HR Policy

ISS Action, LLC (“ISS Action” or “the Company”) is committed to conducting all business operations with integrity, fairness, and respect for the fundamental rights and dignity of every individual. This Human Rights and Labor Standards Policy (“Policy”) establishes the principles and expectations that govern our employment practices, supplier relationships, and service delivery across all contracts and locations.

This Policy applies to all ISS Action employees, officers, managers, subcontractors, and third-party partners operating under the Company’s direction or on its behalf, in every state and jurisdiction where the Company conducts business. Compliance with this Policy is a condition of employment and of any contractual relationship with ISS Action.

ISS Action operates in multiple states, including Arizona, California, New York, New Jersey, Florida, Virginia, North Carolina, Washington D.C., and others. This Policy is designed to comply with the most protective applicable federal, state, and local standards in each jurisdiction. Where any provision of this Policy conflicts with applicable law, the law shall control. Where applicable law is silent, this Policy establishes the Company’s minimum standard.

ISS Action’s human rights and labor commitments are grounded in the following internationally recognized frameworks and applicable federal, state, and local law:

INTERNATIONAL FRAMEWORKS

• The United Nations Universal Declaration of Human Rights
• The International Labour Organization (ILO) Core Conventions
• The UN Guiding Principles on Business and Human Rights

FEDERAL LAW

• The U.S. Fair Labor Standards Act (FLSA)
• Title VII of the Civil Rights Act of 1964
• The Age Discrimination in Employment Act (ADEA)
• The Americans with Disabilities Act (ADA)
• The Genetic Information Nondiscrimination Act (GINA)
• The Pregnancy Discrimination Act (PDA) and PUMP Act
• The Family and Medical Leave Act (FMLA)
• The Occupational Safety and Health Act (OSHA)
• The National Labor Relations Act (NLRA)
• The Trafficking Victims Protection Act (TVPA)
• The Uniformed Services Employment and Reemployment Rights Act (USERRA)
• The Service Contract Act (SCA), where applicable
• Federal Acquisition Regulation (FAR) labor clauses

STATE & LOCAL LAW

• Arizona: Arizona Civil Rights Act; Arizona Employment Protection Act; Arizona Fair Wages and Healthy Families Act; ARS Title 23
• California: California Fair Employment and Housing Act (FEHA); California Family Rights Act (CFRA); CCPA/CPRA; California Labor Code; Cal-OSHA; applicable local ordinances
• New York: New York State Human Rights Law (NYSHRL); New York Labor Law; New York City Human Rights Law (NYCHRL), where applicable; New York Paid Family Leave Law
• New Jersey: New Jersey Law Against Discrimination (NJLAD); New Jersey Earned Sick Leave Law; New Jersey Family Leave Act; New Jersey WARN Act
• Florida: Florida Civil Rights Act; Florida Minimum Wage Act
• Washington D.C.:C. Human Rights Act; D.C. Accrued Sick and Safe Leave Act; D.C. Family and Medical Leave Act; D.C. Paid Family Leave Act
• Virginia: Virginia Human Rights Act (Virginia Values Act); Virginia CROWN Act; Virginia Overtime Wage Act; Virginia Minimum Wage Act
• North Carolina: North Carolina Equal Employment Practices Act; NC Wage and Hour Act; NC Retaliatory Employment Discrimination Act (REDA)
• All other applicable state and local laws where the Company operates

ISS Action strictly prohibits the use of forced, compulsory, bonded, trafficked, or child labor in any form across all of its operations and supply chain. Specifically:

• No person shall be employed by ISS Action under the age of 18 years for any role, including security services.
• All employment with ISS Action is voluntary. No individual shall be required to work under threat of penalty, debt bondage, or coercion of any kind.
• ISS Action complies fully with all applicable U.S. anti-trafficking laws, including the Trafficking Victims Protection Act (TVPA) and FAR 52.222-50 (Combating Trafficking in Persons).
• No worker shall be required to surrender identification documents, pay recruitment fees, or accept terms that limit freedom of movement as a condition of employment.
• ISS Action conducts due diligence on all labor supply chains and requires subcontractors to certify compliance with these prohibitions.

ISS Action is an Equal Opportunity Employer. All employment decisions — including hiring, compensation, assignment, training, promotion, discipline, and termination — are based on qualifications, performance, and the legitimate operational requirements of the role. The Company does not discriminate on the basis of any legally protected characteristic.

PROTECTED CHARACTERISTICS — ALL JURISDICTIONS

• Race, color, or ethnicity
• National origin or ancestry
• Sex or gender
• Gender identity or expression
• Sexual orientation
• Religion or creed
• Age (40 or older under ADEA; broader protection in some states)
• Disability (physical or mental) — ADA and applicable state equivalents
• Pregnancy, childbirth, or related conditions
• Genetic information (GINA)
• Veteran or military status (USERRA)
• Marital or domestic partnership status (CA, NJ, NY, DC)
• Medical condition or cancer history (CA)
• Hair texture or protective hairstyles — CROWN Act (CA, NY, NJ, VA, NC)
• Political affiliation or activity (CA, DC, NY, NJ)
• Personal appearance (DC)
• Family responsibilities or source of income (DC)
• Matriculation or student status (DC)
• Immigration or citizenship status, as permitted by law
• Status as a victim of domestic violence, sexual assault, or stalking (NJ, NY, DC, CA, AZ)
• Any other characteristic protected by applicable federal, state, or local law
  

  NEW JERSEY — NJLAD

  The New Jersey Law Against Discrimination covers all employers regardless of size and provides broad protection, including atypical hereditary cellular or blood trait. ISS Action’s New Jersey operations comply with NJLAD in all respects.

  WASHINGTON D.C. — DC HRA

  The D.C. Human Rights Act is among the most expansive anti-discrimination laws in the country, covering additional protected characteristics including political affiliation, personal appearance, family responsibilities, matriculation, and source of income. ISS Action’s D.C. operations comply with the full scope of D.C. HRA protections.

  CALIFORNIA — FEHA

  California’s Fair Employment and Housing Act provides broader protections than federal law, including coverage of employers with five or more employees for most provisions, and coverage of independent contractors in certain circumstances. ISS Action’s California operations are governed by FEHA standards in all employment decisions.

ISS Action is committed to ensuring that all personnel are compensated fairly and in full compliance with applicable law. Where multiple minimum wage standards apply, ISS Action complies with whichever standard is most protective of the employee.

ADDITIONAL WAGE & HOUR STANDARDS — ALL LOCATIONS

• Overtime at not less than 1.5x the regular rate for hours over 40/week per FLSA and applicable state law, including VA Overtime Wage Act and California’s daily overtime for hours over 8 in a single workday.
• Timely and accurate payment of all wages due, with clear and itemized pay statements in compliance with applicable state requirements.
• Shift limitations consistent with contractual obligations, including any client-mandated restrictions such as the 14-consecutive-hour maximum specified in relevant service agreements.
• No unauthorized or unlawful deductions from wages.
• Proper classification of all workers as employees or independent contractors in compliance with federal law and applicable state tests, including California’s ABC test under AB 5.

ISS Action provides paid sick and safe leave to all eligible employees in compliance with applicable federal, state, and local law. Where ISS Action’s leave policy exceeds these minimums, employees are entitled to the more generous benefit.

Sick and safe leave may be used for an employee’s own illness or for the care of a family member, as defined by applicable law. ISS Action does not retaliate against any employee for using accrued paid sick or safe leave.

ISS Action complies with the federal Family and Medical Leave Act (FMLA) and all applicable state family and medical leave laws, which in many jurisdictions provide greater entitlements than federal law.

• Federal FMLA: Eligible employees at covered locations are entitled to up to 12 weeks of unpaid, job-protected leave per year for qualifying family and medical reasons.
• California (CFRA/NPLA): Up to 12 weeks of job-protected leave; covers employers with 5 or more employees; includes leave for domestic partner’s serious health condition.
• New York (NY PFL): Up to 12 weeks of paid, job-protected leave for bonding, family care, or qualifying military exigency; funded through employee payroll contributions.
• New Jersey (NJFLA/NJ FLI): Up to 12 weeks of job-protected leave under NJ Family Leave Act; Family Leave Insurance provides wage replacement benefits.
• Washington D.C. (DC FMLA): Up to 16 weeks of job-protected leave for personal and family medical reasons; covers employers with 20+ employees.
• Washington D.C. (DC Paid Family Leave): Up to 12 weeks each of paid parental, family care, and medical leave, funded by employer payroll contributions.
• Virginia / Florida / North Carolina: Federal FMLA applies; Company policy supplements where applicable.

ISS Action is committed to pay equity and transparency in all jurisdictions where required by law.

PAY TRANSPARENCY

• ISS Action includes salary ranges or pay scales in job postings as required by California (SB 1162), New York (S9427A/NYC), New Jersey (P.L. 2022, c. 32), Washington D.C., and any other applicable jurisdiction.
• Upon request, current employees in covered jurisdictions may obtain the pay scale for their current position.
• ISS Action conducts regular pay equity analyses and takes corrective action where unjustified disparities are identified.

SALARY HISTORY PROHIBITION

• ISS Action does not inquire about or rely upon an applicant’s prior salary history in setting compensation in California, New York, New Jersey, Washington D.C., Virginia, or any other jurisdiction that prohibits such inquiries.
• Compensation decisions are based solely on the requirements of the role, the applicant’s qualifications, and internal pay equity considerations.

ISS Action is committed to protecting the privacy of all employees and applicants in compliance with applicable privacy law.

• California (CCPA/CPRA): California employees and applicants have rights regarding the collection, use, and disclosure of their personal information. ISS Action provides the required California Employee Privacy Notice and does not sell or share employee personal information for cross-contextual behavioral advertising.
• Personnel records are maintained securely and accessed only on a need-to-know basis.
• ISS Action complies with applicable state laws governing background checks, consumer reports, and the use of credit information in employment, including restrictions under California, New York, New Jersey, and D.C. law.
• Biometric data, where collected for timekeeping or access-control purposes, is handled in compliance with applicable state biometric privacy laws.
• Employee monitoring and electronic communications policies are disclosed to all employees in compliance with applicable law.

ISS Action supports fair chance hiring and complies with all applicable “ban the box” laws and fair chance ordinances. As a security services company, ISS Action also complies with specific licensing and background check requirements mandated by state law and client contracts.

• ISS Action does not inquire about criminal history on initial employment applications where prohibited by applicable law, including in Washington D.C., New Jersey, New York City, and other covered jurisdictions.
• Where background checks are conducted, they are performed after a conditional offer of employment, in compliance with the federal Fair Credit Reporting Act (FCRA) and applicable state equivalents.
• Any adverse action based on criminal history is conducted through an individualized assessment considering the nature and gravity of the offense, the time elapsed, and the nature of the job, in compliance with EEOC guidance and applicable state law.
• Notwithstanding the above, ISS Action complies with all mandatory background check requirements applicable to security personnel under state licensing statutes and federal contract requirements.

ISS Action maintains a drug-free workplace consistent with the Drug-Free Workplace Act and applicable client and federal contract obligations. The Company also complies with state laws that afford employees certain protections regarding lawful off-duty conduct and cannabis use.

• The use, possession, or impairment from illegal substances or alcohol on any job site or company premises is strictly prohibited and grounds for immediate termination.
• ISS Action conducts pre-employment and reasonable-suspicion drug testing in compliance with applicable state law.
• State Cannabis Protections: California, New Jersey, New York, Washington D.C., and Virginia prohibit adverse employment action based solely on an employee’s off-duty, lawful use of cannabis. ISS Action does not take adverse action based on off-duty cannabis use in these jurisdictions except where required by federal law, federal contract, DOT regulations, or where on-duty impairment is established.
• Employees subject to DOT drug testing, federal security clearance, or firearms authorization requirements remain subject to applicable federal standards regardless of state law.
• Lawful off-duty conduct that does not impair job performance, create a conflict of interest, or violate federal law or contract requirements will not be the basis for adverse employment action.

ISS Action respects the rights of all employees to freedom of association and, where applicable under law, the right to organize and engage in collective bargaining under the National Labor Relations Act (NLRA) and applicable state law. The Company will not retaliate against, penalize, or interfere with any employee who exercises these rights in accordance with applicable federal and state labor law.

ISS Action will not discipline, discharge, or otherwise discriminate against any employee for engaging in protected concerted activity, including discussing wages, working conditions, or terms of employment with co-workers.

ISS Action is committed to providing a safe, healthy, and dignified work environment for all personnel in compliance with federal OSHA standards and applicable state plan requirements.

• Full compliance with OSHA and all applicable state occupational health and safety regulations, including California’s Cal-OSHA, which is more stringent than federal OSHA in numerous respects.
• Maintenance of current safety programs, reviewed and updated at minimum annually, including site-specific protocols for security personnel deployed to client facilities.
• Participation in client-required safety compliance platforms (such as ISNetworld) and maintenance of required safety ratings for the duration of applicable service agreements.
• Zero tolerance for workplace violence, harassment, or intimidation of any kind.
• Strict prohibition on the possession or use of alcohol, illegal drugs, or unauthorized weapons on any job site or company premises, consistent with applicable law and client requirements.
• Mandatory reporting of workplace injuries, near-misses, and hazardous conditions, with prompt investigation and corrective action.
• Heat illness prevention programs for employees working in outdoor or high-temperature environments, in compliance with California’s Heat Illness Prevention Standard and applicable federal requirements.
• Compliance with all applicable workers’ compensation laws in every state of operation, including mandatory coverage and timely claims reporting.

ISS Action maintains a workplace free from harassment, bullying, intimidation, or any form of abusive conduct. This applies to interactions between employees, supervisors, clients, subcontractors, and members of the public encountered in the course of duty.

Any form of sexual harassment, hostile work environment, or discriminatory conduct is strictly prohibited and subject to disciplinary action up to and including termination.

MANDATORY TRAINING REQUIREMENTS

• California: All supervisory employees complete at least 2 hours of sexual harassment prevention training every 2 years; non-supervisory employees complete at least 1 hour every 2 years (SB 1343 / Government Code §12950.1).
• New York: All employees complete annual sexual harassment prevention training per NY Labor Law §201-g and the NYS Division of Human Rights model policy. NYC employees receive additional training under NYC Local Law 96.
• New Jersey: All employees receive annual anti-harassment training consistent with NJLAD requirements and the NJ Division on Civil Rights model policy.
• All other jurisdictions: Anti-harassment training is provided at onboarding and annually thereafter, consistent with applicable state and local guidance.

REPORTING & INVESTIGATION

• Any employee who experiences or witnesses harassment, discrimination, or abusive conduct is encouraged to report it immediately through any channel identified in Section 15 of this Policy.
• All reports are investigated promptly, thoroughly, and impartially. The identity of reporting individuals is protected to the extent practicable.
• ISS Action prohibits retaliation against any employee who makes a good-faith complaint or participates in an investigation.

ISS Action provides all personnel with access to a confidential grievance mechanism for reporting concerns related to human rights violations, labor standards breaches, safety issues, or unethical conduct.

REPORTING CHANNELS

• Direct supervisor or site manager (for operational issues)
• Human Resources Department — confidential and accessible to all employees, including by phone, email, and in writing
• Chief Executive Officer — for escalated or sensitive matters
• External regulatory agencies, including EEOC, NLRB, OSHA, applicable state civil rights agencies, and state labor departments

ISS Action strictly prohibits retaliation of any kind against any employee, subcontractor, or third party who, in good faith, reports a concern, files a complaint, opposes an unlawful practice, or participates in an investigation under this Policy or applicable law. Retaliation is itself a serious violation of this Policy and subject to disciplinary action.

ISS Action expects all subcontractors and suppliers engaged in the performance of Company contracts to uphold standards consistent with this Policy. Prior to engagement, ISS Action communicates these expectations in writing, and any subcontractor relationship is contingent upon a commitment to compliance with applicable human rights and labor standards.

ISS Action performs reasonable due diligence on labor supply chains to identify and address risks of forced labor, trafficking, and labor rights violations. Subcontractors that fail to meet these standards are subject to contract termination and, where required, referral to appropriate authorities.

As a company performing under U.S. federal government contracts, ISS Action operates under a heightened standard of compliance, including:

• E-Verify employment eligibility verification for all new hires, as required by federal contract terms and Arizona law (mandatory for all Arizona employers)
• Full compliance with applicable FAR labor clauses, including FAR 52.222-26 (Equal Opportunity), FAR 52.222-35 (Affirmative Action for Veterans), FAR 52.222-36 (Equal Opportunity for Workers with Disabilities), and FAR 52.222-50 (Combating Trafficking in Persons)
• Adherence to affirmative action and equal opportunity requirements under 41 C.F.R. §§ 60-1.4, 60-250.5, and 60-741.5
• Compliance with the Service Contract Act (SCA), including payment of applicable prevailing wage determinations and fringe benefits, on all covered federal service contracts
• Compliance with Executive Order 11246 (Equal Employment Opportunity) and, where applicable, Executive Order 14026 (increasing minimum wage for federal contractors to $17.75/hr)
• Maintenance of all required Affirmative Action Plans (AAPs) for covered federal contractors

The Chief Executive Officer of ISS Action holds ultimate accountability for this Policy. Day-to-day implementation is the responsibility of the Human Resources Department in coordination with field operations leadership and the Director of Legal & Compliance.

This Policy will be:

• Reviewed and updated annually, or upon material changes in applicable law or Company operations
• Communicated to all employees at time of hire and upon each update, in the employee’s primary language where practicable
• Made available to clients, partners, and the public upon request and published on the Company website
• Incorporated into all relevant training programs for management and field personnel
• Monitored through regular internal audits, employee surveys, and compliance reviews conducted by the HR and Legal & Compliance functions
• Supplemented, as needed, by jurisdiction-specific addenda for states or localities with requirements that exceed or differ from this baseline Policy

Violations of this Policy will be investigated promptly and thoroughly. All employees, officers, managers, and contractors are expected to cooperate fully with any investigation. Depending on the nature and severity of the violation, disciplinary action may range from written warning to immediate termination of employment or contract. ISS Action reserves the right to report violations to appropriate regulatory or law enforcement authorities where required by law.

This Policy does not constitute a contract of employment and does not alter the at-will employment relationship where applicable under state law. Nothing in this Policy limits any rights employees may have under applicable federal, state, or local law.