Verify for state contractors in additional states. The HR department shall maintain a current inventory of state E-Verify requirements, updated at least annually and whenever the Organization expands into a new state. Legal Counsel shall be consulted before the Organization begins operations in any new state to determine applicable E-Verify obligations.

5.3 This policy shall be reviewed comprehensively at least once every 12 months by the policy owner in consultation with Legal Counsel, the Contracts and Procurement department, and the Head of Human Resources. An interim review shall be triggered by any update to DHS E-Verify program requirements, changes to federal contractor E-Verify regulations, enactment or amendment of state E-Verify mandates, findings from internal I-9 or E-Verify audits, or any government audit or investigation related to the Organization's employment verification practices. Proposed amendments shall be reviewed by Legal Counsel, approved by the Head of Human Resources and the Chief Executive Officer, and communicated to all affected HR personnel and authorised E-Verify users at least 14 calendar days before the effective date. The Organization shall maintain a complete version history of this policy as an appendix, documenting the date, author, and summary of each amendment.